PB94-963723
EPA/ROD/R01-94/099
February 1995
EPA Superfund
Record of Decision:
BFI Sanitary Landfill (O.U. 1),
Rockingham, VT
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211
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DECLARATION~OR THE RECORD OF DECISION
BFI-Rockingham Landfill
Rockingham, Ver.mont
STATEMENT OF PURPOSE
This decision document represents the selected remedial action
for the BFI-Rockingham Landfill Superfund Site in Rockingham,
Vermont, developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and,
Reauthorization Act of 1986, and to the extent practicable, ~he
National oil and Hazardous Substances Contingency Plan (NCP), 40
CFR Part 300 et ~, as amended. The New England Region
Administrat'or has been delegated the authority to approve t.his . .
Record bf Detision- . . .' .
STATEMENT OF BASIS
This decision is based upon the Administrative Record which has.
been developed in accordance with Section 113 (k) of CERCLA and
which is available for public review at the Rockingham Free
Public Library and at the New England Region Waste Management
Division Records Center in Boston, Massachusetts. The
Administrative Record Ipdex. (Appendix E to the ROD) identifies
each of the items comprising the Administrative Recqrd upon which
the selectiori of the re~edial action is ba~ed.
ASSESSMENT OF THE SITE
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Actual or threatened releases of hazardous substances from t.his
Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to the public health or welfare or the environmen:.
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DESCRIPTION OF THE SELECTED REMEDY
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This ROD sets forth the selected remedy for the BFI-Rockingham
Landfill Superfund Site, which addresses both the source control
and management of migration of contamination at the Site.
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The remedial measures described in this ROD will protect ~he
drinking water aquifer and Connecticut River by minimizing
further migration of contamination into the ground water and
surface water, will eliminate the potential for direct contact
and/or incidental ingestion of the material within the landfill,
. and will control landfill gas and prevent exposure to landfill
. gas containing hazardous substances.
The selected remedy consists of operating and
existing Site controls to achieve the natural
ground water and protect surface water. This
includes: '. .
maintaining the
restoration of the
alternative
.
continued maintenance of the multi-layer cap currently
underconstructioni
.
continued operation and maintenance of the existing
leachate collection .system and groundwater collection
trench. The collected leachate and ground water will
be shipped to an off-site facility for treatment and
disposali
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continued operation and maintenance of the gas
collection and treatment system;
.
maintenance of institutional controls: to prevent
future use of the landfill that would damage the multi-
layer capi to prevent ground water use throughout the
area of Site-related coriiaminationi arid to ~ssurea'
water supply to residents with Site-related
contaminated ground water beneath their residences.
.
continued long-term monitoring of the seeps, ground
water, collected ground water and leachate, Connecticut
River surface water and sediments, and storm water run-
off, to confirm the nature ~nd extent of contamination
and confirm the restoration of the ground wateri and
.
a review of Site conditions every five years.
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.DECLARATION
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The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate for this remedial action
and is cost-effective. This remedy does not satisfy the
statutory preference for remedies that utilize treatment as a
principal element to reduce the toxicity, mobility, or volume of
hazardous substances. The selected remedy was equally protective
and more cost effective and implementable than the treatment
alternative evaluated. This remedy utilizes permanent solutions
- and alternative treatmeI}-t technologies to the maximum extent
practicable.
As this remedy will result in hazardous substances remaining
onsite above health based levels, a review will be conducted
within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
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Date
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John P. DeVillars
Regional Administrator
U.S EPA, New England Region
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NEW ENGLAND REGION
RECORD OF DECISION SUMMARY
FOR THE
BFI-ROCKINGHAM LANDFILL SUPERFUND SITE
September 1994
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BFI-ROCKINGHAM LANDFILL SUPERFUND SITE
TABLE. OF CONTENTS
Contents
Paqe Number
I.
SITE NAME, LOCATION AND DESCRIPTION. . .
. . .
1.
,
v
II.
SITE HISTORY « ENFORCEMENT ACTIVITIES. . . . .
1.
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A.
B.
Land Use « Response History
Enforcement History.
. . . . .
. . . . . .
1.
2.
. . . . .
. . . . . .
III.
COMMUNITY PARTICIPATION
. . . .
. . . . .
4.
IV.
SCOPE « ROLE OF OPERABLE UNIT OR RESPONSE ACTION
5.
v.
SUMMARY OF SITE CHARACTERISTICS. .
. . . . . .
6.
VI.
sUMMARY OF SITE RISKS. .
. . . . .
. . . . . .
10.
VII.
DEVELOPMENT AND SCREENING OF ALTERNATIVES.
. . . . .
19.
A.
B.
Statutory Requirements/Response Objectives
Technology and Alternative Development
and Screening. . . . . . . . . . . . . .
19.
. . 20.
VIII.
DESCRIPTION OF ALTERNATIVES. .
. . . .
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'21.
IX.
. SUMMARY OF THE COMPARATIVE ANALySIS OF ALTERNATIVES.
24.
X.
THE SELECTED REMEDY. . . . . . . .
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30.
A.
B.
Interim Ground Water Cleanup Levels. . . . . . . . 30.
Description of Remedial Components................ 35.
XI.
STATUTORY DETERMINATIONS
. . . . . .
. . . . .
39..
A. The Selected Remedy is Protective of Human
Health. and the Environment. . . . , , , .
. B.' The Selected Remedy Attains ARARs '. ,.', . ,
C. The Selected Remedial Action is Cost Effective
D. The Selected Remedy Utilizes Permanent Solutions
and Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable. .45.
E. The Selected Remedy Does Not Satisfy the Preference
for Treatment as a Principal Element, , . , ,. 46.
39.
40.
44.
XII.
DOCUMENTATION OF SIGNIFICANT CHANGES
........
47.
IV
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XIII, ,STATE ROLE
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
. '. . .
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49.
TABLES
FIGURES
LETTER OF CONCURRENCE
RESPONSIVENESS SUMMARY
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ROD DECISION SUMMARY
September 1994
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I.
SITE NAME, LOCATION AND DESCRIPTION
&
The Site is the BFI-Rockingham Landfill Superfund Site, also known as the
Disposal Specialists Inc. Landfill, and will hereafter be referred to as
the "Site". The Site is located along u.s. Route 5, locally known as
Missing Link Road, in the Town of Rockingham, Windham County, Vermont. The
Site is located on a terrace within 500 feet of the Connecticut River (See
Figure 1). The surrounding area is rural residential and agricultural
land. Four residences are located between the landfill and the Connecticut
River. Three of these residences are supplied water by a private water
line on BFI property. The fourth residence has a private water supply
upgradient of the Site. Much of the topography between the landfill and
the Connecticut River is too steep for development.
The Site consists of a 17 acre solid waste landfill and the surrounding
areas impacted by the Site. The impacted areas include the overburden
ground water, bedrock ground water, and at least three areas of leachate
discharge ~nd the associated seep sediments along Route 5. Two of these
areas of leachat~ discha~ge are now dry. Ther~ is a substantial
floodplain/wetland area at the base of the steep slopes between the Site
and the Connecticut River. There are no wetlands or floodplain areas on
the west side of Route 5 within the 25 acre area consisting of the landfill
and operating facility. The facility adjacent to the landfill includes an
office building, garage, a solid waste transfer station, and storage areas
for the transfer station.
The overburden ground water is discontinuous in the area of the Site.
Bedrock ground water is the primary drinking water resource for the
'residences in the area of the Site. A publicly owned sewage, treatment
works (POTW)is located directly across the Connecticut River in '
Charlestown, N.H.
A more complete description of the Site can be found in the Remedial
Investigation ,Report at pages 1-4 thru 1-16 and the Supplemental Remedial
Investigation Report at pages 3-1 thru 3-3.
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II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A.
Land Use and Response History
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The Site consists primarily of a 17 acre sanitary landfill. The
landfill and associated facilities occupy 25 acres of approx. 120
acres owned by DSI. From 1968 until 1991, the landfill received,
residential, commercial, and industrial solid and liquid waste.
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Approximately 1.2 million cubic yards of solid waste and an unknown
quantity of industrial waste were disposed of in the landfill during
its operation. The landfill stopped receiving waste in November 1991.
An interim cover of clean soil was placed over the landfill after the
end of solid waste activity. The landfill was regraded in 1993 to
establish a three foot horizontal to one foot vertical (3H:1V) grade
over the landfill.
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Prior to the 1960s, the Site was undeveloped woodland. During the
early 1960s it was used as embankment fill for the construction of
Interstate 91. In 1968, Harry K.Shepard received approval from the
Vermont Department of Health to operate a municipal solid waste
landfill. In 1969, Harry K. Shepard, Inc. deeded the landfill
property'to Disposal Specialists, Inc. (DSI) which operated the
landfill. Harry K. Shepard, Inc. was continued as a solid and
industrial waste hauling company. In 1973, Browning-Ferris
Industries, Inc. purchased DSI and Harry K. Shepard, Inc. and
continued operation of the landfill as DSI. In that same year, Harry
K. Shepard, Inc. changed its name to Browning-Ferris Industries of
Vermont, Inc. (BFI-VT).
The current and future land use of the landfill was considered non-
residential due to the impracticality of constructing residences on a
clo~ed landfill with 3H:1V slopes. The adjacent 'property is currently'
. residential. The' future land use for areas adj acent to the landf'ill
was considered residential. However, a significant portion of the'
area between the facility and the Connecticut River is not suitable
for development due to steep topography.
A site chronology is attached as Table 1. A more detailed description
of the Site history can be found in the Remedial Investigation Report.
at pages 1-5 - 1-8.
B.
Enforcement History
On May 15, 1992, EPA notified two parties, DSI, as owner and operator
of the facility, and BFI-VT, as a transporter of wastes to the
facility, Qf their potential liability with respect to the Site.
Negotiations commenced with these potentially responsible parties
(PRPs) on May 15, 1992 regarding the settlement of the PRP's liability
at the Site.
In July 1992, EPA and the two PRPs, BFI-VT and DSI, .entered into an
Administrative Order by Consent, u.S. EPA Region I CERC;LA Docket No.
1-92-1053 for the pe~fo~~ance of a remedial investigation and
feasibility study (~!!FS). EPA also recovered past costs from the
same parties under a 3~~a~ate Administrative Order by Consent, U.S.
EPA Region 1 CERCLA S=:~~: No. 1-92-1052.
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As part of the Sup~~:~~~ ~ccelerated Cleanup Model (SACM), EPA
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December 1992. In February 1993, EPA required the PRPs to prepare an
engineering evaluation/cost analysis (EE/CA) under the existing RI/FS
Order to support the selection of a NTCRA for the Site. The EE/CA
included the assumption that containment was the preferred approach
for landfill closure as described by the EPA document "Guidance for
Cond~cting Remedial Investigations and Feasibility Studies at CERCLA
Municipal Landfill Sites". .
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Based upon the EE/CA, EPA selected the installation of a multi-layer
landfill cap as the NTCRA activity in an Action Memorapdum signed
September 13, 1993. On September 24, 1993, EPA entered into a third
administrative order by consent, u.S. EPA CERCLA Docket No. I-93-1099,
for the design and implementation of the activities described in the
Action Memorandum. The design of the NTCRA was initiated in October
1993 and completed in June 1994. As of August 1994, the PRPs have
completed design and are performing the construction of the NTCRA.
The construction is expected to be completed by November 1994.
In addition, the State of Vermont .has regulated the landfill's
operations under its solid waste management program since 1958.. In
1979, the Vermont Department of Environmental Conservation (V:JEC)
collected and analyzed groundwater samples from six bedrock wells in
the vicinity of the landfill. Based upon the results of those
samples ,. the VTDEC required DSI to supply nearby" residents wi:h"" "
bottled water". In "1980, a new water supply well was installed on the
DSI property to service the facility and the residences. DSI e~~ered
into an agreement with the residents to maintain the water lir.e f8r
twenty years. Since the "installation of the water line no residences
have been supplied bottled water. Several hydrogeologic
investigations were performed during the 1980s by DSI pursuant to
VTDEC requirements.
The landfill received municipal incineration ash from 1986 to 1989.
The municipal incineration ash was disposed in a lined monofill
section in the southeastern section of the landfil~. In 1989, :SI
installed an act~ve gas collection system in order to comply w~th the
Vermont air pollution control regulations. The gas collectic~ 3"d
treatment system is operated and maintained pursuant to a per~it
issued by the Vermont Air Pollution Control Division.
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The PRPs have been active in the remedy selection process for :~is
Site. The PRPs representatives and/or contractors have atte~ded all
public meetings at the Site and the PRPs contractor prepared :~~
Remedial Investigation, Supplemental Remedial Investigation, )~j
"Feasib~lity Study Reports.
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III. COMMUNITY PARTICIPATION
Throughout the Site's history, community concern and involvement has been
moderately high. A local environmental organization and several residents
have been actively involved at the Site. EPA has kept the community and
other interested parties apprised of the Site activities through
informational meetings, fact sheets, press releases and public meetings.
On October 22, 1992 EPA held an informational meeting at the Rockingham
Town Hall in Bellows Falls, VT to announce the signing of the' .
Administrative Order and to describe the plans for the Remedial
Investigation and Feasibility Study. On April 6, 1993, EPA released a
community relations plan which outlined a program to address community
concerns and keep citizens informed about and involved in activities during
remedial activities. .
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" '
In May 1993, EPA issued a fact sheet describing the results of the remedial
investigation and human health risk assessment. In June 1993, EPA released
a fact sheet describing a proposed NTCRA to control the source of
contamination. A public information meeting was held on July 12, 1993 at
the Rockingham Town Hall in Bellows Falls to discuss the proposed NTCRA.
On July 12, 1994 EPA made the administrative record for the NTCRA available
for public r.eview at EPA's offices in Boston. and .at the Rockingham Free
Library. A thirty day comment period was held from July 13 - August 12,
1993. A public hearing was held on August 5, 1993 at the Rockingham Town
Hall to receive oral comment on the proposed NTCRA alternative and the
engineering evaluation/cost analysis. On September 13, 1993, EPA signed
the Action Memorandum selecting a multi-layer cap and expansion of the gas
collection and treatment system as the NTCRA. The Action Memorandum
included a responsiveness summary.
In October 1993, EPA awarded a technical assistance grant (TAG) to the
Vermont Public Interest Research Education Fund (VPIREF). In March 1994,
VPIREF hired technical advisors to provide technical assistance to th~
community. VPIREF has been very a.ctive in Site activities.
In April 1994, EPA issued a fact sheet announcing the upcoming
of the multi-layer cap for the NTCRA and updating the remedial
investigation and feasibility study. EPA held a public meeting
or Miss Club in Rockingham, Vermont (across from the Site) on
April 13, 1994 to discuss the fact sheet.
construction
at the Hit
EPA issued a Press Release discussing the Long-Term Monitoring Program in
May 1994. EPA l).eld :a'public meeting at the Hit or Miss.Club on May 18,
1994 to discuss a the Long-Term Monitoring Plan and the plan to sample
residential wells in the vicinity of the Site. .
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On June 15, 1994, EPA issued the Proposed Plan for the remediation of the
Site's ground water. On June 30, 19'94, EPA made the administrative record
. available for public review at EPA's offices in Boston and at the
Rockingham Free Library. EPA published a notice and brief analysis of the
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Proposed Plan in the Bellows Falls Town Crier and Sprinqfield Reporter on
June 22, 1994 and made the plan available to the public by mailing copies
of the Proposed Plan to the mailing list and placing copies at the
Rockingham Free Library.
,On June 29, 1994 EPA held an informational meeting at the Hit or Miss Club
to discuss the results of the Remedial Investigation and the cleanup
alternatives presented in the Feasibility Study and to present the Agency's
Proposed Plan. From June 30 to July 30, 1994, the Agency held a 30 day
public comment period to accept public comment on the alternatives
presented in the Feasibility Study and the 'Proposed Plan and on any other
documents previously released to the public. On July 20, 1994, the Agency
held a public meeting at the Hit or Miss Club to discuss the Propdsed Plan
and'to,accept any oral comments. A transcript of this meeting and the
comments and the Agency's response to comments are included in the attached
responsiveness summary.
IV.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The selected remedy is the second cleanup activity initiated by EPA at the
Site. The first action was the NTCRA designed to control the source of ,
ground water and surface water contamination. The NTCRA also addressed the
release of landfill gas and potential public contact with the landfill,
debris and soils. The Action Memorandum selecting the NTCRA was signed '
September 13', 1993. An Administrative' Order by Consent, sig'ned by EPA, DSI
and BFI-VT, to implement the NTCRA was signed September 24, 1993. The gas
control required by the NTCRA has been completed and the landfill cap
required by the NTCRA is currently under construction and should be
complete by November 1994. Additional overburden ground water source
control, to prevent contaminated seeps from flowing into the Connecticut
River, and institutional controls to prevent the use of the Site in any
manner that would compromise the integrity of the cap are also being
implemented under the NTCRA. The NTCRA also includes the continued
operation of" the leachate cO,llection system and ground water collectiqn
,trench. T4e NTCRA only included operation an~ ~aintenance of the cap,
lea.'chate collection, ground water collection, and gas collection and
treatment systems until the NTCRA is superseded by a long-term remedial
action. Therefore, the selected remedy also provides a determination of
the need to continue the operation and maintenance of the controls
installed under the NTCRA.
This Site has been a ,national pilot site for the implementation of the EPA
Guidance "Conducting Remedial Investigations/Feasibility Studies for CERCLA
Municipal Landfill Sites". The Site has also used the Presumptive Remedy
Statement forL~ndfill Sites and the Superfund'Accelerated Cleanup Model.
The selected remedy was developed by combining components of different
source control and management of migration alternatives to obtain a
comprehensive approach for Site remediation. All alternatives evaluated
assumed the successful construction of the NTCRA. In addition, all
alternatives evaluated ,in detail, except No Further Action, include the
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component.
v.
SUMMARY OF SITE CHARACTERISTICS
Chapter 1 of the Feasibility Study contains an overview of the Remedial
Investigation. The significant findings of the Remedial Investigation and
Supplemental Remedial Investigation are summarized below.
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Landfill
The major source of contamination of the Site is the 17 acre solid
waste landfill. The landfill is up to 100 feet deep and contains
approximately 1.2 ~illion cubic yards of material. The majority of
the landfill has slopes of 3H:1V. During the late 1960"s~nd1970's
unknown quantities of industrial waste were disposed in the landfill.
The landfill also contains a 1.5 acre lined ash monofill. (See Figure
2 for the location of the ash monofill and other Site facilities) The
industrial waste and municipal solid waste within the landfill mix
with snow melt ~nd rain water which, percolate through the waste
material to form leachate. This leachate is characterized by high
iron and manganese, elevated levels of other metals, volatile organic
compounds, semi-volatile organic compounds, and very low levels of
pesticides. The evaluation of indicator parameters also suggest that
the leachate creates a reducing condition: (See'Flgure 3 for a
conceptual cross-section of the leachate generation)
The leachate generated by the ash monofill portion of the landfill is
collected by a leachate collection system and shipped off-site for
disposal. The leachate that is not collected by the leachate
collection system enters either the bedrock or overburden ground water
system. Most of the landfill is underlain by overburden. The
leachate which flows into the overburden ground water flows
horizontally towards the Connecticut River. The overburden ground
water does not penetrate deeply into the ground because the overb~rden
soils are mostly stratified silts and clays which restrict .thS '
downward flow of'ground water. Prior to January of 1993, this
contaminated overburden ground water discharged to the ground surface
at three seep locations along U.S. Route 5.
As of January 1993, the majority of this flow is being collected by a
ground water collection trench. A small amount of the overburden
ground water still discharges to the ground surface at the location of
seep #6 during the spring and summer (See Figure 4 for the location of
seep #~). This water then flows downslope toward the Connecticut
River or infiltrates into the ground between the seep and the river.
Portions of the land:::~ are directly above or very close to the
bedrock surface. :~ :~~se areas, the leachate migrates into the
bedrock fractures a~j ~:xes with the bedrock ground water. This
leachate is believ~~ :~ ce act as a reducing agent in bedrock ~hich is
hypothesized to ca~s~ :::~ ~obilization of naturally occurring arsenic
and manganese out ~: :~~ cedrock and into the bedrock ground water.
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The bedrock ground water flows towards and eventually discharges to
,the Connecticut River.
Surface Water
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The water of the Connecticut River has been investigated throughout
th~ RI and SRI (see Figure 4 for surface water and seep sampling
locations). The results of the investigation revealed localized areas
of impact to the Connecticut River immediately adjacent to the point
where the landfill seeps flow into the Connecticut River. The,
installation of the ground water collection trench has eliminated the
impact from the two most contaminated seeps. A third seep, which is
identified as seep #6, still flows into the Connecticut River during
the spring and early summer. The cap will significantly reduce the
generation of leachate by the landfill and thus reduce the flow from
the third seep. In addition, Seep #6 has been fenced and t~e
contaminated water will be collected as part of the NTCRA.
Sampling of the Connecticut River in August 1993 and May 1994, after
the installation of the trench, revealed reduced levels of metals in
the surface water. The ground water collection trench appears to have
significantly reduced the impact of landfill seeps on the Connecticut
River. Table '2 sho~s a c6mparison of the maximum yalues dete~=ed in
the Conrtecticut River'surface water as compared with federal and'st~t~
ambient water quality criteria. Table 2 demonstrates that, while'
historical impacts may have occurred, the Connecticut River is ~ot
currently being impacted by the Site.
In addition to the seeps, there is an existing storm water discharge
pipe extending from the landfill and facility parking lot into the
Connecticut River. (See Figure 5) The discharge in the storm drain is
also fed by overburden ground water as evidenced by the consistent
flow from the pipe. Samples from the storm drain indicate very l:)w,
less than 1 part per billion (ppb) level of VOC and elevated =":~'>e 1 s of
several metals. However, river samples from this location do ~~: show
an impact from the storm drain.
Sediments
C~
The sediments located in leachate seeps adjacent to the landf:~: l~d
within the three seeps along U. S. Route 5 were sampled during :.::.e :U
(see Figure 6 for sediment sampling locations). These sedime~ts
contained VOCs and metals similar to those detected in the ass~c:.):ed
surface water at these same locations and very low levels of se':~~" 31
pesticides. In addition, low levels of polycyclic aromatic
hydrocarbons were also detected in the sediments.
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The sediments in the Connecticut River were also evaluated d~~:::: :~e
SRI. Site-related contami~ation was not deiected in the Con~~~:::~:'
River sediments significantly above the National Oceanic and
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levels. Low levels of several pesticides have been detected in the
sediment of the Connecticut River. However, these levels were not
consistent or widespread.
Air
An air quality assessment was performed as part of the RI and SRI.
This included the use of field instruments to provide an initial
screening of potential gas emissions on June 20, 1991 and a
quantitative analysis of ambient air using an eight hour sampling
device on December 9, 1992. (See Figures 7 and 8 for sampling
locations) In addition, daily air monitoring with field screening
equipment was performed in August 'and September 1993 during the'
landfill regrading project. The monitoring reflected a worst case
situation as 45,000 cubic yards of landfill material was excavated and
relocated during the regrading activities. In addition to the
screening surveys, quantitative air sampling was performed several
times a week during the regrade. These air studies confirmed that
while the landfill is a source of methane, hazardous compounds were
not detected in the ambient air above or adjacent to the landfill.
T~e results of these studies also confirmed that the gas collection
and treatment system is controlling the landfill gas. However, some
odors may still be detected when the system is down for maintenance
and when leachate is exposed at the seeps;' "
The landfill gas system was expanded in April-May 1994 to include 11
new gas extraction wells. Once the cap is completed these wells
should provide additional control over the release of landfill gas.
In addition, the cap should significantly reduce the release of odors
from the leachate seeps along surface of the landfill.
Air exposure outside the landfill was not considered a potential
exposure pathway and was only qualitatively assessed, The factors
, included in the qualitative ass~ssment were: (1) the fact that the'
'overburden ground water, ,which contains the higher levels of volatile
organic compounds, does not extend to the area of residences adjacent
to the landfill; and (2) the volatile organic compound levels in the
bedrock ground water beneath the residences are very low.
Ground water
As discussed previously, water which percolates through the landfill
enters either the overburden or bedrock ground water flow system. The
overburden ground water in the immediate vicinity of the 'landfill
contains moderate to high levels of VOCs, semi-VOCs, and metals
contamination. (See Figure 9 for overburden sampling locations) This
overburden contamination is confined to a limited area between the
landfill and east side of Route 5. The overburden ground water has
historically discharged at the top of the ravines adjacent to Route 5.
The extent of contamination in overburden ground water is shown en
Figure 10. Overburden ground water was not considered a pathway for
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human health exposure because the limited area, low yield, and steep
slopes make the development of a residential, water supply in the area
of contamination unlikely. .. '
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The majority of the contaminated overburden ground water is being
collected by the ground water collection trench. (See Figure 9 for
trench location) This water is being transported to an off-site
facility for treatment and disposal. Following the installation of
the cap, the volume of contaminated overburden ground water being
produced should be significantly reduced. The overburden ground water
that discharges at seep #6 will be collected in an extension of the
ground water collection trench as part of the NTCRA. Some overburden
ground water contamination exists in the soils and road bed east of
the ground water collection trench. This contamination will decrease
over time as clean water flushes the residual contamination.
Bedrock ground water between the landfill and the Connecticut River
also contain elevated levels of VOCs, semi-VOCs, and metals. However,
the bedrock g~ound water has much lower levels of VOCs and semi-VOCs
than the overburden ground water. (See Figure 11 for bedrock sampling
locations) The major contaminants in the bedrock ground water are
arsenic a~d manganese. The extent of bedrock contamination is shown
in Figure 12. The VOC and semi-VOC contamination is attributed to the
waste material in the landfill. The arsenic and manga~ese
cbntamination appears to result 'from the flow of'landfill' leachate
into bedrock ground water, which causes the mobilization of naturally
occurring arsenic and manganese from the bedrock into ground water.
While a significant percentage of the manganese is also contributed by
the landfill leachate, the RI sampling of the leachate seeps and
overburden ground water supports that the arsenic is primarily
contributed by the bedrock.
As shown in Figure 10, overburden ground water contamination has only
been detected in the area north of the Hit or Miss ~lub and south of
,monitoring wells 8, 9, and 10. As shown 'in Figure 12, bedrock ground
water contamination has'been detected in an area north of the Hit or
Miss Club to monitoring wells K-39 and K-40. Low levels of volatile
organic compounds (4 ppb of trichloroethene and 2 ppb of
, tetrachloroethene) detected at monitoring well K-40 indicate that the,
northern edge of the plume may extend further north than the K wells.
Water level data, which indicated the direction of ground water flow,
collected as part of the RI and SRI does not support the migration of
contaminated overburden and bedrock ground water to other areas.
~
The landfill cap will significantly reduce the generation' of l~achate.
This will result in less flow of water to the ground water collection
trench and leachate collection system and less flow into the bedrock
ground water. As the leachate flow drops contaminant concentrations
in the bedrock ground water should return to the natural levels for
bedrock in the area of the Site.
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10
A complete discussion of site characteristics can be found in the
Remedial Investigation and Supplemental Remedial Investigations
Reports at chapters 4 and 5. A discussion of the natural restoration
model for the bedrock ground water can be found in pages 93 through
115 of the Feasibility Study. .
VI.
SUMMARY OF SITE RISKS
A Human Health Risk Assessment (HHRA) and Ecological Risk Assessment were
performed to estimate the probability and magnitude of potential adverse
human health and environmental effects from exposure to contaminants
associated with the Site. The.public health risk assessment 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
characterization, 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
. public health risk as"sessment "for the BFI-Rockingham Landfill "Site .are
discussed below followed by" the conclusions of the ecological risk
assessment. .
Twenty-three contaminants of concern, listed below in Tables 3-7 were
selected for evaluation in the risk assessment. These contaminants
constitute a representative subset of the more than 76 contaminants
identified at the Site during the Remedial Investigation. The twenty-three
contaminants of concern were selected to represent 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 Section 2.3
. .
of the human health risk assessment.
(}
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p.
11
TABLE 3: SUMMARY OF CONTAMINANTS
OF CONCERN IN BEDROCK GROUND WATER
c
Contaminants
'0£ Concern
2-Butanone
Antimony
'Arsenic
Barium
Benzene
Bis(2-chloroiso
propyl) ether'
Bis(2-ethylhexyl)
phthalate
Chromium
Manganese
Nickel
Pentachlorophenol
Tetrachloroethene
Xylenes
Vinyl Chloride.
Average Maximum
Concentration Concentration Frequency
( Uq / 1) (uq/l) o£ Detection
18 370 2/34
14 28 1/32
49 282 18/32
303 1850 30/32
6 17, 10/34
11 100 1/33
8 62 10/33
5 81 5/32
1020 5830 28/32
30 102 14/32
3 3 1/34
5 12 2/34
82 1200 11/34
4 6 3/34
TABLE 4: SUMMARY OF CONTAMINANTS
OF CONCERN IN DRAINAGE POND SEDIMENTS
Contaminants
of Concern
Arsenic
Benzo(b)fluoranthene
Benzo(k)£luoranthene
Beryllium
Chromium
Manganese
Nickel
'Vanadi um
r.'
I'
Average
Concentration
, (mq/kq)
Maximum
Concentration
(mq/kq)
2.1'8
0.06
0.06
0.18
15.8
277.0
19.8
20.2
5.5
0.07
0.07
0.26
34.7,
677.0
41.5
45.0
Frequency
of Detection
4/8
2/8
2/8
2/8
8/8
8/8
8/8
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12
TABLE 5: SUMMARY OF CONTAMINANTS
OF CONCERN IN SEEP SEDIMENTS
~
Contaminants
of Concern
Average
Concentration
(mq/kq)
Arsenic
Barium
Benzo (a) anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)£luoranthene
Beryllium
Chrysene
Indeno(1,2,3-cd)pyrene
Manganese
16.5
707
0.23
0.24
'0.32
0.30
0.22
0.18
0.18
1550.0
Maximum
Concentration
(mq/kq)
Frequency
of Detection
64.8
2240.0
0.77
0.53
1.30
1. 20
0.40
0.40
0.39
3810.0
11/12
12/12
6/12
5/12
8/12
8/12
1/12
7/12
4/12
12/12
TABLE 6: SUMMARY OF CONTAMINANTS
.OF CONCERN IN DRAINAGE POND SURFACE WATER
Contamiriants
of Concern
Average
Concentration
(Uq / 1 )
4-Methy1phenol
Arsenic
Manganese
62.3
2.8
3040.0
Maximum
Concentration
(Uq /1 )
Frequency
of Detection
210
5.2
6180.0
3/3
2/4
4/4
TABLE 7: SUMMARY OF CONTAMINANTS
OF CONCERN IN CONNECTICUT RIVER SURFACE WATER
Contaminants
of Concern
Average
C.oncentration
(Uq /1 )
2.0
0.7
15.8
381.0
11.3
4-Methylphenol
Beryllium
Chromium
Manganese
Vanadium .
Maximum
Concentration
(Uq /1 )
200.0
1.1
40.0
1600.0
47.6
Frequency
of Detection
1/6
1/6
2/6
6/6
4/6
Potential human health e::ec~s associated with exposure to the contamir.ants
of concern were estimated q~an~itatively or qualitatively through the
development of several ::y;:~: ::e~ ical exposure pathways. These pathways were
. developed to reflect t::e ;:8:e~:ial for exposure to hazardous substances
based on the present uses, 9c~e~tial future uses, and location of the Site.
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r,.
c.
r)
13
The Site is a 17 acre solid waste landfill and transfer station that is
unlikely to have a future residential use. The areas to the north and
south of the landfill are residential. The area between the landfill and
the Connecticut River is very steep and heavily vegetated and future
development of that area is unlikely. However, exposure to the seep
sediments.on the landfill and between the landfill and the Connecticut
River by trespassers who might occasionally contact seep sediments was
evaluated. Bedrock ground water is the primary source of drinking water in
the vicinity of the Site and local residents rely on bedrock wells or
overburden springs for their water supply. Overburden ground water is .
discontinuous in the area of the landfill and discharges along Route 5 at
the top of steep drainages that lead to the Connecticut River. Due to the
limited extent and low yield; the overburden ground wat~r was not.
considered a current or future exposure pathway. One drainage pond on-
site and the Connecticut River adjacent to the Site are suitable for
swimming. Although the drainage pond is very small and is fenced ~he risk
assessment assumed that exposure to the drainage pond surface water could
occur during occasional swimming. The Connecticut River is a major water
body that supports a variety of recreational uses including fishing. A
sewage treatment plant is located directly across the river from the,Site.
A second sewage treatment plant is located five miles upriver on t~e 31ack
River, a major tributary of the Connecticut River. The presence of the
sewage plants make future use of this section of the river as a arinking
'water s.upply unlikely. . In the risk assessment, only exposure while.
swimming in the Connecticut River was evaluated. . . .
Seven potential exposure pathways were
Site. A more thorough description can
Health Risk Assessment. The following
pathways evaluated.
quantitatively assessed for :~e
be found in chapter 4 of the E~~an
is a brief summary of the exposure
Future potential exposure from ingestion of bedrock ground water as a
residential drinking water supply was evaluated. This pathway assu~es :hat
a future. user of bedrock ground water would drink 2 liters of conta~:~a:~d
water fo~ ~50 days per year for 30 years.
The current and future potential exposure from ingestion of the sed:~e~~s
of the three seeps along Route 5 and on the landfill were evaluated :~~ an
adolescent 6-18 years old. The adolescent was ~ssumed to ingest :J: ~?iday
of contaminated soil and visit the seep a total of 36 days per year.
The current and future potential exposure from ingestion of the sed:~~~:s
of the drainage pond on the landfill were evaluated for an adolesce~: :;-18
years old. The adolescent was assumed to ingest 100 mg/day of ccn:a~:~3:ed
soil'and visit the .drainage pond.a total of 36 days per year.
The current and future potential exposure from dermal contact wi:~ ~~:..
surface water of the drainage pond on the landfill and the Connec::~;:
River were evaluated for an adolescent 6-18 years old. The adolesc~::: ~3S
assumed to contact the surface water during a one hour swimming ~\'~':: - ...
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14
The current and future potential exposure from ingestion of the surface
water of the drainage pond on the landfill were evaluated for an adolescent
6-18 years old. The adolescent was assumed to ingest 0.05 liters of water
during a one hour swimming event in the drainage pond for a total of 36
days per year.
(,
The current and future potential ingestion of the surface water of the
Connecticut River for an adolescent 6-18 years old. The adolescent was
assumed to ingest 0.05 liters of water during a one hour swimming event in
the Connecticut River for a total of 36 clays per year.
For each pathway evaluated, an average and a reasonable maximum exposure
.est:imate was generated corresponding to exposure to the . average and the
maximum concentration detected in that particular m~dium.
Excess lifetime cancer risks were determined for each exposure pathway by
multiplying the exposure level with the chemical specific cancer 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 unlikely to
be greater than the risk predicted. The resulting risk estimates are
expressed in scientific notatiop as a probability (e:g. 1 x 10-6 for
1/1,000,000) and indicate (using this example), that an average individual
is not likely t6 have greate~ than a one in a million chance o~' developing
cancer over 70 years as a'result of site-related exposure as defined to 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. A hazard quotient is
calculated by dividing the exposure level by the reference dose (RfD) or
other suitable benchmark for non-carcinogenic health effects for an
individual compound. Reference doses have been developed by EPA to protect
sensitive individuals over the. cQurse of a lifetime 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 quotient is often expressed as a
single value (e.g. 0.3) indicating the ratio of the stated exposure as
defined to the reference dose value (in this example, the exposure as
characterized is approximately one third of an acceptable exposure level
for the given compound). The hazard quotient is only considered additive
for compounds that have the same or similar toxic endpoint and the sum is
referred to as the hazard index (HI). (For exampie:. the hazard quotient' for
a compound known to produce liver damage should not be added to a second
whose toxic endpoint is kidney damage) . .
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15
[J\
Table 8
bedrock
bedrock
maximum
depicts the carcinogenic risks for the contaminants of concern in
ground water evaluated. to reflect potential future ingestion of
ground water corresponding to the average and the reasonabl~
exposure (RME) scenarios.
~
TABLE 8
CARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTION
OF BEDROCK GROUNDWATER
Contamin- Concen- Exposure Cancer
ant of tration Factor Potency Factor
Concern (ug / l) (l/kg/day) (mg/kg/day) -1 Risk Estimate
class av max av RME
Arsenic (A) 49 282 . 1.2xlO- 1. 75 lxlO - 6xlO.
Benzene (A) 6 17 1. 2xl0-2 2. 9xl0-2 2xlO-6 6xlO-6
Bis (2-Chloroisopropyl)
ether (B2) 1.1 100 1 . 2xl 0 -2 7. Ox1.0-2 9xlO-6 axlO-5
Bis(2-ethyl h~xyl) 1. 2xl0-2. 1.4xl0-2 lxl0 -6 lxl0-5
phthalate (B2) 8 62
Pentachloro-
phenol (B2) 3 3 1. 2xl0-2 1. 2x1.0-1 4xlO -6 4xlO-6
Tetrachloro-
ethene(B2) 5 12 1. 2x10-Z 5.0xlO-z . 3xlO-6 7 xl 0-6
Vinyl 1.'2xlO-2 9xlO-5 lxlO-4
Chloride (A) '4 '6 1.9
SUM lxlO-,) 6xlO-,)
( .
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16
Table 9 depicts the non-carcinogenic risks for the contaminants of
Concern in bedrock ground water evaluated to reflect potential future
ingestion of bedrock ground water corresponding to the average and
the .reasonable maximum exposure (RME) scenarios.
NON-CARCINOGENIC RISKS
OF
Contamin- Concen-
ant of tration
concern {ug/l}
class av max
MEK {D} 18 370 2.7x10-
AntimonY{ND} 14 28 2. 7x10-2
Arsenic {A} 49 282 2. 7x10-2
Barium {ND} 303 1850 2. 7x10-2
Bis{2-chloroisopropyl}
ether {ND} 11 100 2. 7x10-2
Bis{2-ethylhexyl}
phthalate {B2}8 62
Chromium 5 81
Manganese 1002 5830
Nickel {A} 30 102.
Pentach1oro- .
phenol {B2} 3
Tetrachloro-
ethene{B2}
X 1ene D
5 12
82 1200
Exposure
Factor
{l/kg/day}
3
2.7x10-2
2. 7x10-2 .
"2.7x10-2
2.7x10-2
2.7x10-2
2.7xl0-2
2.7x10-2
<.
,
TABLE 9
FOR THE POSSIBLE FUTURE INGESTION
BEDROCK GROUNDwATER
Target
Endpoint
of
Toxicity
Reference
Dose
Fetotox.
Blood
Skin
Blood Pres.
4x10-2 Blood 7x10-3 7x10-2
Incr. Liver
2x1 0 -2 Weight 1x10 -2 8x10-2
5x10-3 none obs. 3x10-2 4x10-1
5x10-3 CNS 5.4 31.5
2xIO-2 Wgt.Loss 4x10 -2 1x10-1
3x10-2 Liver/Kidney 3x10-3 3xIO-3
lxl 0 -2 liver 1x10-2 3x10-2
2 W t.Loss lx10-3 2x10-2
HI Liver 3X10-2 1x10-'
HI Kidney 3X10-3 3 xl 0 -3
HI CNS 5.4 31.5
HI Blood 1.1 2.7
HI Skin 4.4 25.4
,>
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17
{l.
Table 10 presents a summary of the carcinogenic and non-carcinogenic
risk for all other pathways. These pathways. are summarized since they
did not contribute to an unacceptable risk at the Site.
'w
TABLE 10
RISK SUMMARY FOR OTHER PATHWAYS
Exposure Pathway
Non-Carc~nogenic
Hazard Index
Carcinogenic
Total Risk
Avq. RME Avq. RME.
Seep Sediment
Ingestion 0.2 0.5 4.0x10-6 1.0x10-S
Drainaqe Pond
Sediment Ingestion 0.02 0.04 2. Ox10-? 5. Ox10-?
Surface Water Ingestion
and Dermal Contact 0..08 0.2 1. OxlO-7 3.0xlO-.7
Total 0.10 0.24 3. Ox10-7 8: 0.X10-7
Connecticut River
Surface Water Ingestion
and Dermal Contact
0.02
0.09
lxlO-?
3.0xlO-? .
<
The results of the Human Health Risk Assessment indicate that an
. unacceptable carcinogenic and non-car'cinogenic risk would result from
"ingestion of bedrock ground water. This is a future use scenario
since no individuals are currently ingesting contaminated ground
water at the Site. The carcinogenic risk results primarily from
arsenic and vinyl chloride. Arsenic, manganese, and antimony all had
hazard quotients greater than 1. Arsenic and manganese represented
the majority of the non-carcinogenic risk at the Site under both
average and maximum scenarios. The risk estimates for antimony were
just above the hazard quotient under both the average and maximum
scenarios. Compounds which exceed an MCL or MCLG in bedrock ground
water during any of the five ro.unds of samples obtained at the Site
include: antimony, a:::-senic, barium, benzene; bis (2-ethyl hexyl)
phthalate,. chromium, ~~=~el, pentachlorophenol, tetrachloroethene,
trichloroethene, and v~~y~ chloride. In addition to the above
chemicals, the State o~ V~:::-~o~t ground water standards were also
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18
All other pathways evaluated in the human health risk assessment were
well within the 10-4 to 10-6 target risk range.
An Ecological Risk Assessment was also prepared for the Site. The
Ecological Risk Assessment evaluated the potential ecological impacts
from the release of hazardous substances to the environment. The
Connecticut River surface water and sediments were identified as the
most significant ecological habitat at the Site. Impacts to aquatic
receptors were assessed using federal and Vermont ambient water
quality criteria for surface water impacts and NOAA effects range 'low
and medium sediment quality criteria for sediment impacts. A hazard
quotient for ecological receptors was prepared by dividing the
.' average and maximum Goncentrations by the selected criteria.
The Ecological Risk Assessment concluded that localized areas of the
Connecticut River surface water were impacted by the landfill seeps.
Aluminum, chromium, iron, and lead were identified as contributing to
a Hazard Index significantly greater than 1 based upon the maximum
concentrations. Connecticut River sediments did not show a hazard
index above 1 based upon the effects-range medium criteria and a ~ow
hazard index of 3 resulted from the evaluation based upon the
effects-range low criteria.
The Ecological Risk Assessment also concluded that the sediments and.
surface water of the seeps would be unacceptable aquatic habitat:
The Ecological Risk Assessment was prepared using data collected
prior to the installation of'a ground water collection trench which
has eliminated two of the three seeps impacting the Connecticut
River. The third seep is still uncontrolled. Data collected after
the installation of the ground water trench demonstrates that impacts
to the Connecticut River have been significantly reduced. Table 2
shows the maximum levels detected in the Connecticut River during :~e
10/92, 8/93, and 5/94 sampling events. All of the metals detected in
these sampling events were below the.ambient water quality crit~ria.
Therefore, there is no longer an impact to the Connecticut River :rom
the Site provided surface water seeps are controlled in the fut~re.
Figure 13 shows the locations of the areas evaluated in the
Ecological Risk Assessment. Table 11 provides a summary of the
results of the Ecological Risk Assessment.
Actual or threatened releases of hazardous substances from this site,
if not addressed by implementing the response action selected i~ :~:s
ROD,' may present an imminent and substantial endangerment to public
health, welfare, or the environment. In particular, the future.
potential ingestion of contaminated bedrock ground water as a
drinking water supply would represent an unacceptable risk to r.~~ ,::
health.
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19
(J"
VII., DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. Statutory Requirements/Response Objectives
c.
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 CERCLA establishes several other statutory requirements
and pr.eferences, including: a requirement that EPA's remedial
action, when complete, must comply with all federal and more
stringent state environmental standards, requirements, criteria
or limitations, unless ,a waiver is invoked; a requirement that'
EPA select a remedial action that is cost-effective and that
utilizes permanent solutions and alternative treatment technol-
ogies or resource recovery technologies to the maximum extent
practicable; and a preference for remedies in which treatment
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 alterna-
tives were developed to be consistent with these Congressional
mandates. .
Based on preliminary information relating to types. of contami~
nants, 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: '
Landfill (Source Area) Remedial Action Oblectives
.
Prevent, to the extent practicable, the potential for
water to contact or infiltrate through the debris mass;
.
Prevent, to the extent practicable, the generation of
landfill seeps and the migration of landfill impacted
surface water into the Connecticut River; .
.
Control landfill gas emissions so methane gas does not
represent an explosion hazard; prevent, to the extent
practicable, the inhalation of landfill gas containing
hazardous substances, pollutants, or contaminants; and
, meet state and federal air standards;
.
Prevent, to the extent practicable, the migration of
contaminated ground water/leachate beyond the points of
compliance by controlling the source of the
contamination;
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.8
20
8
Minimize the potential for slope failure of the debris
mass associated with the multi-layer landfill cap or
any future action;
. .
8
Prevent, to the extent practicable, direct contact with
and ingestion of soils/debris within the landfill and
beneath the landfill;
Ground Water Remedial Action Obiectives
8
Prevent, to the extent practicable, the ingestion of
landfill-impacted bedrock grqund water exceeding EPA
Safe Drinking Water Act Maximum Contaminant Levels
(MCLs), Vermont Primary Ground Water Quality Standards,
or in their absence, the more stringent of an excess
cancer risk of 1 x 10-6 for each compound or a hazard
quotient of 1 for each noncarcinogenic compound, by any
individual who may use the bedrock ground water within
the area of landfill-impacted ground water or within an
area that could become impacted as a result of pumping
activities; .
Restore the bedrock ground water at the edge of the'. . .
WastB Management Unit to: MCLs, Vermont Primary Ground
Water Quality Standards, or in their absence, the more
stringent of an excess cancer risk of 1 x 10-6 for each
compound or a hazard quotient of 1 for each
noncarcinogenic compound.
Surface Water (Ecoloqical) Remedial Action Obiectives
8
Protect off-site surface water by preventing the
.occurrence of landfill impacted seeps;
Meet'federal and state applicabl'e or relevant and
appropriate requirements (ARARs) for any surface water
discharge to the Connecticut River; and
8
8
Provide long term monitoring of the surface water and
sediments of the section of the Connecticut River
adjacent to the landfill to assure that no landfill
related impacts occur in the future.
B. Technology 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
requirements, a range of alternatives were developed for the
site.
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21
o
~
With ~espect to source control, the FS assumed the successful
implementation of the NTCRA. The NTCRA included the construction
of a multi-layer low permeability landfill cap to control the
generation of leachate which is the source of ground water
contamination. In addition, the NTCRA involved the collection
and treatment of leachate from the ash monofill leachate
collection system, collection and treatment of ground water from
the ground water collection trench, expansion of the active gas
collection and treatment system, and institutional controls to
prevent the future use of the cap in any manner that would reduce
its effectiveness. Since the NTCRA addressed all of the source
control remedial action objectives, .only the need to continue to
operate and maintain the NTCRA components was evaluated as source
control alternatives.
With respect to ground water response action, the FS developed a
limited number of remedial alternatives that attain site specific
remediation levels within different timeframes using different
technologies and a no action alternative.
As discussed in Chapter 3.0 of the Feasibility Study, the RI/FS
identified, assessed and screened technologies based on irnple-
mentability, effectiveness, and cost. The identificat{on and
s~reening of technologies is sho~n irt Table 12. These.
technologies were combined into source control (SC) and
management of migration (MM) alternatives. Chapter 4.0 of the
Feasibility Study 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 5 of
the Feasibility Study. In summary, the t~o source control and
. three management of migration remedial alternatives screened in
Chapter 4.0 were combined into 3 site-wide alternatives. The 3
site-wide alternatives were retained for detailed analysis.
. Chapter 4 of the FS discussed the alternatives that were retained
through the screening process, as well as those that were
eliminated from further consideration.
VIII.
DESCRIPTION OF ALTERNATIVES
~
,
. This Section provides a narrative summary of each alternative
evaluated. A detailed assessment of each alternative can be
found in Chapters 4 and 5 of the Feasibility Study.
n
Alternative SW-1:
No Further Action:
This serves as a baseline ror comparison with the other remedial
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22
Contingency Plan. Under this alternative, no extraction and
treatment of the ground water or maintenance of the existing
leachate collection, ground water collection, or gas extraction
system would occur. In addition, the multi-layer cap and
institutional controls would not be maintained. Long-term
monitoring and five year reviews of Site conditions would be
included in this alternative.
~l
b
Annual monitoring costs: $110,OOO/year for at least thirty years
Net Present Worth: $1,400,000
ALTERNATIVE SW-2: Manaqement and Natural Restoration:
SW-2 consists of operating and maintaining the existing Site
controls to achieve the natural restoration of the ground water
and protect surface water. This alternative includes:
.
continued maintenance of the multi-layer cap currently
under construction;
.
. .
continued operation and ' maintenance of the existing
leachate collection system and ground water collection
trench. The collected leachate and ground water will'
.be shipped to an off-site facility for tre~tment and
'disposal'; .
.
continued operation and maintenance of the gas
collection and treatment system;
.
maintenance of institutional controls: to prevent
future use of the landfill that would damage the multi-
layer cap; to prevent ground water use throughout the
area of Site-related contamination; and to assure a
water supply to .residences with Site-related
contaminated ground waterbBneath their residence.
.
continued long-term monitoring of the seeps, ground
water, collected ground water and leachate, Connecticut'
River surface water and sediments, and storm water run-
off to confirm the nature and extent of contamination
and confirm the restoration of the ground water; and
a review of Site conditions every five years.
n
.
The operation and maintenance activities for the multi-layer cap
and gas system would con::nue for at least thirty years: The
operation and maintenance of the leachate collection and ground
water collection sys:e~s Nou~d continue for as long as these
systems collect wate~,
Estimated Time =~ =~eration: at least 30 years
Estimated Annua: ~~erations and Maintenance Costs:
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23
Q
years 1 - 5: $
years 5 - 15: $
years 16 - 30:$
Estimated Total Cost
400,OOO/year
200,OOO/year
90,OOO/year
(net present worth) :
$2,900,000
-::
Alternative SW-3: Ground Water Extraction and Treatment:
This alternative would control the further spread of
contamination through the bedrock ground water by extracting
ground water using five extraction wells.
Contaminated water pumped from wells would be treated to remove
metals and VOCs by separate processes; Metals would be removed
using a chemical precipitation and flocculation process to
separate metals from the ground water. Water would be removed
from the residual solids and t'he solids would be shipped to a
hazardous waste disposal facility, if deterITlined to be hazardc'...;s,
or to an off-site solid waste landfill, if determined to be non-
hazardous. The water extracted from the.solids then would be
processed through the on-site ground water treatment system.
Ground water then would pe treated for removal of VOCs using a:r
stripping and carbon adsorpti6n. In air stripping, the
. contaminated ground w?lter is pumped to the top of a tower where,
as the water cascades down, air is forced up through the tower,
The rush of air through the contaminated water transfers VOCs in
the w~ter to the air stream. The resulting air stream is then
passed through an activated carbon filter to which contaminanrs
adhere before the air is released to the atmosphere. The water
leaving the air stripper would also pass through carbon filters
to further reduce the levels of organic compounds prior to
discharge.
Water would be treated to meet the surface water discharge
req1,.liremeJ;lts established by the State of Vermont . T.reated wa:~~:
wouid be discharged from the system through a pipe into the
Connecticut River. Alternative SW-3 is described in more deta::
in Section 5.0 of the Feasibility Study.
00
Estimated Time for Design and Construction: 2-3 years
Estimated Time of Operation: 12-14 years for Ground Wate~
Treatment and at least 30' years for cap, gas system, and
monitoring
Estimated Capital Cost: $1,100,000
Estimated Annual Operations and Maint'enance Costs:
years 1 - 3: $ 600,OOO/year
years 2 - 5: $ 400,OOO/year
years 5 - 15: $ 380,OOO/year
years 16 - 30:$ 90,OOO/year
(net present worth at 7%): $4,350,000
Estimated Total Cost (Capital and net present worth) :
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IX.
24
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
,-,'
Section l2l(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 National Contingency Plan 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
following is a summary of the comparison of each alternative's
strength and weakness. with respect to the nine evaluation
criteria. These criteria are summarized as follows:
Threshold 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 the
environment addresses whether or not a remedy
provides adequate protection and describes how
risks posed through. ea~h pathway ar~. eliminated,
reduced or controlled through treatment,
engineering controls, or institutional controls.
2.
Compliance with applicable or relevant and
appropriate requirements (ARARS) addresses
or not a remedy will meet all of the ARARs
other Federal and State environmental laws
provide grounds for invoking a waiver.
whether
of
and/or
Primary Balancinq 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
the criteria that are utilized to assess alter-
natives .for the long-term effectiveness and
pe~manence they afford, along with the degree of
certainty that they will prove successful. .
p,
Reduction of toxicity, mobility, 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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.q
co
25
5.
Short ter.m effectiveness addresses the period of
time needed to achieve protection and any adverse
impacts on human health and the environment that
may be posed during the construction and
implementation period, until cleanup goals are
achieved.
6.
Implementability addresses the technical and
administrative feasibility of a remedy, including
the availability of materials and services needed
to implement a particular option.
7.
Cost includes estimated capital and Operation.
Maintenance (O&M) costs, as well as. present-worth
costs.
Modifvinq Criteria
The modifying criteria are used on the final evaluation of
remedial alternatives generally after EPA has received
public comment on the RI/FS and Proposed Plan.
8.
State acceptance addresses the State's position
a~d key concerns related to the prefer.red
alternative and other alternatives, and the.
State's comments on ARARs or the proposed use of
waivers.
9.
Community acceptance addresses the public's
general response to the alternatives described in
the Proposed Plan andRI/FS report.
A detailed assessment of each alternative according to the
nine c~iteria can be found in Chapter 5 6f the Feasibility
. Study.
Following the detaiied analysis of each individual alterna-
tive, a comparative analysis, focusing on the relative
performance of each alternative against the nine criteria,
was conducted.. This comparative analysis can be found in
Chapter 6 and Table 6.1 of the Feasibility Study.
"
The section below presents the nine criteria and a brief
narrative summary of the alternatives and the strengths and
weakne$ses.according to the detailed and comparative
analysis. .
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26
1. Overall Protection of Human Health and the Environment
addresses how an alternative as a whole will protect human
health and the environment. This includes an assessment of
how public health and environmental risks are properly
eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
),..\
'>
Alternatives SW-2, the selected remedy, and SW-3 provide
overall protection by preventing direct contact, ingestion,
and inhalation of Site contaminants. ,Protection is provided
by: preventing contact with soils and debris buried within
the landfill by maintaining the multi-layer landfill cap
cons'tructed as part of the NTCRA; prevent'ing exposure to
airborne contamination by operating the existing gas
collection and treatment system; preventing ingestion of
contaminated bedrock ground water, in t~e short term,
through the use of institutional controls and maintenance of
the water line to residences with ground water contaminated
by the landfill, and in the long-term by restoring the
ground water to drinking water standards; and protecting the
Connecticut River by maintaining the multi-layer cap,
leachate collection system~ and ground water collection
trench to prevent ~ontaminated seeps from flowing into the
Connecticut River. '
In addition, alternative SW-3 would provide additional
containment of the ground water during the time period
required for groundwater restoration by extracting ground
water at the edge of Route 5 adjacent to the landfill.
However, alternative SW-3 would have several
implementability concerns due to steep topography and the
lack of connectivity between the bedrock fractures. In
addition, with the existence of the water line ,and the
natura.l discharge of the bedrock ground water to, the ,
Connecticut River at' undetectable levels, there is a very
low probability of exposure to the bedrock ground water
during the time period required for restoration.
Alternatives SW-2 and SW-3 would achieve protection in a
similar time period. Only SW-1, the no action alternative,
would not meet this criteria. SW-1 would allow for the
degradation of the cap and'other control systems. This
would lengthen the time period for ground water restoration
and allow the seeps to flow to the Connecticut River.
()
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27
u
,2. Com liance with A olicable or Relevant and A ro riate
Requirements (ARARs) addresses whether or not a remedy
complies with all state and federal environmental and public
health laws and requirements that apply or are relevant and
appropriate to the conditions and cleanup alternatives at a
specific Site. If an Applicable or Relevant and Appropriate
Requirement (ARAR) cannot be met, the analysis of the
alternative must provide the grounds for invoking a
statutory waiver.
G
With the exception of the no action alternative (SW-l), all
of the other alternatives that received detailed analysi~ in
the FS would meet the identified ARARs. The no action
alternative would not meet ARARs because it would allow the
continued release of contaminants from source areas which
would not allow for the restoration of the ground water to
federal and state drinking water standards. The no action
alternative, SW-l, would also fail to meet the closure'
requirements for landfills as required by Subparts Nand G
of the Resource Conservation and Recovery Act. Th~se
requirements are described in detail in Chapters 2 and 5 of
the FS.
3. Lonq-term Effectiveness and. Permanence refers to the
. ability of an alternative to maintain reliable protection of
human health and the 'environment over time once the remedial
action objectives and cleanup levels have been met.
G
Both SW-2 and SW-3 would achieve the same level of long-term
effectiveness and permanence in a comparable time frame.
The ground water would be restored to drinking water
standards in approximately 15 years for SW-2 and 13 years
for SW-3: . The long-term effectiveness and permanence of
both alternatives SW-2 and SW-3 relies primarily on the,
maintenance of the multi-iayer cap, 'ground water collection
trench, leachate collection system, and gas collection
system. SW-2 and SW-3 significantly reduce the mobility of
the contaminants within the landfill debris mass because the
multi~layer landfill cap will prevent infiltration from
contacting and mixing with the landfill waste material. The
multi-layer cap and gas collection system are reliable
technologies if they are properly maintained. The landfill
cap and ground water collection trench will also prevent the
generation of seeps that could flow to the Connecticut
River. Alternative' SW-l, the no action alternative, is noe
considered per~a~~nt or effective in the long term because
the multi-laye~ :a~d:ill cap and related systems would not
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28
4. Reduction of Toxicity, Mobility, or Volume throuqh
Treatment are three principal measures of the overall
performance of an alternative. The 1986 amendments to the
Superfund statute emphasize that, whenever possible, EPA
.should select a remedy that uses a treatment process to
permanently reduce the level of toxicity of contaminants at
the Site, the spread of contaminants away from the source of
contamination, and the volume, or amount, of contamination
at the Site.
l>
Alternatives SW-2 and SW-3 achieve a reduction in toxicity,
mobility, and volume through treatment of the landfill gas
and. treatment of the collected overburden ground water and
leachate. Only SW-3 includes treatment as a principle
component of the remedy through treatment of the collected
bedrock ground water. SW-1, no action, would not provide
any reduction of toxicity, mobility, or volume through
treatment.
s. Short-term Effectiveness refers to the likelihood 0:
adverse impacts on human health or the environment that ~ay
be posed during the construction and implementation of an
alternative until remedial acti6n objectives and cleanup
levels are achieved. ..
All of the alternatives retained for detailed analysis in
the FS would have minimal short term impacts. No additional
excavation activities within the landfill would occur under
the alternatives considered. However, as part of SW-3 some
increase in traffic and construction impacts would occur as
a result of the installation of the bedrock ground water
extraction wells. The time period until remedial action
objectives are achieved are comparable, 13 years vs. IS
. y~ars, for alternative SW-3 and SW-2, .respectively. Th~
time period to achieve remedial action objectives under
alternative SW-l could not be estimated.
In addition, SW-2 and SW-3 would be effective until
restoration is achieved by providing water to the residenc~s
through maintenance of the water line, implementing a deed
restriction to protect the cap and prevent ground water ~s~
in the. area of impacted ground water, and maintaining the
leachate collection system and ground water collection
trench to prevent contaminated surface water from.migrat:~~
to the Connecticut River.
'">
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29
(..
6. Implementabilitv refers to the technical
administrative feasibility of an alternative,
availability of materials and services needed
the alternative.
and
including the
to implement
u
Alternative SW-2 would be readily implementable. All of SW-
2 and the majority of alternative SW-3 relies upon'the
operation and maintenance of controls previously'
constructed. The materials and services required to
maintain the landfill cap, gas collection and extraction
system, ground water collection trench, and leachate
collection system are readily available. Alternative SW-3
has the most-significant implementability concerns.' The
extraction of ground water from fractured bedrock, as
required under SW-3, would be very difficult and the extent
to which a proper capture zone can be achieved will not be
known until pump tests are performed. In addition, reducing
metals concentrations in the. treatment system discharge to
ambient water quality standards can be very difficult given
the extremely low acceptable levels established by these
criteria. Alternative SW-l would be technically
implementable as no activities other than monitoring are
required . However, the administrat.i vefeasibility of this.
alternative would be low given the existence of several'
state permits requiring the operation of the gas collection
and treatment system and the closure of the landfill.
7. Cost includes the capital (up-front) cost of
implementing an alternative as well as the cost of operating
and maintaining the alternative over the long term, and net
present worth of both capital and operation and maintenance
costs.
Alternative SW-l, No Action is the least costly.
. alternative'. Excluding the no action alternative, EPA's .
SW-2, the selected alternative, would have a 30 year net
present worth of $2,900,000 as compared to alternative SW-3
at $5,450,000. SW-2 is the most cost-effective of the
alternatives that are protective of human health and the
environment and comply with ARARs.
. .'
8. State Acceptance addresses whether, based on
,of the RI/FS and Proposed Plan, the State concurs
opposes, or has no comment on the alternative EPA
selected as the remedy for the Site.
its review
with,
.has
VTDEC has been extensively involved in all Site activities
to date. The VTDEC has provided EPA with a letter of'
concurrence with the selected remedy. This letter is
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30
9. . Community Acceptance addresses whether the public
concurs with EPA's Preferred Alternative. Community
acceptance of this cleanup proposal will be evaluated based
on comments received at the upcoming public meetings and
during the public comment period.
As presented in the Responsiveness Summary, attached as
Appendix D, the public did not strongly oppose the selected
remedy. The technical assistance grant (TAG) group, VPIREF,
provided extensive comments regarding the RI/FS and
. requested additional evaluations of the risk from exposure'
to household vapors and the extent of contamination. The
TAG group also opposed the continued discharge of the.
bedrock contamination into the Connecticut River. EPA
considered all of the public comments received. A response
to all of the TAG groups comments is presented in the
Responsiveness Summary.
x.
THE SELECTED REMEDY
The selected remedy combines the previously implemented NTCRA
activities at the Site, including a multi-layer landfill cap,
with the natural attenuation/dilution processes. This
combin~tion of source 'control and managemen~ of migration actions
will result in the restoration of the bedrock ground water to
drinking water standards within 15 years of the completion of the
cap and protect surface water by preventing the generation of
landfill impacted seeps that could migrate to the Connecticut
River. .
A.
Interim Ground Water Cleanup Levels
Interim cleanup levels have been established in ground water
for contaminants of concern identified in the Baseline Risk
Assessment found to pose an unacceptable risk to either.
public health or the environment. Int~rim cleanup levels
have been set based on the ARARs (e.g., Drinking Water
Maximum Contaminant Level Goals (MCLGs) and MCLs) as
available, or other suitable criteria described below.
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. At the time that
Interim Ground Water Cleanup Levels identified in the ROD
and newly promulgated ARARs and modified ARARs which call
into ,question the protectiveness of the remedy have'been
achieved and have not been exceeded for a period of three
consecutive years, a risk assessment shall be performed on
the residual ground water contamination to determine wheth~r
the remedial action is protective. This risk assessment of
the residual ground water'contamination shall follow EPA
procedures and will assess the cumulative carcinogenic and
non-carcinogenic risks posed by an individual ~onsuming
b
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31
v
bedrock ground water. The residual risk assessment will
include sampling of a sufficient number of Site monitoring
wells. for VOCs, SVOCs, target analyte list metals, and
pesticides to determine if constituents not previously
identified as cleanup levels represent an unacceptable
carcinogenic or non-carcinogenic risk or exceed federal or
state drinking water standards. If, after review of the
risk assessment, the remedial action is not determined to be
protective by EPA, the remedial action shall continue until
e.ither protective levels are achieved, and are not exceeded
for a period of three. consecutive years, or until the remeqy
is otherwise deemed protective. These protective residual
levels shall constitute the final cleanup levels for this'
Record of Decision and shall be considered performance
standards for any remedial action.
o
Because the aquifer at and beyond the compliance boundary
for the landfill is a federal Class IIB and a State of
Vermont. Class III aquifer, which are both considered
potential source of drinking water, MCLs and non-zero MCLGs
established under the Safe Drinking Water Act are ARARs.
Interim cleanup levels for known, probable, and possible
carcinogenic compound's (Classes A, B., and C) ~ave been
eBtablished to protect against 'potential carcinogenic
effects and to conform with ARARs. Because the MCLGs for
Class A & B compounds are set at zero and are thus not
suitable for use as interim cleanup levels, MCLs and
proposed MCLs have been selected as the interim cleanup
levels for these Classes of compounds. Because the MCLGs
for the Class C compounds are greater ttan zero, and can
readily be confirmed, MCLGs and proposed MCLGs have been
selected as the interim cleanup levels for Class C
compounds.
Interim cleanup levels for Class D and E compounds (not
classified, and no evidence of carcinogenicity) have been
established to protect against potential non-carcinogenic
effects and to conform with ARARs. Because the MCLGs for
these Classes are greater than zero and can readily be
confirmed, MCLGs and proposed MCLGs have been selected as
the interim cleanup levels for these classes of compounds.
~)
In situations where a promulgated State standard is more
stringent than values established under the Safe Drinking
Water Act, the State standard was used as the interim
cleanup level. In the absence of an MCLG, an MCL, a
proposed MCLG, proposed MCL, State standard, or other
suitable criteria to be considered (i.e., health advisory,
state guideline) an interim cleanup level was derived for
each compound having carcinogenic potential (Classes A, B,
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32
per compound considering the ingestion of ground water. In
the absence of the above standards and criteria, interim
cleanup levels for all other compounds '(Classes D and E)
were established based on a level that represents an
acceptable exposure level to which the human population,
including sensitive subgroups, may be exposed without
adverse affect during a lifetime or part of a lifetime,
incorporating an adequate margin of safety (hazard quotient
= 1) considering the .ingestion of bedrock ground water. If
a value described by any of the above methods was not
capable of being detected with good precision and accuracy
or was below what was deemed to be the background value,
then the practic~l quantific~tion.limit or background val~~
was used as appropriate for the Interim Ground Water Cleanup
Level.
D
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u
33
Table 13 below summarizes the Interim Cleanup Levels for
carcinogenic and non-carcinogenic contaminants of concern
identified in ground water.
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34
reflects a risk management factor.
While these interim cleanup levels are consistent with ARARs or
suitable TBC criteria for ground water, a cumulative risk that
could be posed by these compounds may exceed EPA's goals for
remedial action. Consequently, these levels are considered to be
interim cleanup levels for ground water. At the time that these
Interim Groundwater Cleanup Levels identified in the ROD and
newly promulgated ARARs and modified ARARs which call into
question the protectiveness of the remedy have been achieved and
have not been exceeded for a period of three consecutive years, a
risk assessment shall .be.performed on the residual ground water'
contamination to determine whether the remedial action is
protective. This risk assessment of the residual ground water
contamination shall follow EPA procedures and will assess the
cumulative carcinogenic and non-carcinogenic risks posed by
ingestion of bedrock ground water. If, after review of the risk
assessment the remedial action is not determined to be protective
by EPA,' the remedial action shall continue until either
protective levels are achieved and are not exceeded for a period
of three consecutive years, or until the remedy is otherwise
deemed protective. These protective residual levels shall.
constitute the final cleanup levels for this Record of Decision
'and shall: be considered performance standards for any remedial
action.
CO>
All Interim Groundwater Cleanup Levels identified in the ROD and
newly promulgated ARARs and modified ARARs which call into
question the'protectiveness of the remedy and the protective
levels determined as a consequence of the risk. assessment of
residual contamination, must be met at the completion of the
remedial action at and beyond the points of compliance which is
the boundary of the Waste Management Unit as defined. by ,
monitoring wells adjacent to the landfill and shown in figure 11.
The points of compliance include the' ground water collection
trench along Route 5, monitoring wells E23, E24, C17, C18, MW-6,
MW-7, MW-3, MW-4, MW-9, MW-IO, J-37, J-38, K-39, K-40, H-27, H-
28, B-3, G-25, G-26, and any new bedrock monitoring wells in
close proximity to the landfill in a flow direction not covered
by the previously mentioned monitoring wells. The Waste
Management Unit includes the 17 acre landfill and associated
surface water controls, gas collection and treatment system, and
ground water and leachate collection systems and storage tanks.
EPA has estimated that these levels will be obtained within 15
years after completion of the landfill cap which is being
installed as part of the NTCRA. .
(>
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q
B.
35
DescriPtion of Remedial Components
The selected remedy, SW-2, consists of operating and maintaining
the existing Site controls to achieve the natural restoration of
the ground water and protect surface water. This alternative
includes:
v
.
.
continued maintenance of the multi-layer cap currently
under construction;
.
continued operation and maintenance of the existing
leachate collection system and ground water collection
trench. The collected leachate and ground water will
be shipped to an off-site facility for treatment and
disposal; .
.
continued operation and maintenance of the gas
collection and treatment system;
.
maintenance of institutional controls: to prevent
future use of the landfill that would damage'the multi-
layer cap; to prevent ground water use throughout the
area of Site-related contamination; and to assure a
water supply to residents with Site-related
contaminated ground water beneath their residences.
.
continued long-term monitoring of the seeps, ground
water, collected ground water and leachate, Connecticut
River surface water and sediments, and storm water run-
off, to confirm the nature and extent of contamination
and confirm the restoration of the groQnd water; and
a review of Site conditions every five years.
The continued maintenance of the multi-layer cap will involve the
implementation of the landfill cap maintenance plan. This plan
will require periodic inspection of the cap to identify areas of
erosion or signs of cap failure. Slippage of the cap due to
steep slopes is the most serious maintenance concern. The cap
has been designed to minimize the potential for slippage.
However, the inspections will be performed to identify any mass,
movements of the cap. While direct measurements of the overall
leachate generation'ii not possible, the observation of the watei
levels in the overburden wells and the leachate and ground water
collection trenches will provide information regarding the
effectiveness of the cap. The reduction in contaminant
concentrations in the bedrock ground water will also provide an
indication of the cap's effectiveness. In the event that
leachate and overburden levels do not decrease and the bedrock
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36
ground water is not fully restored, the potential for horizontal
flow into the landfill from the bedrock will be re-evaluated.
This re-evaluation will focus on the need to provide upgradient
controls to further reduce leachate generation and restore
bedrock ground water concentrations. In addition, the slopes
adjacent to the landfill on both sides of Route 5 will be '
periodically inspected to identify any new seeps that may result
from changes in ground water flow after cap installation.
,-
The continued operation and maintenance of the leachate
collection and ground water collection system will involve the
periodic replacement of pumps and piping as necessary. The pumps,
leachate tank, ground' water collection tank, and piping will be
periodically inspected. The collected leachate and ground water
will continue to be shipped to an off-site facility. Testing of
the leachate and ground water to date indicates that the levels
are below the standards for characteristic wastes, therefore, the
collected leachate and ground water is currently considered a
non-hazardous waste water. The acceptability of an off-site
facility will be based upon state and federal regulations, the
analytical results from the leachate and ground water, and EPA
guidance regarding CERCLA discharges to off-site facilities.
Tha continued operation and maintenance of the gas collection and'
treatment' system involves the collection' of methane' levels in gas
monitoring probes on a regular basis. In addition, the flare
must be operated and maintained in accordance with the operating
permit issued by the Vermont Air Pollution Control Division.
This permit specified that the gas flare temperature must be
maintained at a minimum of 1600 F.
Institutional controls in the form of deed restrictions on the
property owned by BFI-VT and DSI are'being implemented as part of
the NTCRA. These deed restrictions will prevent the use of the
landfill in any manner that wO,uld compromise the effectiveness of
the dap and prevent future use of the contaminated ground water
on BFI owned property. (See Figure 14 for the extent of BFI (DSI)
owned property) In. addition, BFI-VT has entered into agreements
with the owners of three properties in the area of the
contaminated ground water requiring BFI-VT to provide them with a
water system at no charge for a period of twenty years from the
date of full and final closure of the entire BFI-Rockingham solid
waste disposal facility. This period is considerably longer than
the estimated time for the natural attenuation of contaminants in
the ground water. A drinking water supply line will be provided'
to the residents until EPA and VTDEC determine that the water
beneath the residences is acceptable for use as a water supply.
In addition, when the water beneath their residence is considered
acceptable for use as a drinking water supply, a new water supply
well will be installed for each of the residences that were not
able to use the ground water beneath their residence. EPA will
evaluate the need for, and if it deems appropriate, require
~
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37
(1
additional institutional controls if the above referenced
controls prove ineffective at preventing the extraction of
contaminated ground water.. .
.:>
Long-term monitoring of the surface water, ground water,
sediments, and residential water supplies will be performed.
This monitoring will focus on establishing long-term trends in
each media and confirming the restoration of the media. The
Long-Term Monitoring Program will develop a method for tracking.
the restoration of ground water to confirm that the cleanup model
was correct. The Long-Term Monitoring Plan will also include
interim goals to evaluate the effectiveness of the selected
remedy,
The surface water of the Connecticut River will be sampled to
confirm that the landfill is not impacting the Connecticut River.
At least five locations in the Connecticut River will be sampled
until the grass cover on the cap is well established. After the
grass cover on the cap is well established, the Connecticut River
will be sampled at the points at which surface water from the
landfill discharges to the river and at least one background
location. In particular, surface water will be sampled to comply
with storm water discharge requirements. The th~ee on-site
z;etention ponds. shall be s'ampled periodically for VOCs., SVOCs, .
and TAL metals to characterize the quality of the water from the
surface water run-off and drainage layer. Sediment samples will
be obtained from the Connecticut River at the same locations as
the surface water samples until EPA determines that sediment
samples are no longer necessary. The surface water and sediments
of any leachate seeps flowing after the installation of the
landfill cap will be sampled. Connecticut River surface water
and sediment samples will be analyzed for full TAL metals, at a
minimum. The Connecticut River sediments will only be sampled
for volatile. organic compounds if these compounds are detected in .
the surface water:
A program will be developed to sample a subset of the residential
wells in the vicinity of the landfill. The depth, location, and
proximity of the residential wells to the landfill will be used
to identify the wells to be sampled. These samples will be
analyzed using methods capable of achieving detection limits
lower than federal and state of Vermont drinking water standards.
Residential wells will be sampled for VOCs and select metals, at
a minimum. A subset of residential wells will be periodically
. sampled for SVOCs.' . .
n
A subset. of the exist:~g ~onitoring well network will be sampled
twice per year. AI: ~c~i:oring well samples will be analyzed for
volatile organic co~pou~ds and select metals, at a minimum. A
subset of the ground Nate~ monitoring wells will be periodically
sampled for semi-vo:a:::e organic compounds and pesticides.
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38
prior to restoration
understanding of the
relationship between
River levels.
as necessary to develop an accurate
ground water flow conditions and the
the bedrock ground water and Connecticut
Monthly measurements of water levels and quarterly monitoring of
a subset of monitoring wells and Connecticut River locations will
be performed for three years after all of the cleanup levels have
first been achieved. Analytical pa~ameters will include VOCs,
SVOCs, TAL Metals, and pesticides. Analytical methods capable of .
achieving detection limits below federal and state drinking water
standards and the cleanup levels established in this ROD shall be
used during this confirmation period. All of the data collected
to confiim cleanup levels shall be validated. . If the ground
water restoration has been conf~rmed by the three years of
monitoring, then a revised Long-Term Monitoring Program will be
developed for post-restoration monitoring. T.he post-restoration
Long-Term Monitoring Program will involve the sampling of a
reduced set of monitoring wells, residential wells, and
Connecticut River locations.
c,
To the extent required by .law, EPA will review the Site at least
once every five years after the 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. During the five
year reviews the existing data base of technical and maintenance
information will be evaluated to determine if the remedy is
meeting the remedial action objectives. In addition, sampling.
for additional analytical parameters may be performed as part of
the five year review. Changes in land use, toxicity information,
or federal and state regulations will be assessed to determine if
. the selected remedy is still protective. In addition, EPA will
perform a .review of the Site prior to a determination that
remedial activities are complete and/or the Site is removed fro::1
the NPL.
The operation and maintenance activities for the multi-layer cap
and gas system will continue for at least thirty years. The
operation and maintenance of the leachate collection and ground
water collection systems will continue for as long as these
systems collect water. Long-term monitoring will continue for a:
least thirty years. A detailed cost breakdown is included on
Table 5-3 and Appendix E of the FS. A summary of the cost of :~e
selected remedy is provided below. . .
[}
Estimated Time of Operation: at least 30 years
Estimated Annual Operations and Maintenance Costs:
years 1 - 5: $ 400,000/year
years 5 - 15: $ 200,000/year
years 16 - 30:$ 90,000/year
Estimated Total Cost (net present worth): $2,900,000
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39
o
XL.
STATUTORY DETERMINATIONS
,-
The remedial action selected for implemehtationat the BFI-
Rockingham Landfill Site is consistent with CERCLA and the NCP.
The selected remedy is protective of human health and the
environment, attains ARARs and is cost effective. The selected
remedy does not satisfy the statutory preference for treatment
which permanently and significantly reduces the mobility,
toxicity or volume of hazardous substances as a principal
element. However, treatment alternatives for the bedrock ground
water were not considered as cost effective and had significant
implementability concerns. Additionally, the selected remedy
utilizes alternate treatment technologies or resource recovery
technologies to the maximum extent practicable.
A.
The Selected Remedy is Protective of Human Health and the
Environment
The remedy at this Site will permanently reduce the risks
posed to human health and the environment by eliminating,
reducing or controlling exposures to human and environmental
receptors through treatment, engineering controls, and
,institutional controls; more specifi~ally the selected
remedy will provide for the restoration of bedrock ground
water in approximately' 15 years of the completion of the
landfill cap, prevent direct contact with the landfill
debris mass and soils, reduce the generation of leachate
that would otherwise migrate to the Connecticut River,
control the release of landfill gas containing hazardous
substances, prevent a methane buildup, and provide for the
maintenance of the water line serving affected residences.
Moreover, the selected remedy will achieve potential human
health risk levels that attain the 10-4 to 10-6 incremental,
cancer.risk range and.a level protective of noncarcinogenic
endpoints, and will comply with ARARs and to be considered
criteria. At the time that the Interim Ground Water Cleanup
Levels identified in the ROD and newly promulgated ARARs and
modified ARARs which call into question the protectiveness
of the remedy have been achieved and have not been exceeded
for a period of three consecutive years, a risk assessment
shall be performed on the residual ground water
'contamination to determine whether the remedial action is
protective: This risk assessment of the residual ~round
water contamination shall follow EPA procedures and will
assess the cumulative carcinogenic and non-carcinogenic
risks posed by ingestion of bedrock ground water. If, aftey
review of the risk assessment, the remedial action is not
determined to be protective by EPA, the remedial action
shall continue until protective levels are achieved and have
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40
or until the remedy is otherwise deemed protective. These
protective residual levels shall constitute the final
cleanup levels for this Record of. Decision and shall be
considered performance standards for any remedial action.
.)
B.
The Selected Remedy Attains ARARs
(~
This remedy will attain all applicable or relevant and
appropriate federal and state requirements that apply to the
Site. Environmental laws from which ARARs for the selected
remedial action are derived, and the specific ARARs include:
Resource Conservation and Recovery A~t (RCRA)
Clean Water Act (CWA)
Safe Drinking Water Act (SDWA)
Executive Order 11988 (Floodplain Management)
Executive Order 11990 (Protection of Wetlands)
Clean Air Act (CAA)
Vermont Ground Protection Rule and Strategy
Vermont Water Quality Standards.
New Hampshire Water Quality Standards
Vermont Act 250
Vermont Hazardous Waste Management Regulations
Vermont Wetland Rules'
A more detailed discussion of why these requirements are
applicable or relevant and appropriate may be found in Table 14
and in the FS Report at pages 32-51. The RCRA Land Ban
requirements do not apply to the selected remedy as no
excavation, placement, or disposal of Land Ban waste will occur
as a result of the remedial action. .
The following policies, criteria, and guidances will also be
considered (TBCs) during the implementation of the remedial
action:
Safe Drinking Water Act Proposed MCLs
EPA Human Health Assessment Cancer Slope Factors
EPA Reference Doses
Vermont Health Advisories
Federal Ambient Water Quality Criteria
NOAA ER-I and ER-M Sediment Criteria
EPA Technical Guidance Document: Final Covers on
Hazardous Waste Landfills and Surface Impoundments
. (EPA/S30-SW-89-047, July 1994) ,
1>
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41
'-I
CHEMICAL-SPECIFIC ARARS
Safe Drinking Water Act
(SDWA)
~,
The bedrock ground water in the aquifer at and beyond the edge of
the Waste Management Unit has been historically used as a
drinking water supply. Several residences are now supplied water
by DSI, the operator of the landfill, through a water line from a
supply well on the property of DSI. The water is classified'
according to Vermont ground water classification as class III,
which is suitable for domestic use. Therefore, the SDWA 40 CFR
141.11-141.16 maximum contaminant levels and maximum contaminant
level goals for~ drinking water supply are relevant and
appropriate ground water cleanup standards. The selected remedy
will comply with this ARAR by meeting ,SDWA MCLs and MCLGs at and
beyond the edge of the Waste Management Unit. The selected
remedy is expected to reach these levels within 15 years of the
completion o~ the landfill cap. Proposed MCLs and secondary MCLs
were designated "to be considered" when MCLs and Vermont Ground
Water Enforcement Standards did not exist for a compound. .
Resource Conservation and Recovery Act (RCRA) and Vermont
Hazardous Waste Management Regulations
. ..
. .
The maximum concentration limits specified in RCRA 40 CFR 264.94
and the Vermont Hazardous Waste Management regulations, which
incorporate these levels by reference, are relevant and
appropriate ground water standards at the boundary of the Waste
Management Unit. The selected remedy will comply with this.
remedy by achieving these levels at and beyond the edge of the
Waste Management Unit.
Vermont Ground Water Protection Rule and Strategy and Ground
Water Quality Standards.
The Vermont Ground Water Classification scheme and Ground Water
Quality Standards (10 V.S.A. Chapter 47 and 48) are applicable
requirements for the remedial actions at the Site. The State of
Vermont Classification for the aquifer at the Site is class III.
Class III aquifers are suitable for use as domestic water
supplies under the State of Vermont classification. The Ground
Water Quality Standards are ambient ground water quality
standards. These levels were used as cleanup levels when they
were .more stringent than SDWA requirements. The selected remedy
will comply with this ARAR by achieving the Primary Ground Water
Enforcement Standards at the boundary of the Waste Management
Unit.
EPA Proposed MCLS, EPA Human Health Cancer Slope Factors, EPA
Reference Doses, and Vermont Health Advisories are designated "to
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42
evaluating the residual risk represented at the time cleanup
levels'are met. The use of these factors during risk evaluations
at the Site will assure that these TBC's are considered.
~ederal Ambient Water Quality Criteria, Vermont Surface Water
Quality Criteria, New Hampshire Surface Water Quality Criteria,
and National Oceanic and Atmospheric Administration Sediment
Guidelines will be used as "To Be Considered" guidance in
evaluating impacts to the surface water and sediment of the
Connecticut River.
'>
Location Specific ARARs
The selected remedy will comply with all location-specific ARARs
specified in Table 14 and in the FS, including Executive Orders
11990 and 11988, and the Vermont Wetland Rules. No wetlands or
floodplains will be impacted by the selected remedy.
Action Specific ARARs
Resource Conservation and Recove~y Act
Hazardous Waste Management Regulations
(RCRA) and Vermont
RCRA Sections 40 C.F.R. 264 Subparts 264.90-101; 264.111,
264.117, 264.310 and 'Vermont S0bchapter 7~502(3) which
incorporates'thefederal RCRA 40 CFR 264, Subparts B through 0
and X regulations by reference are considered relevant and
appropriate to the closure of the landfill due to the pre-1980
disposal of materials sufficiently similar to RCRA regulated
hazardous wastes in the landfill. Vermont is the delegated
authority to implement the hazardous waste management and closure
program, therefore, the Vermont regulations are the controlling
ARAR. Since Ve~~ont has incorporated the federal regulations by
reference, the discussion will focus on the federal regulations
cited above. The majority of these requirements have been
addressed through the construction of a multi-layer landfill ca~
under the NTCRA. However, long-term maintenance of the cap,
erosion control, surface water run-off, and leachate collection
system will be performed to comply with the closure requirements.
The point of compliance is designated as the boundary of the
Waste Management Unit. This boundary includes the 17 acre
landfill, gas collecti6n and treatment system, and ground water
and leachate collection systems. The monitoring points used to
evaluate compliance at the boundary of the Waste Management Unit
are shown in Figure 11. The points include the ground water
collectio~ trench along Route 5, monitoring wells E23, E24, C17,
C18, MW-6, MW-7, MW-3, ~;W-4, MW-9, MW-IO, J-37, J-38, K-39, K-40,
H-27, H-28, B-3, G-25, ~-26, and any new bedrock monitoring wells
in close proximity t~ :~e landfill in a flow direction not
covered by the prevl~~sly mentioned monitoring wells.
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43
~)
water quality for the entire compliance period of at least thirty
years; achieving ground water compliance levels as measured by
testing the monitoring wells at ~he point of compliance; and the
implementation of long-term operation and maintenance activities
to reduce the impact of erosion and protect the long-term
integrity of the cap.
<,
Safe Drinking Water Act
Certain elements of the Safe Drinking Water Act are relevant and
appropriate to the operation and maintenance of the water line.
The testing requirements of 40 C.F.R. 141 Subparts B, C, and D
will'be included in the Long-Term Monitoring Plan to meet this
ARAR.
Vermont Surface Water Quality Standards (10 VSA Chapter 47), New
Hampshire Water Quality Standards (RSA Ch. 149:3, Ws. 400, Par~s
430-439 and Ws. 437), and Clean Water Act Storm Water Discharge
Requirements (40 C.F.R. 122.26)
The Vermont Water Resource Board promulgates the water quality
,classifications and water quality standards for the State of
Vermont pursuant to the Vermont Water Pollution Control Act (10
VSA Chapter 47) which are' applicable to the storm water discharge
, 'from the Sit'e. New water classifications and water qua'lity'
standards were promulgated on July 12, 1994 and became effective
August 1, 1994. The Vermont Water Quality Standards include ~he
storm water discharge requirements.
The section of the Connecticut River adjacent to the Site is
designated a Class B surface water according to Vermont, New.
Hampshire, and the EPA. Any discharge to the Connecticut River
from the Site cannot cause a impact in the beneficial use of :~~s
classific::;ation of surface water. Class B surface waters are
suitaple for swimmiI1g, fishing, recreational use, a:nd as a
drinking water supply after treatment. 'The presence of a sewage
treatment plant directly across the river from the Site
significantly reduces the potential for use of the Connecticu~
River in the immediate vicinity of the Site as a drinking water
supply. Based upon the presence of the sewage plant, the water
quality criteria used as discharge criteria for the storm water
discharge from the Site will be based upon the acute, chronic, .
and fish ingestion criteria listed in the Vermont Water Quali:y
Standards, effective August 1, 1994. Although the Connecticut
River is entirely within the boundaries of the State o~ New
Hampshire, the Clean Water Act and case law provide the s~ate
within which the discharge occurs to be the permit authority.
Since the discharge will originate in Vermont, Vermont will t~
the permit authority for the storm water discharge. Vermont
regulations are no less stringent than the federal and State ,;:
New Hampshire standards. Therefore, compliance with the Ver~8~:
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44
Water Act and State of New Hampshire Water Quality Standards.
The selected remedy will comply with this ARARthrough testing of
the surface water discharge to ensure compliance with the Vermont
standards and proper management and control of erosion and run-
off.
,
,>
Vermont Air Pollution Control Regulations
These requirements of the Vermont Air Pollution Control
Regulations (10 VSA Chapter 5) are applicable to the continued
operation and maintenance of the landfill gas collection and
treatment system. . The landfill gas collection and treatment
system was tested and permitted by the VTDEC prior to the'
initiation of Superfund activity on the Site. The selected
remedy will comply with this ARAR by incorporating the
requirements of the VT Air Pollution Control permit into this
action. Since the Air Pollution Control permit for the gas
treatment system was issued prior to the initiation of the CERCLA
action, the facility owner must continue to comply with the
administrative and substantive aspects of the permit.
Vermont Act 250
This regulation specifies ten. criteria that must be
an improvement to property. Several of the ACT 250
were determined be applicable to the actions at the
selected remedy must not:
addressed by
requirements
Site. The
cause undue water or air pollution;
cause unreasonable soil erosion or affect the capacity
of the land to hold water;
cause unreasonably dangerous or congested conditions
with respect to highways or other means of
transportation; .
have al'l undue adverse effect on aesthetics,' scenic
beauty, historical sites, or natural area, and
imperil necessary wildlife habitat or endangered
species in the immediate area.
The selected remedy will comply with ACT 250 through proper
maintenance of the cap and surface water controls.
c.
The Selected Remedial Action is Cost-Ef.fective
In the Agency's judgment, the 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
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45
~
assessing the relevant three criteria--long term
. and permanence; reduction in toxicity, mobility,
through treatment; and short term effectiveness,
The relationship of the overall effectiveness of
alternative was determined to be proportional to
effectiveness
and volume
in combination.
this remedial
its costs.
D
The costs of this remedial alternative are:
Estimated Time of Operation: at least 30 years
Estimated Annual Operations and Maintenance Costs:
. years 1 - 5: $ 400,OOO/year
years 5 - 15: $ 200,OOO/year
years 15 -. 3G:$ 90,OOO/year
Estimated Total Cost (net present worth): $2,900,000
The selected alternative provides the same level of protection
and achieves bedrock ground water restoration ih a comparable
time frame to alternative SW-3 which would cost an estimated
$5,450,000.
D.
The Selected Remedy Utilizes Permanent Solutions and
Alternative Tre~tment or Resource Recovery Technologies to
th~ 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 treatment technologies or
resource recovery technologies to the maximum extent practicable.
This 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-termeffectiveriess; 4)implementability; and
5) cost. The balancing test emphasized long-term effectiveness
and permanence and the reduction of toxicity, mobility and volu~e
through treatment; and considered the preference for treatment as
a principal element, 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 selected remedy provides long-term
effectiveness and permanence by maintaining the multi-layer low
permeability cap to reduce the generation of landfill leachate.
The landfill cap reduces the mobility of the hazardous
constituents. The operation and maintenance of the landfill gas
system also reduces the mobility and volume of hazardous
constituents and provides treatment of the collected gases. The
collection of leachate and shallow ground water prevents the
migration of leachate and contaminated surface water into the
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46
shipped off-site for treatment. The selected remedy will achieve
the restoration of the bedrock ground water in approximately 15
years. The selected remedy considers the presumptive remedy
statement for municipal landfills which acknowledges that removal
of the landfill contents as impractical alternative. Therefore,
treatment options for source control were determined to be
impractical and Containment was identified as the presumptive
approach for source control. The selected remedy complies with
all identified ARARs.
>
~
As described above, the selected remedy achieves long-term
effectiveness by maintaining the existing Site controls. The
selected remedy does not include treatment of the ground wat~r.
However, the selected remedy will achieve the restoration of the
ground water in a time period comparable with the alternative
that included treatment. The selected remedy will provide
protection until the remedial action objectives are achieved
through maintenance of the water line, institutional COntrols to
prevent ground water use, and long-term monitoring to detect any
c~anges in ground water flow paths or contaminant distribution.
The selected remedy is readily implementable and was the most
cost effective of the alternatives evaluated. The State of
Vermont supports the selected remedy. Public comments were -
- strongly considered in developing the selected remedy and -
measures.t6 provide significant long-term monitoring, ~dditional
-institutional controls, and water SUpply wells for the effected
residences were included.
E.
The Selected Remedy does not Satisfy the Preference for
Treatment Which Per.manently and Significantly reduces the
Toxicity, Mobility or Volume of the Hazardous Substances as
a Principal Element
The selected remedy does not include treatment which permanently -
and significantly reduces the toxicity, mobility or .volume of the
hazardous substances. as a principal element. The principal
element of tne selected remedy is the maintenance of the actions
implemented as part of the NTCRA and the natural restoration and
dilution processes. The NTCRA includes a landfill cap to
significantly reduce the mObility of the hazardous substances by
preventing infiltration into the landfill waste material.
Reductions in toxicity, mobility, or volume are achieved through
the gas collection and treatment system. The leachate collection
and ground water collection systems prevent the migration of
leachate and shallow ground water. The collected leachate and
ground water is treated at an off-site facility.
~
Bedrock ground water is the principal medium addressed by the
selected remedy. Bedrock extraction and treatment options were
considered less implementable and cost effective than the
selected remedy due to the steep topography which limits the
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47
with bedrock ground water extraction.
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48
regulations will serve as the surface water classification and
water quality criteria for the storm water discharge.
The Proposed Plan included a split cleanup level for the
compounds xylene and tetrachloroethene. This split level was
proposed based upon an expectation that Vermont will be changing
the enforcement standard to the MCL. However, a timeframe for
the adjustment of these standards could not be specified.
Therefore, EPA has determined that the best method to adjust
these standards would be an explanation of significant difference
to the ROD after the State of Vermont has promulgated the new.
standards. The existing Vermont standards were included as the
cleanup levels. ..
XIII. 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, Supplemental Remedial Investigation, Human Heal~h
and Ecological Risk Assessments, and Feasibility Study to
determine if the selected remedy is in compliance with applicable
or relevant and appropriate State Environmental laws and.
.. regulations. The State of Vermont concurs with the select~d
remedy for the BFI-Rockingham Landfill Site. A copy of the
declaration of concurrence is attached as Appendix c.
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<;
,>
APPENDIX A
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o
,>
Date
Early 1960's
January 1968
1968
May 1969
Early 1970's
1973
1977
1977
1979
1979
-'
1979
December 1979
TABLE 1
SITE CHRONOLOGY
BFI-ROCKINGHAM LANDFILL SUPERFUND SITE
ROCKINGHAM, VERMONT
Site-Related Activity
Site soil was used for embankment fill to
build Interstate 91.
Harry K. Shepard, Inc. received approval'
from the Vermont Department of Health to
operate a municipal solid waste landfill
at the site. .
Landfill operations began at the site.
Harry K. Shepard, Inc. deeded the landfill
to Disposal Specialists, Inc. ~DSI).
A groundwater seep was observed to be in
contact with refuse by Vermont Department
of Environmental Conservation.
Browning Ferris-Industries purchased DSI
and Harry K. Shepard, Inc. Harry K.
Shepard, Inc. changed its name to
Browning-Ferris Industries of Vermont
(BFIVT) .
Neighbors began reporting potential ground
water quality impacts.
DSI was given an. Interim Operating.
Certificate by Vermqnt Department of
Health to operate the facility until
January 1980.
Ground water samples from the bedrock
aquifer were found to contain some metals
and volatile organic compounds.
DSI was ordered by the state to supply
potable water to residents. Bott,led water
for potable use was supplied .to nearby
residents by DSI.
Hydrogeologic investigations were started
by DSI'p hydrogeologic consultant, Donald
Reed. Operation plans were prepared by W.
H. Moore Associates, Inc.
The first Assurance of Discontinuance and
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Date
September 1980
November 1981
March 1982
October 1982
November 1982
February 1983
July 1983
September 1983
October 1983
October 1983
Summer 1984
Summer 1985
Site-Related Activity
DSI installed a water supply well and
distribution system to serve 19 neighbors.
A bituminous cap/liner was sprayed over
bedrock and fill. DSI requested a
one-year extension of the Assurance of
Discontinuance and Agreement.
A second Assurance of Discontinuance and
Agreement was issued to DSI.
DSI's consultant, Donald Reed, completed
the first hydrogeologic report." Reed
continued to sample wells through 1986 and
issued annual reports.
DSI established an escrow account for
maintenance of the potable water supply.
Final engineering report is submitted to
the state by W. H. Moore Associates, Inc.
A Limited Release Agreement was signed
between DSI and nearby residents. .
Sampling of six domestic wells was
performed by the state.
The third Assurance of Discontinuance and
Agreement was issued to DSI.
The landfill was certified for municipal
waste disposal by the state for the period
October 15, 1983 to October 15, 1988.
A ground water interceptor well located
upgradient of the landfill was installed
by DSI and placed into use.
Use of the interceptor well was stopped
because of ineffective performance,
freezing conditions, and pump problems.
-------
Date
July 1985
July 1986
1987
September 1?87
April 1988
October 1988
1988-March 1989
March 1989
June 1989
October 1989
October 1989-
December 1989
1989/1990
Site-Related Activity
DSI installed 1.5 acre 40-mil
high-density, polyethylene (HDPE) liner in
southeast area of landfill.
The NUS/FIT Preliminary Assessment
Superfund study was completed.
DSI obtained approval from the state to
use the expansion area in the southeast.
area of the site. .
Ealey and Aldridge, Inc., hydrogeologic.
~onsultants to DSI, installed additional
monitoring wells, sampled wells and
undertook a hydrogeologic study.
The NUS/FIT Final Site Inspection Report
was completed.
Haley and Aldridge, Inc. issued the 1986
to 1987 Annual Hydrogeologic Report.
The state issued DSI an Interim
Certificate. (PermitWH66C) for operation
for the period October 15, 1988 to July 1,
1990.
Geotechnical Engineers, Inc.,
hydrogeologic consultants to DSI, sampled
monitoring wells.
DSI samples residential wells.
.The lined. landfill area~ fil~ed mostly
with municipal solid waste incinerator
ash, was proposed for closure.
The site was included on the EPA National
Priority List (NPL).
Balsam Environmental Consultants, Inc.,
consultants to DSI, installed additional
monitoring wells and collected ground
water samples. .
Balsam issued the 1989 Annual
Eyd=ogeologic Report.
:S! installed a landfill gas extraction
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Date
June 1990
August 1990
February 1991
June 1991
November 1991
August 1992
May --August-1992
November 1992
November 1992/ ' ,
January 1993
February 1993
February 1993
April 1993
May 1993
Site-Related Activity
The state confirmed that the landfill
could operate after July 1, 1990, while
DSI pursued recertification.
Balsam issued the 1990 Annual
Hydrogeologic Report.
Geotechnical Engineers, Inc. issued a
report on behalf of the state regarding
1989 field work for the Phase I Vermont
Landfill Assessment Program.
Balsam began Remedial Investigation of DSI
landfill. .
Landfilling of MSW and construction and
demolition debris was discontinued.
An Administrative Order, EPA Docket No.
1-92-1053, for Remedial Investigation and'
Feasibility Study activities was entered
into by EPA, DSI and BFIVT.
The Route 5 slope stabilization and
seepage -control system was designed.
A Draft Remedial Investigation and Initial
Screening of Alternative Report was
completed and submitted to the EPA and
VTDEC. .
The Route 5 slope stabilization and
seepage control system
was constructed.
EPA required DSI and BFIVT to perform an
Engineering Evaluation/Cost Analysis due
to the need for a non~time-critical
removal action.
Residential Wells in the area of the
landfill were sampled.
Submittal of the Final Remedial
Investigation Report to the EPA.
EPA issues Fact Sheet describing the
results of the RI and Human Health Risk
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Date
er 1993
October 1993
January 1994
March 1994
April 1994
April 1994
Site-Related Activity
Balsam, on behalf of DSI and BFIVT,
prepared an Engineering Evaluation/Cost
Analysis to perform a non-time-critical
removal action.
EPA issues Fact Sheet proposing to cap the
landfill as a non-time-critical removal
action.
EPA issues the Human Health Risk
Assessment.
EPA holds a public information meeting to
discuss the Fact Sheet:
EPA holds a thirty day public comment
period for the non-time-critical removal
action.
DSI Landfill regraded.
EPA issued an Action Memorandum requesting
that a non-time-critical removal action be
conducted at the DSI Landfill.
An Administrative Order, EPA Docket No.
1-93-1099, for non-time-critical removal
action design and construction activities-
was entered into by EPA, DSI and BFIVT.
EPA a!'lards a Technical Assistance Grant to-
the Vermont Publi~ I~terest Education
Fund.
Design of the non-time-critical removal
action initiated.
Submittal of the Supplemental Remedial
Investigation Report to the EPA.
Ecological Risk Assessment Released by
EPA.. -
EPA issues a Fact Sheet discussing the the
cap construction and updating RI/FS
activities.
EPA hold a public meeting to discuss Fact
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April 1994
Date
April 1994
May 1994
May 1994
May 1994
May 1994
June 1994
June 1994
June 1994
June/July 1994
July 1994
September 1994
Landfill gas collection and treatment
system is expahded as part of the non-
time-critical removal action.
Site-Related Activity
Supplemental Remedial Investigation Report
is released.
EPA issues Press Release Summarizing the
Long-Term Monitoring Program.
.EPA holds a public meeting to discuss the
Long-Term Monitoring Program.
Residential wells sampled by BFI.
Draft Feasibility Study Report released.
Design completed for non-time-critical
removal action and construction initiated.
EPA releases Proposed Plan for ground
water action.. .
EPA holds public information meeting for
Proposed Plan.
EPA holds thirty day public comment period
for the Proposed Plan and RIfFS.
EPA holds public hearing for Proposed
Plan.
EPA signs Record of Decision for ground.
water action and released Responsiveness
Summary.
-------
<)
Table 2.
.',
Compounds Reference Criteria Maximum Value
(federal and state Detected in
ambient water Connecticiut River
quality criteria) Based Upon 10/92,
8/93, and 5/94
(ug /1) Sampling Events
(ug/l)
Arsenic 190 <1.2
'Cadmi urn 1. 79 <0.5
Chromium 11 <4
Copper 6.54 4.3
Lead 1. 32 <1
Mercury 0.012 <.2
Nickel 87 <8
Silver 1.23 0.18
Zinc 58 7.2
Iron 1000 463
-------
-
-
-
-
-
-
-
-
-
-
-
Table 11
SUMMARY OF AGGREGATE HWRD INDICIES FOR ALL EXPOSURE ZONES'
DFI-ROCKINOHAM UNDILL .
ROCKINOHAM, VERMONT
E.lloIUf8 zeiiiii'
Connldicul Rlv...
Rlvel
Rlvel BacklllOund
Pondl
Pond 1
Pond 2
Pond 3
SUP'
Seep A
Seep B
Seep C
Seep 0
Seep E
Seep F
Seep 0
Soop It
Seep Background
SW.35
...
, "",,;'>~J~~::.:.;:;tr,t~:!';":;:::;~~'~i~:;.:;j:l:::~:r:;h;:::~td.'. .,..., M~.10:U:7,:ohr~ni;:: ;""
'1i11.am:::':'AO[:'t::::i1iijiiiihi";::,::'AOi/::::::::Uiiliiiri1" ""ACt: li.i..Iii" ADL' .
ER'l.
Ii.i..", "ADi.
..
0.7 0.07 18 3 ~ 100 . 2
0.3 0.04' 5 3' 0.4 0.07 \3 4 2
4 37 . 7 . 57 . 3
. . . . . . .
0.005 3 . 0.009 . 7 . 2
75 855 . 142 . 117\ . 3
4 5 84 2 8 \55 . 15
II 19 312 592 15 . 548 . It
0.4 22 . 0.7 . 34 . 2
2 2 31 8 4 59 . 23
5 . 101 . 11 . 247 . 0.5
8 \' 20 12' 23 2 50 \9 \
\9 7\ . 38 772 . 1
, . . . . . . II
1 . 8 . . . .
Nol..
I. '.' ndlc8ll1lhl'"ampOl .1.."" obIaned 'omlhlOllocldonl
I. .Tho ."""" iIIled undl' AOllvl..,,1 .,.Ih. pol.. opeol" ,w. ..tIm....1or Round , ....~.. ..."Iin". .nd no' I'... .....go..
,. . Indlc8111lhl18 d""lc8lt .00'""'n Of IhOl"''''' .... on. ...."'1. 1I.".."IocIIlo. oo,.._d.,o"" "POO." Ion..
3I"~
AOl ProJo
-------
Reaponae
Mea!lllrerrechnolo
Containment
Paeaiv" Hydraulic
Graclient Conlrol
Adive lIyclllllolic
(,racliont Control
rt1l1l1illl'lll
VHticalUan;elll '-\ydJ..uUc~Il~~~q8U~f~..~~~ .. q.. .q q. . q fJ"uila i~ greaier tllAli i(joUi
Wl\J~.ah';~l,r.\,~~~iino/~~~~il(. . ..q ::. fHt.Ntil fllia.ibly. .
I:'!rta~~i:\)::,:::,.,,>.,.:,.. '" .. ....:t::::::,::"?:.':/::,::.,:;:.:::::::::) .'... ..,:,,:~t~~~~~~~,in ~e4r~~!\
,":.:., : ~~~:~:~:~~::::;:;:t;~:r~;~;:?;;;:::;:;:;' . ";.:-:.: :':';';';';-";';';';-";-:::..:-:.;.;. :::." :.~:~?:\::.:(;: >;""." ,', ';'~::. "'.. . . . ... . .
.. """,""."',",","", 'n " .. -.... ..
J>roc"aa Option
Tahle 12 \
REMEDIAL TECIINOI.OGY IUENTlFlCA110N ANn SCREENING FOR GROUND WATER
~SmILl1Y STUDY. DISPOSAl. SPECIALISTS, INC.
nOCKlNGIIAM,VERMONT
Deacrlptlon
Errecllven..a.
Implemelltablllty
q.
... .... .. .", .
~'~~i7~~i~~~~~t~~r~::~f; .. :. '.
. ~~~~~~::{~~:,~f~':l\i~~. D1,niaminant:
.. . .. .
rj"pl)l~ b.~11)Ok a~tb~.i~~
"''fIa~iI..t~''~.1 ('M) f"~t, Noitq
fe4~ibl,Y oaw;tnarloble'.
In.' ...
....
.".,"..".".:.'.
d. .
"."..",
.., "
..
-... .
...
...'"
'. .
...
...
...
..
..
. ""
".".:.:.:.;..:-:,",.,.:.,'.:.:
. .
...
.. .
.....
.....
.......
..
..
..
.. .
., ..
....
...
. ..
...
CDl1t.inm~D~lir.colltn)19(tb~, NOL~f(~I~~/riF¥.~~~~~I~'D 10..... .
m~V~T'~\~rt. "r?~ !1~f.~~,~,: ~~H.. ~."o..:.rn;..~.nn'.:;. &ec:.'.'.'"...':.u~..~.:..icu:....,,~.,.ttY. :.:.'~I.~.:.:'.'y:.\..'.~e'.:.::.'.r,.I...:.h.,:..',::.'...~.;...:...;..:,I.:...)...;.~........;....i.r.....:.,.,'.'.:.:,f.....~...:..;.:.J.::.~.r.,..:....:...:.:..Qf.:: t .,\~..
bD~to~ta,~ .~~~rv.eH!Cfr:::.:::.,:::;'::-' u IU - ".. .
dirllct,ijiil\ t hrQuiJl1 ~.iiitnir.twnqr ';:";;;'::/:::::!:.::...:)::j::'::'!}""::.:": :....'
::~:~:;~11~Ci1~~:~~~~~;.:;' ... .:.::::.:/:.:.::;:::(::.':"::'::..:.':,;.';:'
IlIa\o lIalion ofinJoct.ion w.:lla
. . .. .
I\\-Y~. dUTi~~lt to irUI\J.t~~~~t
rJlI;'tcJtb~..depth o(~f~~~
r.r1'I\I~r thnu 11)(1 (~&l... '. .
Nol..:
I COIl rel.ti". La other P'"~. OS'Uona within th. ..m. technololD' type..
2 SI..d,n. d.note. .llml...... l.duloloO.
6rlMI4
1S.lum Project IHC8.02:00If5RT.XI.'I
(.
Coat (I)
Statu"ltJu8t1 neat 1011
...
...
....
?fii;rii~~;~~ d;;~t~:
.:}Pf~"?I...gy 16 Jillt -/f"t1ive
:/~?/'~:.~'i1~. to.oh~ oonditiontt
... .
.. !'J~t fuaibly con31ructable
ill hi..i."'~k.
.~.1'1'~h,wl...gy Ie JM .lTqr;1ivQ
. to ired ground waler
. Not (eaeiLly cou.t rueta LIe
'-Ir<>ck.
. HIGh .
'..,~rjl~.J
: Elimillllt6<1 due III;
.. ~ EIf\!~tjv\!neee And
, .. .
i:: iniplemantabilily
. ..
'.'''.
..
" .
-------
Tnble 12
REMEDIAL TECIINOLOGY mENTIFlCATION AND SCREENING FOR GROUND WATER
n:ASIIJIJ.I1Y STUDY. ntSI'OSAJ. SI'r,.CIAI.IS1'9. INC.
noCKINGJIAM. VERMONT
He.pon.e
Meo,uret1'echnolo
Willltlra Wa I/Coll ect ion
;'w~i~;~I~fi~~1~~i'l!ill!lill'll.ii:;~~~iij~;
U'UU'EI' " , 'dd U
f;~~~~uww~1~.~&MrJ'.
Proce.io Option
De.clipllon
Effective,.....
I...plemell tRhl1l ty
Co.t (I)
Siol U8/.JU.tI nCRt I"n
-I
I
I
I
I
ExtraclioD Wells
Inal.1I ODe or more well. 10 extract EffectiveDe.. likely to be .ignificantly
ront.miDated bedrock grouDd limited due 10 bedrock permeability
water. .nd DOD-uniform Dature of
bedrock grouDd wat.r lIow.
Difficult 10 effectively
internept impacted
bedrock grouDd w.ter due to
nature of bedrock and
Moderate
capilal
Retained due to:
- Be.t avail.ble technology 10
exlracl bedrock ground w.ler.
Mod.ral.
difficulty iD localing extracliol
well. due to .UM.ce
topograghy.
Downgradi.Dt bedrock
O&M
.'
well. may induce lIow
frolD Connecllcut !liver.
...- -
-'
Not..:
1. Cool ...1011.. 10 other proceoa opllon. wllhln Iha 18m. IechnoloBY Iype.
2- Shadin, donoleo eliminated lechnoloBY.
&/2&/94
11.10010 Pndoct 84D8.02:0Slf'BnT-XIB
-------
c
. Tnh1e 12
REMEDIAL TECHNOLOGY IDENTIFICATION AND SCREENING FOR GROUND WATER
FF..ASInIUTY STUDY. DISPOSAl. SPECIAI.ISTS, INC.
nOCKINGIIAM,VEIIMONT
"O.IIOII.e
Mes!llIreffechnolo
Treatmeot
J'rvce.. Olltloll
De80rliitioll
Effecllve...,..
1IIIIIInmollillblllly
Co.! (I)
I:Itlll.../.J.18llnClilln..
MattUkle .II'~.~ .~~ .1,~t'1)~~~e o~~.~II.~~..... i~~t~iI~i~im~f:iiu.:;'.~~~J.~iZ;Jtti;.a....) ~}~I~,~~n~f~~t,~:~:w,rLi;'
. !~t~1~~~~# ~~?"';~~m'~!f..~~.~ !:,~~WU::~;:~f~!
?!£~¥' ~~7b4). ~~iiiil"f~""'~ ~~~i~~i~;¥?I'
...
.'"
.,."
...
Oiolop:ic.l1Tealm8nl
(i""1I1I1 \V.lar
.11~i
...
. m~t~t-~£~:~~,~[i,fu~:f::;i:
..: ~f7i~;~ffflr~~l~~Th1~;:"
..
...... ":.;.;.;..:.:.:-;.;.;.....,.. ._....:t~:;.::
...
....
...
. '" . . .
. .. ..... . . . .
.... . '. .n
",,",".,:,,:,;,:,:,:,:,:,;.;.:.:.:.,,".".::
','.',',".'.' ',',',',',',',',.',',',",'
. .. .... . ..- ......
""...-.... ...
".....
... .....
:-::,',;,',';,',:,:.
..
""'''''.."......,.,.,
,',','.',',',',',''''',',',',',',',',',',',','
",.",,;,::;;..:,;./:::;:f::::;:;:;:;::::;:;::::::;:::::;;,
.:.:.: :. ,,:,:,:,:,:,',:,: ~.":':':':':':'
"",',',,',',"',',',,',',',',',',',"
,.. ...-,.......,
,.,..." ........'
','.
..
'...
',','," ,',',',',',',',',',','
.'
.-,...,.,
NoIM:
I. C..I ,.,Iotl.o 10 othor proc:.ao optlono wllhln Iha um. IochnololD' Iype.
2. Shodin, doooloo ollmlnoted l~hnololD'.
G126/1H
Bolum Prqjoc:t ~68.02,nslrsRT.XLS
-------
IIcel,ollee
I\Ico811rof)'echnolo
1'r88lmel1t
Phy.ical Trutment
of around Water
Proce88 Option
Air Stripping
Tahle 12
REMEDIAL TECIINOLOOV IDEN"I1F1CATION AND SCREENING FOR GROUND WATER
FEASIDII.I1Y STlJnV. mSI'OSAI. SI'F£IAI.ISTS, INC.
nOCKINGlIA.M,VEItMONT
Deecrtl'tlon
Effect'veneell
Extracted cround water will be Air etripping may remove the orgal1ic
pumped through a countercurrent, constituent. of col1cern. Not ~fTective in
packed tower aeration ayetem or removing inorganic conatituel1ta of
an Induced draft air etripper. concern. Will require an inorganic
If oll'-g...- were to IXClld the treatment technology to remove inorg.nic
V.rmont DEC .ction lev.", constituentl of concern. Aleo will re'Jllire
treatmlnt (polillhingl with vapor iron and manganlee removal to prevent
pha.a .ctivated carbon will be eyatem fouling.
required.
Carbon Abeorption Extractld cround wa~er will be
pumped tbrouBh a uriee of
packed bed reactore containing
granular activated carbon (OAC).
The GAC abeorb. organic
ooUltitulnt. by IUreaCII attraction.
Th. GAC wiD require periodio
repl.cemeDt or regenel'1!tion.
..
.......
. .
...
: "","';"';":'.',"."
'.'..:...""""',::",,',","
...
. .
. ..
Nole.:
I. Cool relolive ID oIhor 1'''''''''' opllono wilhln Iho lime 1""''''01011)' Iype.
2. ShodinS donotee ollminoied "i<,hnololl)'.
erJeJllt
......... I'''1!DCt 84eII.02:DSIF8RT.XLS
Carbon abeorption wiile/Tectively remove
conetituente of concern. Due to low
leve" of .ome inorganic conetituente,
. .
pretreatment may not be required. May
aleo be ell'ectivI for Uel ae a
poet.treatmlnt poliahing pI'OCl88.
..
........
..
;':';';';';'..,'.':':'
....
......
"...
...
...
.:,'
..
. . ".... .
.:,.:::.: :~:"::.::;':;' .::::)':.:':::.
.::.::::;::::::::.:,;.::.:::.::.:::::'.;;.::':::>::.:
....
Implcmentoblllty
Air etripping ill commonly
ueod to removl VOCe from
ground -tel'. Air etrippe..
are widely available. Air
controle mey be required if
conetit"lnte in ofT. gaeelll
exceed et8le action lIve".
Carbon abeorption ill
commonly ueed for the
removal of organic
OOD8tituln~ from wute
watlr and drinking wa~r.
Full ecale and pilot ecale
eyetlme are readily Bnd
widoly available.
Coet (I)
Low to
Moderatl
cepital.
Low to
Moderate
O&M
Moderate
capital.
Moderate
to High
O&M
..
...
8101119/.II19110colloll
#
-------
(COllI.)
n".I"'".O
Measllrerrechnolo
Trealment
""yaical1"'8almelll
o( G roll lid \Valer
Dialye j~1
I:lectoJi.ty.ia
Tab le 12'
\.
"
REMEDIAL TECIINOLOGY IDEN11FICATION AND SCREENING FOR GROUND W~TER
FEASlmU1YSTUnY. DlsrOSAI.SJ>ECIAIJSTB,INC.
UOCKINGllAM,VEnMONT
O.,lorll.tIOIt
-
t.T)".'.lIhCl,I iill' IIh/)I",j.,,,;:
Dialy.ibi'EliI(t;",!i.liIIL.\tf.i li,~,.
application ot. 'diJTerence iu'
8Iect~c; POI'J\'~.' 10 ~'I!~y!IY
coiice ni~t~' ~~tA iii j;~~~e'~ id~ '."
. ',' .' " ,',.
'" '"
Q(~'\!lnl.~iij.;i\~.bi. mfm~ran.: p'
~~i~~~$~~,
..n.
.....
.....
..
'''-''''
....
. .
n. .
",-
",... .
'p
.P
':-:"';'.:','
p'
. ."
....
. .
....
p
. ...
.....
p
-....
"...
",','.',',',..'.'
. .
Note.:
I. Coet rel.tlve to other prfX'Cl88 option. .Ithln the ..m8Iochnolo81 'JP&
2. Shodin8 don.leo olimlnoled lechnol.lI)'.
8I'JMJ4
I"'.om P,qecI6488.02:OSrfSRT.XI..9
p .
P'
P'
t:rr..ntlv.....,,,a
8I~~
".'.,
p
........
""."
.... .
P'
Ti,lil,cl\Jio'oiiY~nQtw911 ftui'~' for
.pplioalloJO to iniud Waol" .11'8.11\0 wi,,,
J,I~', ~"Ii~~ c.?~'IClnt!, 1~~' te~hl1"'\I&Y J.... .
n()Cb8~ad~moW!tr.ted~;: lullarole ror Iha
...... . . ..., . .. .
. .... '. .. ."..
t~.ifriii\\~o(~\.i.\.t~,,~ ~ut...
..
,..,"
..
....
". ..
'..'
...
....
.." .
n. .
....
... ...
.:.;.''',:,:,:,;
""."
..
.....
.. .
... .
",".".'
n. "'
. ..
. .
...
...
.....
'"''', ...
.... .
....
. .
......
.'..
..
~~~t~~j~!j~::
ii1iiii~t"!"
..,', .... '"'"'"':';"';'"'".;.,';".'.
...
"'::.' ;',"...',",',"
:'.".;: .:. :'::-.
. .
...
..
.. .
. .
..
...
."
..
:""'::..:;.:.;...
. . .
-..,
...
. ...
..
..
. n.
o "" ",.
:.~:~~~.;:;:!:!:!jilili:!i.!!.~;liliii!I!lil:lii~!iii!Ili!i!i'll/il:i!il.//!:illl!'I?::!!!:!ij:::::
..
.."
. .' ,,"." ~:"... ..
'.'..'
..
1"'1'1."110111..,,, III Y
COllt (I)
;:~~;~~?:;rrr;}?~~;~;;~i~i~~?:)/:. ':::;-::ir;:::~:t:;:; ::=;:)r:;:=t/:: ::;'Y::::::::'::::";"'" ," ....
. ".'" .. ..... -, . '';:::;;::::"::: '::':'.::::.:'~.:
~ii~~i~~~a i~~ir~
1111,1. ii~rY hl811\y(J)l.It.'OII~iI.." n
. .. . . ...
~,;';n;Ii;;g ~~.iclilio";'~
P"
.. -,.... . ... .
Moder~i~
O&M
11" teelmololtY hae not'
I",ell impl.noente.l.1 rull
lelll" r...r Ibe Ire..hTlellt'\I( .
. ;.,~,j~~t.?
alpilal
luizardauD Waale.
,.
HI nl""/"'",IIII.".II.."
n.
.... ... . .
.. .
.' '.'.. j..:.:i2:'~~:'f'~:::'~'::~,:oiaKY
. bie/le ."''''8.liMtiOTl
j"\'j...rl.
. F./irnlnllled ii.., to!
. NoL II proven l"cllllol,,!:>,
. ". .jl" rflrnediftlj""
. pl'Ojecla
I':limiUll.cld due '0:
~ Not ~ettlve or .pJlliuLle
to Sile con.liliolle.
-------
Reapon.e
Mea!lnrerrechnolo
Treatment
rhY8icai Treatment
of Ground Water
Ir.ollt.l
Table 1.2
'. .
REMEOIAL TECIINOI.OGY IDENTIFICATION AND SCREENING FOR GROUND WATER
'FEASIBIU1Y STUDY . DISPOSAL SPECIAUSTS, INC.
ROCKlNOIIAMiVERMONT
Proce.. Option
DeacrtpUon
i~\I..iiil
. . .., . p.. ... _to"",". 'j"."ftr~.'~'''r'~ii,r,,~:,' .:"
. ".
~~ilt.i~~~lti~~:i,
....
..
. .....
..
..
Chemical
Precipitationl
flooculation
Chemical precipitation removes
diaeolved metale and .uepended
eolide from aqueoue wades by
chemically combining thel1llnto
beavy, ineoluble fonne that.
precipitate out oholution.
~.'
.-
---. '
Nol..:
I. Cool ...1011.. I<> othor pr.reu opllono wUhln Iho urn. t.chnololl)' Iype.
2 Oll.dtn. deno"" .II,nl...Led '.echnolol1.
&1'l&/\J4
1181"'0 P,qoc1 84&8.02:I>SIFSRT.Xt.5
Eflectlvene.s
bnplementabllity
Coet (1)
8tBtns/J'lIItlncB!lon
. .
i'\lJ~~~~;~~i ~~~i~liill
. . . . ac:tjtllA It,v_I" . .
.... ....
. .
...
'.':'~'~ :.:.
....
" .
....
. .
_,n
.... "'. ....
... ..,... ..........
..... .... .....
','.",'.'.','..'.",','.-.-.'.....".'.'.',",
............".....
...... .
. ....
. .
"UII'.litIAI '.Jlant~lIlIl' ,uli,"" IID.IIJ'llIhloo
~~~"e~~J,~t~M.ir.,Lrio 1i~lr~iiD~ ~m
n~(r;TWi(~jitji.,'W~tit;i~ri'~Qi#nc.rii:
i.:J~'ti;~'~~~i~~I;:;;~j;;!~~~d~ii.Y th~; in .
... ... . ..
i~i.'liqj:!~;i
Effective ill removing die80lved meta"'.
OrganiCl ...ociated with eU8pended eolide
may al80 be removed. Effective for
removing a variely of heavy meta'" at
v.rying conClntratione.'
:~~iJ~i'\\4
""'n..
;: I':Hmineted duo to:
. .. .. . . . . .. . ..
:i~pii,E.:{t:f~ol~~Jv41 Al tr..,tlnre .Il
.....' . '" "'. ':;;';;;';lil;;~nla ~f ooucr""
. n"'llIh'fJft '''Pft'I'l1h,..,I
. .. ..
Mlld.,...t..
Wen prove II techllology (or 11" Moderate
treatment of induatrial wade cepital.
_Ier. Emuenl muet comply
with NrDES etandente which
netaiued due to:
. Applicable Technology
. Effective in removing
meta"',
may roeult in secondary
treatment (poliebing).
Reeultinr: eludge/aoli,l. mllet
be de_tered, treated, and
diepo8ed 0(. Mobil. unite
available.
Moderate
O&M
-------
'"
Tllhle 14
REMEDIAL TECIINOLOGY IDEN11F1CATION AND SCREENING FOR GROUND WATER
FEASIDIUTY STUDY. DI~rOSAL SPECIAIJSTS,INC.
ROCKINGlIAM,VERMONT
Itell,on.e
Meuillre{rechnolo
Tnotment
I'rocelll 0l'llon
Ih.lcrillUon
..~rrocllvoneell
1"'1'1 o",,';lt..1.11I Iy
COlli (I)
H...tll!t/.J'I!'f'ln,~..flc.I'
Phyoicol1\eotmllnt
of Ground Wilier
1111ItJ'f11l11~--
. . .
!~!I!!lf;~;r::j!i:i: li~ii:!i!!~:~;~~~~:~~~:;le~1tl:~i~«'
";C:;;ili'tltli"n~ of tQl\~rn
(conI. 1
...
'lI..'iitu
A<\.o I> r}) I io"
1::lil1lillnlo.\ rJ.." 10'
"Te~hu"loKY 1I"t d.tn()u.tJ'~I"cI
: III (..110.010
Ion E"chollgo
11.io procelll romovoo to"ic 10110\
iODII from lIolution by ion
..change with. non.toxic
moterial. The relulting realduala
include llpent reoina and
ragllnlranta.
Ion o"chongo wouldllot be effective ill
treating the organic ooll8tituonta of
concern but may be efflctive in capturing
areenic. Technology may nat be effactivlI
dUI to high Ion conoontratiall8 and
potentially high IUlpendld lIalida and
11.io lechnology io reilltivoly
opecific in treating different
typel of waite.
High
capital
lIeloillo,1 II.." 10:
. Effective al a inorganic POlt.
treatment poliohing proceoo. :
fljgh
O&M
diololved lolid concentratialUl in thl waotl
'" .
.. ., .
. t\iminnlo,\ due lOi
:i:,T.Nol:~ "/\IV"'I l~h"',II"IU'
, in p'Ound waler treatment
proj~ct., :
Nul~.: .
I. Cool ...1.11..10 01100. pr""""o opllono ..lIhln III. urn. a.chnololl)' Iype.
2. St,odlns donouo olimlnol4d lechnololl)'. ..
OI'lMI4
...10810 I'~oct 0408.02:0SlfllIIT.XI.8
-------
Tnhle 1/."
REMEDIAL TECHNOLOGY IOEN11F1CATION AND SCREENING FOR GROUND WATER
FEASIDIIJIT STtJOY. mSI'OSAI. SPECIALISTS. INC.
ROCKINGlIAM.VERMONT
Re.I>on.e
I\f n n.......rr"""n"l"
Procell8 Option
De.crllJtlon
Errectlv.,nell8
hnl.lementahillty
COli' (I)
9Iat"."'""lln""llon
(co"I.)
, ' '. t:iimiualed duo to~""1
.~ C.Hilo ftl'll ..\ t,I,t.'f o( "'''Huilud
highSI' lI,a" air .hippi"l1 I
Treatment
Phyeical Trealment
of f: roll n<1 Waler
NOle.:
I. Cool relollvo 10 other proceo. opllono wllhln Iho .omo I.edInology I~
2. Shodin, denoleo olhnlnoled lochnology.
DI2MJ4
1I.lum Project 84D8,02:IJSIf5RT.XI.9
-------
Ue8'I)()nle
I\feal\arerrechnolo
Treatment
Phy.ical Treatment
of GrollDd Water
(cont.)
1'..o.lInollt
Chomical Treatment
ofOrollnd Water
Table 12
\;
REMEDIAL -reCIINOLOGY IDEtrnFiCATION AND SCREENI NG FOR GROUNDWATER
Deaorlptlon
FEASIDIU1Y STUDY. DISPOSAL SPECIAUSTS,INC,
ROCiUNGIIAM.VERMONT
Erfectivene.1
Iml,lementBblUty
81-
Olonalion
11,e reactive oxillant, oJone, Ie
l188d to oxidize org~nio
oompoundeln .quCIOU. :waete
etreame with an organic conlent
of 1""0 than 1.0% (<10,000
ppm). 11.e by.product. created
are carboD diollide, hydrochloric
acid and water. alOne contact
with the ground W8ter occon
wilhin a multl..tag,! bamod
reactor. Ba.lc .y.tema typlcall,y
0008lot oUhe baffled reactor, air
or oll)'lr.n compreeeor, air dryer
and an oJona Irenerator (2.6%).
UV light in combinat1oQ with the
OJODation lyatem caD
.lpUicantl,y increaee .- ..- .' .
degradatl~!!ohome organic
oompound..
Not..:
t. Gool ...lolI.alo oIho.. proc.... 'O(1l1ono within tha aamalaohnololl1lype.
2. Bhodine denolea oUmlno\4ld ledmololl1. .
6fJ6104
......," I'r<>jec:t 84DB.02:091f'BRT.XI.B
Pilot and fullecale applicatione of
olonalion to aquIDus W8et.. et....amo
ie well doclllDented. Organice oolliailling
oonatituellie of concern may be efTectively
trealed. Removal of inorganic
oonalituenlo o( concern (e.g., anonic) mey
not be effectively trelled. OJone bae been
proven to be more effective in combinatioD
wilh IN photolyeie and hydrogen peroxi.le
oxidation.
Coat (I)
"
Slallu/Jlullncallon
1I_lti~1f}Ef
...
Proce.. ia oolllmerciall,y
available aOlle..ily
implemenlablo. Ueod for
many yoen by Ellropean
communitiee (or tho treatmon
o( drinking weior.
:~~:::p~i~lf} .
::::oaiM/
Moderato
. capital
Moderate
to II igh
O&M
:':-:';'"':.:0:.:..
..
..
. .
....
...
...
Relaine,1 .Iuo 10:
. Applif'..hle au,I (III.nou811",. nt-
lechnology, "ao1iclllarly ill
combinalion will. UV
phololy. ia.
. Other po8oiblo combinalion.
.lIclo a. 01000 with bydrogell
peroxide may be corobined
with UV pl1otol)'8ia to
efTectively treat conelilllenl"
o( concom.
-------
Tn!> 1c~ 1 :!.
REMEDIAL TECHNOLOGY IDENTIFICATION.AND SCREENING FOR GROUND WATER
FEASIDILI1Y STUDY. DISPOSAl. SPF..cIALISTS, INC.
. noCKINGlIAM,VERMONT
Reepon.e
M"a.llrerr"cllnolo
Tre.tment
Proce.. Option
De8orlptlon
lIydrogen Peroxld lIydrogeD peroxide is ueed to
OxidatioD oxidize organic compounds in
aqueous wit.t. .treame. Major
Chemical Treatment
of Ground Water
(COllt.)
by-producte ofthe reactloD are
carbon dio.ide and water. 8aelc
ey.tem component. typically
inch,,'. the oxidation chamber,
chemical.torRSe ves..1 and
metering pump. UV light in
combination with the .y.tem can
eignificantly increa.e
degradation, reaction ratee and
oVen II destnlction efficiency.
"'" ". ""'''' .......
. ...
'. ..
. . ..
Hydrvlyele
. . . ... ...: :.:::~:;: :;;.
~i~i~~i~~~i{,,~)~M .
v. rl~'t illril';bi~b i:au~i4~ii:::
i/lCI'
-------
,.
Tahlp- 17.
'.
"
REMF.:OIAI. TECIINOI.OGY IOF.:N'I1FICATION ANO SCIIEF.:NlNO FOR GR01JNO WATER
. FEASmIlJ1Y BTtJOY. DISPOSAl. 91'1~"'I.ISTS. INC.
ROCKINGIIA"'.VERMONT
'p
Effectlven.....
Irnpl..mentabllity
Blalou/J...tlncatlon
n...pon...
Meosllrerrechnolo
Treatrnent
Proc.... Option
D...crlptlon
''.'''''''.:'In:'ii;'i:,,:'j.::j':';';:: '~'~!'I;'~:'~~:~~~'~~~~~~:~::~~:;!!::i!!:i!:I:!"
'~i..i.U.n ~;~~i~!ii~~\L
r~~i~,!i~!1~E;k
.. .. ..
.. .. ..................
n.........,.................
""''''''''''''''''''''''''
. ',".'',".',',",',',',',',',",',',','.','.'."."'.',",'"
''''''''''''''''''''''''''''
,'n.','..',",',",','"","".:.,o",,,,,,",",,,",,,,,,,
":',;,:::",;,;,;,:,;,;,;,;,,".,;.;.:.;.:.;.;.::.;.;.",
~~~..J1'.~i~~litJ~"!~~I:~!i;~~~:
~'!~W1i;~it~~ ~~~/:)): ...
IIvaiJahl. ., th~ .ii,:;'
n,-
11.ennal1'1-ealmeot
..
Un .....
, tIG;;i;~;~,i' dl;1I f~;
of (;rollllSII'SIIT.XI.5
-------
Table 12,
nEMED~I. TECIINOI.OGY IDENTIFICATION AND SCREENING FOR CROIINU WATIm
FEASIDIU1Y STUDY. DISPOSAl. SPECIAUSTS,INC.
ROCKlNGJIAM, VERMONT
n".I>on...
l'tfr.o,',r,,(J'..chllulu
Proc.... Option
De.onptlon
Ertectlvene..
Implemolltobillty
Co.t (I)
Stot 118/.' '18 t I ncot lUll
(coni.)
Otr..iUj niep~~at
throiigb Plpjllfuf
to no.reat..
..... . . .
~1~~:~t~iti~1rJ.::.r...
COII"tnlcle:d' .. aJ1rii,,,(j~Id,H
r~.'I~t ~~irji1eit ~ !MlF'';
hlCir~,;..~,t i.rtmlc tuffic~."'. .
~~UAI« ij'J'iHe~ ,.~i,t !l1'~~/
""'P....,... ".
.::::':':':.Ui~~.'::::
..\~I;jl.f.
. "" .
H'H :.. Elitiiii;otedrluet.c;i'
..........'..".". ". ",. ".. ..
"."'.".',.,"." ."",..". ". .".". "". .
> jlnpi;'in~,ii ~hi1iiy.
Tr...led Waler On...ile
} Pii;~JjII" eOiUl tnit;tioM
. dilYlcn/t.
O"..il. Uiedll.rg. Tr..'." groll",1 will or io
t:rroctiV8 in rellaovillK tnmltnl wulur
""'," i...... eli.eI,'II,.go JlUI:lllil.
I.ow
Uul..illutl ,111ft In;
to
Surface Water
diacbarged to Connecticut
River througb pipeliDe.
from e ite. Rivor b.. large
aeeimilative capacity.
capital
. Effectiven.... and
implelDentability.
Low
O&M
.-
"",."
---.,'"' .
Noloo:
I. Coot rel.llve to oIh.r pro"... opllon. within Ihe ..me """'nology type.
2. 811.dinll d.no"'. .Iimlneted I",:hnology. .
&128104
l!alum P,q8Ct 64ft8.02:OSIf'8RT.XI.5
-------
:---
Tflhh 14
Acllnll Tn 110 l'nkell'o,Alln'" AIIAI/a
M",II,uII/AulhoriIY n..A .. guidanca lavela prior "a'.I.Iial.mant o(TeGa, Howovar. excepl for mallg.ne.o
to promu'g.tion, (which -a ealad.ted in ",a rUlRA), TeGa ware
" eal.hli.ho.1 baae" llpollalala a".. fa.la....' MCr.... Sill..,
rrol'""e" MCr.... ware not ...ad in "."",Ii.hing 1'Cn. a"d
,, " COlnpolI,"I. li.tada. pro/>oaa.1 MCr.... do 1101/"0..,,1 all
-,..,. '"'.OI:e/>'ablo risk, 110 ("'1h"r actioll" .r~ IIcce...1)' 10
...-. IIlIlIinlhia AllAn,
CI,e.nic.I-Specific SOWA. Secondary MCr.... (40 To be S"condal}' MCr.... h.v. he.1) promu'gal"d for we'f.''O-h..ad S"co".181}' MCr.... were co""idar"d d"rillg lI,e rs for
' f'e.ler.1I Cfnl4:!) eo"eillal'8,1 .1.1I.I.n'. (e.g,. color), '1,e." erilo,'i,; 8"0 a.alhclic I,..a.. cellll,liehlllellt of1'Cf:a, Howovor, "COI'l (11"1118"1;8'10.0
.lId .ra not ri"k b..ed. 8.con.181}' MCI.... a.'O Ihore(ore IIOt (which w.a ealculaled in Ilia mlllAl, 1'C(;a we...
conaidared AllARa. """'''Ii.hed haaed "pan elale .nd federal MC'"", Sine.
SeeolIC'BI}' MC'.... ware not lIaed in e.l.hli.I,ill/: TeG. .11,1
compounds Jialed .. aecondal}' MCr.... elo nol poaa an
IInaOl:al'l.ble risk, no furlhar .ctio"" Bra nec.....1}' 10
altaillihia ARAR.
a/2S/IH
AllAns FOn COMPI.IANCE
81TE W'nE AL TEIlNA'hVE 8W.' MAINTA'NANeE ANn NA11"IA', A' ""NIIA"I10N "'8"08", 8"F.el",'91"9. 'Ne. ..".nUl.noy 91'''".
' IIOC'UNGi'AM. V.:UI\ION'I' .
"n10'" 01128 004 ''Sl1t~W2A.X'_'I
-------
Tahle 14
AllAns l'OIl COI\II'I.IANC.:
811'E WIOE AI.n:RNAllVE 9W.2 MAINTAINANCE ANn NATUlIAI~A'''''';NIIA'''ION mSI'OSAI. SPECIAI.Im'S. INC, ftEA911111.ITY 911'UV
nOCIUNGIIAM. Vf:nMoNT
Acllon To lie Token To Allllin AIIAI/.
Medlum/Aulhort ty Requirement Stah.. Requirement 9yn0I'.I, 9W.2. MOIl0lteUlent and Nalllrol Allellnallon
Chomical.Specifia r.rA Uuman Uoallh AB.eo.monl To'" r.PA ".velol>1 CSFI for h.allh ..ITo,," ".elI.men'. for '11,.... valu.. """.Olltlll> 10 .Ialo CaliCOI' ,i.k I'0loll"y
I"a".ral) Cancer Slope F,cton (CSr.) conllde...d ovah.ation by the Uuman 1I...lth ABlelo...ont Gtollp ;1I(001lation and won 1I.0d during the IllIItA to o.tahliah
.ilo riok. No furthor action il nocoe18ry to aUain Iho
TIIC.
Chomical-Specific EPA Refonnce Do..a (RCD.) To be RIDe are dOlelovel1 doveloped by 1100 EPA for 1110 in tho nfICall.e thil alternative ptovidoo for mainlenanco of II,.
(t'.doral) canaldo...d chancterizalion of lieu ,dllO 'to non..,arcino£el18 in va rioll. low pennoabilily landfill CAp. conlinllo.1 oporalion 0(11.0
me"i.. Jloul. 6 alope al.biliulion and '''pago oolilrol.yal.....
.."I conlinllod oporalion of II.. ga. man.gomont .yolem,
Ihis THC which w.. ulod to od.bliah 11.0 TCG for
manganOOI will be mot,
Chemic.l-Specilic Vennont Ground Water Applica blo TI...o regulatiol18 incilldl a ground waleI' TIltougb . combination of ndllction in I.ndfill infillration,
ISI.,.) Prot.ction Rulo and Slralegy ptolection ",10 an,I.lralogy. . ground walor and oonlinued O&M of NTCRA .ctiviti.., Vennont waler
(10 V.S.A. Ch.pler 48) cla..ific.lion Ichomo. and groulld w.lor qua lily qu.lily .land...
-------
('
Table 14
ARAns Fon COI\II'I.IANCF.
SITE WIOE AI.TEnNA11VE 8W-2 I\IAINTAINANCE ANn NATlIll.Al. A.1'1't:NIJNI'ION mSI'OSAI. SI'ECIAI.I91'9, INC. PEA911111.1TY sTuny
ItOCKINGIIAIIf, VEItIlfON'!'
Adl.... T.. II" 'I'..k.... '1'.. All III.. AIIAII.
1It".II. ..,,/A III hurt Iy It".."........ "... HI.I,.. II 11'1"""'''' nil I NY""I'.I. N\II.2, 1\I..",.It'"II"..1 ....1 N.........I Allnll....I\II"
Chemical.Specific Vennont Heallh Advillori... To be Vennont developed h"alth advilloriea .. guidance crileria for. Health advillorilla Were cOMidered during Ihe 11.11 IlIIRA
(Slalll) conaidered drinking Waler in the abaence of MCte. an,l rs for ealabliahmllnt ofTeGa. lIowever, ncepl for
lIIa"«a,,eall (which waa "al""I,,leol ill 11.11 IlIIIIAI, TC(;.
were ealahllahe" baaed ul'0n IIlale a lid fe,le..1 MCte.
Sillce health advlaoriee Wllre not uaad in ealaMillhing
TeGa and compound liIIled .. beallb advilloriee do lIot
1""'" an unaoc8plaLIe "eallh riak al 11.8 aite, 110 further
"dio"...e ""co.ury 10 .11";11 11.;. AIIAII.
~lIlln"o \\'...~:..
Ch"mic.I.Sp.cific r...l.ral Ambient Waler To be f...I..IlII AWQC are I'88llh.b.....1 "ril.ria wl,id. h"ve beell '11111111g11 a comhinalion of reductio II illl"",1Ii1l infiltralioll,
Ir...I.,.11 Quality Criteria (A\VQCI cO"ii"..red tlovolol,o,1 (01" on carciuoS811ic aU11Ilonr.ArciUlJ,:unic .",1 CUIII illllll,1 0& M of NTCIIA .rl ivil io., COII.t illlolli. of
leWA 8.,1ioll :IIHCal(\) a",1 001111'01111.1.. 111e clilel'ia for Ihe I,roledioll of IImlll,;ical t"aJnceru wiilllleot AW<}Ce. 8..11 tlUI1'Cfnl'tl Chie Tne won.11
40Cf"I:lU recel'lolll from aCllle .",1 chronic impacle arll beillg lIae0811 an
Sedimllnt Guidalinell (ER.L .nd IIlIdpainte for toxicity uuuIDenl for pelat;ic'hiola. ecological risk. 11ll11l1gh a oombin.lion of reductio II in
[n.M) lall,Ifili ililillralion, alld cOlllilllled O&M of NTCltA
.ctivitiea, conetiluenla of concern ill sediment will he
mainlained atillveia below tb0811 posing an ecological
ri.k. 11.erefol'll, 110 fur"'"r .ction ia necessary 10 allain
Illia TI1C.
All'
Clillmic8'-Specific 11,reahold \.imit Vailles (TLVe) To be TI'llee elandarels w"re i..uacla. conallnall. TIII1IIIgh mainlellance oflhlll,,",lfili cap al,,1 gae
(fedllrall conai
-------
Tflhl~ 14
ARAIIS FOil eOl\lI'UANCE
SITE WIDE AI.TERNA11VE SW.2 MAINTAINANCE ANn NA11.JUAI. A1'I'ENI/Al'fON mSI'OSAI. Sl'ECIAI.ISl'S, INC. FEASIDII.ITY STI/DY
. IIOCKINGIIAM, VEUMON1'
Ar.IIOI'l'o II" l'nkm, Tn Allnln AIIAII.
M...lluIII/A ul!torily ""' ulremenl'. SI.hu lIe'l"I"'''II''1I1 SYllo!,,,la SW-2lMnnltlfeinelll Biul Nlttl,rBt Attenuatlnn
WcllnndsWluoclplnlns
l.ocal iOIl-Specific Fiah and Wildlife Coordinalion Applicable Under Il.ie regulation, allY ",o.lifieelion of a waler Ui.el.e..ge oflo"ele.1 waler u...ler Ihi. ellonoelivo wo"I.1 nol
(t"ed.ra" Act (10 U.S.C. 601) Lo<\y requiree oonaultalion will. II... U.S. Fi.h and occur. Therefore, no fmiher actiona are naceo..ry 10
\Vil.llifo Servicoa, 10 .Iovelop "'oa.urea 10 ,wovoul, HII"illlhi.. AllAn.
miligalo, or oo...pan88lo for I.... 10 Ii.h elld
wi"'life. 11.ia reqllirement ia a."'.....e.1 uOller CW A
Section 404.
l.oca. iOIl.Specific Proloction of flood I'laina Ar>plica ble Undor Ihia rogulalion, Fodonl egellcio. are ....qui'".1 1I...ler Ihi. alternalivo, lu,re"" weier aeol'" Il.at "'ey
('-o.lan" E.eculive Onler 11088 to avoid adveree eflectl, minimize J'Olenliall.arm, ..hierooly afloct wollan.1a ae
(40 erR 0, AppendiJr AI "'Itore and prelerve Ih" natural and l>enelicial ....di.cod. Diachargo of t",aled _ter und.r Il.i. allon..liva
valuee ofnood plaina. would not occur. Thorefore, no f\.rtl.ar ecliona aro
lIoce.88ry 10 ellein Ihi. AltAR
Local ion.Specific Prolection of Wallenda Applicablo Reqnirea redenl egendee 10 avoid impada ...ocialad Undar Ihia altarualivo, .utfa"" wate.. .eepe I hat may
(roderal) Exocutive Onler 11 !J!JO with the deslruction or 1088 of wollan,1a and 10 avoid adveroely afloct wellanda ae
(40 crR G, AppendiJr AI IUpport of n"w conalruction in wetlanda if a practical reduced Ihrougb operation of tbo Route 6 elopo
altomative ""ieto. etobilizalion and ooopage oontroloyotam and
maintonance of tla"landfill cap. l£tbee" requirement. are
adhered to, thi. ARAR wiU be attainod.
-
Local ion-Specific Clean Waler Act (CWAI (33 Relevant and Under thi" reqnirement, no activiily tha" adveroely Under thi" altemalive.lu"a(18 water leo... Ibat may
(roderal) u.s.e. Sec. 13441 and U.S. Appropriate aflectl a wetland "ban be pen:nitted if. pr"cticable adveroely aflect wetlande ae
Anny Corp of Engineere ., altemative tltat Ita, lell eflect ie available. reduced Ibrougb opera lion of Ibo Roule Ii olopa
Nalionwide Pennit Program .Iabiliution aud oeepago oontrollyolem and
(33 CrR Part 330) rn.inlenlnoo oflholaudlill cap. If I hue requiremenle a ro
- adhe",d to, thil ARAn will be aU.ined.
~ -.
---~
Locat;o...S".cir,c C\VA 40.4..0ro.lgo and rill !lolovanl and Urqllireo th.t no prncticfthla .lIenm.ivtl e.iah he(ore tlrc(lb.;nt; Ihu).!r Hlie alten'lIlivtI, .noc1ificnl ion of wet 1"l1clo will not },r.
It'o.l.rall Acliviti.. 140 crlll'art \!:IO: :J:J "'"p,ol,ri.le .uel fillinG wotlanlle. ,.110 activity will 1101 nilitle. "ioln.iun or IIUl'1!IUI8')'. '1'1101"0(0"0,1\0 r...thor IlI1iOll11 8''0 rO'Jlli"uIIO
C"II 1'8I,a :I\!U.:I\!HI oIalo walor quality .la...I."la or .i,;IIif,ca..1 .lub,...,I.1 ion of 11.0 all.iul"ia AIIAII.
wllor Ind Idvereo effocta will 1.0 minirniz!d.
fir. 1\,,,.
"".1II11I11~ft IJOi t1inl:1WJA XI..'t
I' 4 II( II
-------
:--
Tahle 14
ARAns FOR COI\WI.IANC.~
SITE WIDE ALTERNATIVE 9W-2I\1AINTAINANCE AND NA1'U ItA L ArrENtJAl'lON DISPOSAl. SI'ECIAI.I9Ts,INC. FEASIDILI1Y STUDY
nOCKINGIIAl\I, VEnMONT
Acllon 1'0 ""Takell"" All alII AltAllo
Medlum/Aulhorlty Requirement 9t."18 R8rinkilll W.ter SIII1II."I. (40 Appropri.le reporting for pll!.lie ,"'iuking wat..r .Ulil'li.., ,'O.i,lon08a in the vicillity o(the l.u,UiII will iuch..le
C.'1t 141 SuLp.rt. 0, C, IDd DI .' oompli.nce witb .pplication monitorillg .nd reportiog
.' requiremenle. .
,.
Action.Specific EPA Tecbnlc.1 Quld.nell To be Pre.ent. technlc.1 .peclli""lIona for Ibe .Ieoign of Inilltil.yer COII.ln,cllon .1"I'o.I"lell."ce o(lhe e.p willl,e
'(t'e.ler.1) Document: Fin.1 Cov"n on conoldered coven.t I.ndlill. where h'.unloue .uhet.nDee were oollOiolent with Ih..e guidelinee.
IIn.rd!'ul W..te landfilL. .nd diapoeed of,
Surf.08lmpoundlUenl'l
It:rN6:10.sW.89.0471
6fl619C
I'rujecl 0112~.OOC:rsTIJSW2A.XIS
-------
Table 14
. ARAR!I FOR COMPI.IANm~
81TE WIDE AI.TERNAl1VE SW.2 MAINTAINANCE ANn NATUIIAI. A'I....:NUATION J}l9I'OSAI. SPECIAI.I9T9, INC. FF.ASmn.n'Y STI/I)Y
nOCKINGHAM, VEUMON1'
Ar.IIOII To no Tnk"n To Allnl.. AIIAII..
M...llmn/Anlhorlty ne.."lre,"ellt 8tah.. Ue....lre.......t 9Yllo..el. 9W-2: 1II""",,,"',,"t ..1111 N..tur..1 Alle..u..lloll
Act ion -Specific Vennont NatioDal rollulion A,'plicable Regulalee tbe diecharge oCetonnwaler inlo Ihe wate.... or Mainlenance and moniloring aclivilieo undor Ihie
(State) ()jecharge EliminatioD Sy.tam Vermont, and the tenD' aOlI ;"'nditioD8 ofpermile. allemalive including control of ouna"" waler releaaeo an
-------
APPENDIX B
-------
Fig1ire 1
,
I .....
I! :,,~~'::'~::-!J~:.~,:;,\n!'I:'" I'..'''{'':-''':/.''''''~:--'''''''' ,
,;!,,-..,~, j':J":,':""',7':I"'It:..',r':'..:;;r:./:~"'="I':'::~f""if ' I'. ..~,- .~ "--.~-'--'\ -. :
- "}",....":..(.,,,_.,,,.,-/,,;,.,/; \,.- -, -x -."""\g' ,
,t,;~k:}:;!'1./> :,i}--"',/.I Ii] II; I~'~!~f, 3.1> ;~.:l~-il£. IN
~..t.X ~\~f lM j;u';l"')f : f:t~s~; ~ ;'"j;:~( (';Q.::~\~~ '~ l~ '-~'~~~;j~:; {$'; ~~f!~
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(:) RE9IDENCE
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1" = 325 fT.
- BFI-ROCKINGHAM
_IT.
II1\{,
Sri - ROCKINGHAM
SITE MAP AND SAMPLE LOCATIONS
r:~
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-..
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Arthir D Little
-----
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, GREENWOOD
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--------------
--.------.
. APPROXIMA TE PER/ME TER
OF LANDFILL
~ RUMRILL SPRING.
I
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APPROXIMA TE LOCA TlON I
or NEW MONITORING WELLS
- ~A~O« .--{-/
S8
. DISPOSAL SPECIALISTS. INC
lEST[R/DANfORTH Yw£lL
~(
DISPOSAL SPECIALISTS. INC. (24 :, ~2) .
.-'
.~
-------
APPENDIX C
-------
i
,~
;c.£ ~-
~
. ., .~ <,?
.~~
~~
" x
State of Verrno~t
AGENCY OF NATURAL RESOURCES
Department of Environmental Conservation
Depanment 01 Fish and Wildlife
Depanment 01 Forests, Par1Voice
, .800-253-0' 95 Voice> TOO
Commissioner's Ofl"'ace
103 South Main Street
Waterbury, Vermont 05671-0401
802-241-3800
FAX 802-241-5141
September 12, 1994
John DeVillars, Regional Administrator
USEP A, New England Region
JFK Federal Building '. .
. Boston, Massachusetts 02203
RE: BFI-Rockingharn Landfill Site
- rf1M /'
Dear Mr. DeVillars; \J~' V'-
The Vennont Department of Environmental Conservation (VTDEC) has reviewed the various
remedial al~rnatives developed for this site, and we support the selected remedy, which is operation
and maintenance of the multi-layer landfill cap; continued operation and maintenance of the existing
leachate collection system and ground water i~terception trench; continue
-------
APPENDIX D -
-------
Section
II
III
IV
TABLE O? CONi~NTS
Page
Preface.
. . . .
. . . .
1
. . . . '"
I
Overview of Remedial Alter~atives Considered in the
Feasibility Study and Proposed Plan.......... .........
2
Site History and Background on Community Involvement and
Concerns. . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . .. . 4
Summary of Public Comments and Agency Responses......... 8
1. Comments Regarding the Superfund Process
- TAG Group and Citizen Comments.
2,. Comment~ Regarding the RI/FS ," 0
- PRP Comments........................... o. . . . . . .. 11
- TAG Group and Citizen Comments... ..... ....... ... 11
3. Comments Regarding the Human Health and Ecological
Risk Assessments
- PRP Comment s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27
'- TAG Group and Citizen Comments. ...... ........... .27
4. Comments Regarding the Proposed Plan
- PRP Comme n t s . . . . . .... . . . . .. . 3 5
- TAG Group and Citizen Comments. .. ..... 36
5. Comments Regarding the cur~ent NTCRA Activities
- TAG Group and Citizen Comments .0. .0. . . . . . 45
6. Comment's Regarding Long-Term Monitoririg Plan
- TAG Group and Citizen Comments. .. ..... 48
. . . '"
8
Remaining Concerns ..... .....'. ....... ........ ........ ...53
Attachments
A
B,
Formal Community Relations Activities Conducted at
the BFI-Rockingham Landfill Superfund Site
-------
BFI-~OCK:~GHk~'LANDFILL SUPERFUN~ SITE
~ESPONSIVENESS S~~Y
PREFACE
The U.S. Environmenta: Protection Agency (EPA) held a 30-day
comment period from J~~e 30, 1994 to July 30, 1994 to provide an
opportunity for the p~~lic to comment on the Remedial
Investigation (RI), S~;plemental Remedial Investigation (SRI),
Human Health Risk Assessment, Ecological Risk Assessment,
Feasibility Study, Lo"-~-Term Monitoring Plan, and Proposed Plan
for the BFI-Rockingha~ Landfill Superfund Site (the "Site")
located in Rockingham, Vermont. In the Proposed Planr issued on
June 15, 1994, the EPA announced a preference for the Natural
Restoration and Manage~ent of Existing Site Controls Alternative.
A collection of all documents used by the EPA in choosing this
alternative were made available for review at the EPA Records
Center (90 Canal Stree~, Boston) and the Rockingham Free Library
'(65 Westminster Stree~, Bellows Falls). These documents are
known collectively as ~he Administrative Record.
The purpose of this Responsiveness Summary is to document the
EPA's responses to the questions and comments raised during the
public comment period. The EPA considered all of the comments
summarized in this doc~ment ~nd included in the Administrative
Record before selectir.a a final remedial altern~tive to address
the contamination ~i t;e Site. '
This Responsiveness S~~mary is. organized into the following
sections:
I.
Overview of ~emedial Alternatives Considered in the
Feasibilitv Study and ProDosed Plan - This section
briefly outlines the remedial alternatives evaluated in
the .F$ and Proposed Plan, including the EPA's
preliminary recommendation of a preferred alternative.
II.
Si te Historv
and Concerns
history, and
and concerns
and Backqround on Communi tv Involvement,
- This section provides a brief Site
a general overview of community interest
regarding the Site.
III. Summary of Concerns Received Durina the Public Comment
Period and E?A ResDonses To These Comments - This
section summarizes and provides the EPA's responses to
the comments received from residents and other
interested parties during the public comment period.
Additionally, comments received from the Potentially
Responsible ?arties (PRPs) are summarized and the EPA's
responses to the comments are provided.
IV.
Remainina Cc"-cerns.- This section summarizes comments
raised durir.~ the public comment period that cannot be
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2
but which wi:~ continue to be of concern c~=ing the
implementatic~ and monitoring of the EPA's selected
remedy for the Site. The EPA resDonds to these
comments and will address these concerns during the
development or the Long-Term Monitoring Program and
Operation and Maintenance Plans for the Site.
In addition, two attachments are included with this
Responsiveness Summary.
Attachment A - List of community relations activities that EPA
has conducted at the Site.
.Attachment B - Transcript of the July 20, 1994 public hearing
regarding the Site, held at the Hit or Miss Club in Rockingham,
Vermont.
All comments received during the public comment period have been
included in the Administrative Record.
I.
OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE
FEASIBILITY STUDY AND PROPOSED PLAN
Using information gathered from the Remedial Investigation (RI),
Supplemental Remedial Investigation (SRI), Human Health. Risk
Assessment, and Ecological Risk Assessment, EPAidentified
remedial action objectives for the cleanup of the Site.
The remedial action objectives for the Site cleanup are to
control the source of ground water and surface water
contamination, centrol the release of landfill gas, prevent
contact with the landfill debris, protect the Connecticut River,
and restore bedrock ground water to drinking water standards.
EPA has established cleanup goals for the bedrock ground water at
levels that EPA considers to be protective of public health and
the .erivironment.
EPA initiated a non-time-critical removal action (NTCRA). in
February 1993 to address the centrol of the source of
contamination. Under the NTCRA, EPA selected an action that
included constructing a multi-layer low permeability cap over the
landfill to control the release of leachate and prevent direct
contact with the debris mass. The NTCRA also included measures
to control of the release of landfill gas and to prevent
contaminated surface water seeps from flowing into the
Connecticut River~ Institutional controls were included in the.
NTCRA to prevent an actions that might reduce the effective of
the cap. The NTCRA institutional controls also prevent ground
water use on the facili~y property. The control of the source of
contamination also con~ributes to the restoration of ground
water.
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3
After identifying the remedial action objectives and cleanup
levels for the Site and considering the extent to which the NTCRA
addressed these objectives and cleanup levels, EPA develooed and
evaluated potential cleanup alternatives, called remedial-
alternat~ves. The Feasibility Study (:S) describes the remedial.
alterna~~ves considered to address the bedrock ground water
contam~~ation and to maintain the effectiveness of the actions
impleme~ced under the NTCRA. The FS also describes the. process
used to narrow the range of alternatives to three remedial
alternatives. The FS also provides a detailed evaluation and
comparative analysis of the three remedial alternatives based
upon ni~e evaluation criteria established in the National
Continge~cy Pla~.
.,
. .
EPA's preliminary recommendation of a preferred alternative to
address Site contamination and meet the remedial action
objectives and cleanup levels involves relying on natural
restoration processes and the management of existing Site
controls to restore bedrock ground water within 15 years of the
completion of the landfill cap installed under the NTCRA and
prevent the generation of surface water seeps that could flow
into the Connecticut River.
The preliminary recommendation included:
. .
.
continued maintenance of the multi~layer cap currently
under construction;
.
continued operation and maintenance of the existing
leachate collection system and ground water collection
trench. The collected leachate and ground water will
be shipped to an off-site facility for treatment and
disposal;
.
continued operation and maintenance of the gas
col~ection and treatment system; .'
maintenance of institutional controls: to prevent
future use of the landfill that would damage the multi-
layer cap; to prevent ground water use throughout the
area of Site-related contamination; and to assure a
water supply to residents with Site-related
contaminated ground water beneath their residence.
.
continued long-term monitoring of the se~ps, ground
water, collected ground water and leachate, Connecticut
River surface water and sediments, and storm water run-
off to confirm the nature and extent of. contamination
and confirm the restoration of the ground water; and
.
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4
REMEDIAL ALTERNATIVES EVALUATED IN THE FS
The three re~edial alternatives considered by EPA are listed
below. The June 1994 Proposed Plan and Feasibility Study should
be consulted for a detailed explanation of these remedial
alternatives as well as EPA's preferred alternative.
ALTERNATIVES CONSIDERED
Alternative SW-1:
No Further Action
Alternative SW-2:
Natural Restoration and Management of
Existing Site Controls
Alternative SW-3:
Ground Water Extraction and Treatment and
Management of Existing Site Controls
II. SITE HISTORY ~~D BACKGROUND O~ COMMUNITY INVOLVEMENT AND
CONCERN'S
The Site is located in southeastern Vermont on the west side of
u.S. Route 5 in Rockingharn, Vermont on a terrace overlooking the
Connecticut River. . The Site is bounded by undeveloped woodland
to the north and west, 'Route 5 to the east ,~nd a residence and a
private club to the. south. Across the river is Charleston, NH
and a publicly-owned treatment works (POTW). The surrounding
area is rural residential property and undeveloped woodland, with
approximately 17 residences located within 1/2 mile of the Site.
The area between the Site and the Connecticut River has a very
steep grade and thus is likely not suitable land for development
purposes. There is a substantial wetland along the edge of the
Connecticut River below the Site.
The Site consists primarily of a 17 acre .sanitary landfill. . The
landfill and associated facilities occupy 25 .acres of .
approximately 120 acres owned by Disposal Specialists Inc. (DSI).
From 1968 until 1991, the landfill received residential,
commercial, and industrial solid and liquid waste. Industrial
waste was only accepted during the 1960s and 1970s.
Approximately 1.2 million cubic yards of solid waste and an
unknown quantity of industrial waste were disposed of in the
landfill during its operation.
Prior to the 1960s, the Site was undeveloped woodland. D~ring
the early ],960s it was used as embankment fill for the
construction of Interstate 91. In 1968, Harry K. Shepard
received approval from the Vermont Department of Health to
operate a municipal solid waste landfill at this location. In
1969, Harry K. Shepard, Inc. deeded the landfill property to DSI.
The landfill was operated by DS!, and Harry K. Shepard, Inc.
continued as a solid and industrial waste hauling company. In
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5
.:0
1973, Browning-Ferris Industries, Inc. purchased DSI and Harry K.
Shepard, Inc. and continued operation of the landfill as DSI. In
that same ,year, Harry K. Shepard, Inc. changes its name to
Browning-Ferris Industries of Vermont, Inc. (BFI-Vi).
'"
The Site was proposed for inclusion on the National Priorities
List (NPL) on June 24, 1988 (NPL update #7, 53 Fed. Reg. 23988-
98). The Site was listed for final inclusion on the NPL on
October 4, 1989 (NPL final rule update #7, 54 Fed. Reg. 41020).
The State of Vermont has regulated the landfill's operations
under its solid waste management program since 1968. In 1979,
the Vermont Departme~t of Environmental Conservation (VTDEC)
collected and analyzed groundwater samples from six bedrock wells
in the vicinity of' the landfill. Based upon the re~ults'of those
samples, the VTDEC required DSI to supply nearby residents with
bottled water. In 1980, a new water supply well was installed on
the DSI property to service the facility and the residences.
This new water supply eliminated the need to provide bottled
water to the residents. DSI entered into an agreement with the
residents to maintain the water line for twenty years.
As a result of the contamination of the bedrock drinking water
wells the VTDEC required DSI to perform several hydrogeolog~c ,
investigations. The results of these studies were presented ,in a
series of r~ports. TheVTDEC'also required sampling of
monitoring wells and of the Connecticut River twice per year.
In 1989, DSI installed an active gas collection system in order
to comply with the Vermont air pollution control regulations and
prevent methane problems in the facility buildings. The system
includes 28 gas extraction wells installed into the landfill'
solid waste material. The collected gas is burned in a flare.
In Aug~~t 1992, DSI an9 BFr-VT entered into an Administrative,
Order by Consent (~OC) with EPA for the,performance, of a remedial
investigation and feasibility study. This Site was also selected
for use as a national pilot for the implementation of the EPA
municipal landfill guidance. The pilot program involved the use
of the landfill guidance to streamline the remedial investigation
and feasibility study for landfill sites.
In October 1993, BFI-VT and DSI proposed to install a ground
water interceptor trench to collect overburden ground water to
prevent landfill-impacted seeps from flowing into the Connecticut
River. This trench was completed in January 1993. The water
collected in the tre~ch is shipped to an off-site facility for
treatment.
In February 1993, E?A initiated an action to cap the landfill as
part of the EPA Superfund Accelerated Cleanup Model (SACM). SACM
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6
time-critical removal authori~y to expedite the Superfund
process. Information Update #2, issued in July 1993, provided an
explanation of the SAC~ process. '
','
In July 1993, EPA issued a fact sheet describing EPA's proDcsal
to cap the landfill as part of the SACM. In addition to the
construction of a multi-layer cap, the proposal included the
expansion of the active gas collection system, deed restri~tions
to prevent disturbance of the cap, and continued operation and
maintenance of the leachate and ground water collection sys~ems
with treatment of the collected water at an off-site facility.
30 day public comment period with two public meetings were held
during July - Augu~t 1993.
A
In September 1993, EPA signed an Action Memorandum finalizing the
~ecision to cap the landfill as a SACM action. On September 24,
1993, EPA entered into an AOC with BFI-VT and DSI to complete the
design and implementation of the multi-layer cap.
In April 1994, the design of the multi-layer cap was complete and
construction activities were initiated. The installation of 11
additional gas extraction wells was completed by the end of May.
Construction of the multi-layer cap is expected to begin in July
and to be, completed by November 1994.
History of Community Involvement
The Site has been subject to moderate to high levels of community
involvement through its history. Several local residents
objected to the development of the landfill in 1968. Several
residents between the Site and the Connecticut River are supplied
water due to contamination of several drinking water wells by the
landfill. Past public concerns have focused on: overflow of
liquid wastes from the landfill onto adjacent properties during
the early 1970's; drinking water supplies; the receipt of ' ,
municipal incineration ash by the landfill; and expansion of the
landfill. The State of Vermont held public meetings and was
responsible for community involvement prior to the Site being
placed on the NPL.
Since placement on the NPL in 1989, the public has been
interested in the Superfund process at the Site. Attachment A
provides a chronology of public involvement since EPA began
formal involvement in the Site in 1992.
A technical assistance grant (TAG) was provided to the Vermont
Public Interest Research Education Fund (VPIREF) as part of the
Superfund process. This group has reviewed the Site documents
and provided comments to EPA. Citizen concerns throughout the
process have focussed primarily on water quality, Site access
control, and surface water run-off. Public meeting attendance
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7
u
has been quite variable wi:h only one person attending the public
hearir.g for the NTCRA to 15-20 persons attending later meetings.
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8
III. SUMMARY OF CO~~ENTS ~~CEIVED DURING THE PUBLIC COMMENT
PERIOD ,AND RESPONSES 70 THESE COMMENTS
This Responsiveness Summa~y summarizes the comments received
during the public comment period held from June 30, 1994 to July
30, 1994. Two sets of wr~~ten comments were received: one from
the TAG Group, VPIREF, an~ their technical advisors, and one from
the PRPs. Two individuals and the TAG Group, VPIREF, also
provided oral comments at the public hearing held July 20, 1994.
A copy of all written com~ents received is included in the
Administrative Record and a copy of the'transcript from the
public hearing is attache~ to this Responsiveness Summary.
. . . .
1. Comments Regarding the Superfund Process
2. Comments Regarding the ~I/FS
- PRP Comments
- TAG Group and Citizen Comments
3. Comments Regarding the Human Health and Ecological Risk
Assessments
- PRP Comments
- TAG Group and Citizen Comments
~. Comments Regarding the Proposed Plan
- PRP Comments
, - TAG Group and Citizen Comments
'S.Comments Regarding the'current NTCRA Activities
6. Comments Regarding Long-Term Monitoring Plan
- TAG Group and Citizen Comments
1.
Comments Reaardinq the Superfund Process
Comment a: A comment was submitted stating that the public has
not had a ~ufficient rol~ in ,the process due to the SACM approach:
and that no changes should be made to any,Site related design,
, document, or action without public comment.
Response: There has been significant opportunity for public
involvement at the Site. There have been seven public meetings
in less than two years at the Site. All major Site reports,
including the Remedial Investigation, Human Health Risk
Assessment, Supplemental Remedial Investigation, Ecological Risk'
Assessment, Feasibility Study, and Design Reports, have been
placed in the Site informa~ion repository as soon as they were
available.EPA and VTDEC have continually 'indicated a
willingness to meet with t~e public over any issues raised for
concern.
The Superfund Accelerated Cleanup Model (SACM) and EPA guidance,
Conducting Remedial Inves~~gation and Feasibility Studies at
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9
o
activities to initia:~ source control actions as quickly as
possible. This Site ~as made use of SACM and E?A guidance to
make a 'decisiop to ca;the landfill within o~e year of the
initiation of the RI/?S and to initiate cap construction within
two years of initiati~~ of the RI/FS. E?A believes control of
the source of contami~ation should be achieved as quickly as
possible. However, E~A also provide the public with significant
opportunity to participate in the SACM process. Two facts sheets
were issued prior to :he initiation of the comment period for the
SACM action, which was to cap the landfill. A public information
meeting was held to i~itiate a thirty day comment period and a
transcribed public he=.ring was held during the comment period.'
After the selecting c: the cap as the SACM action, EPA placed
each draft of the design in the Site repository.' EPA also issued
a fact sheet discus~i~g the fin~l design and describing
construction activities prior to the start of construction. A
public meeting was he:d to discuss this Fact Sheet.
Once a remedy or remcval action is selected for implementation,
the design process must be implemented. There are often changes
to the alternative described in the decision document during
design. The vast majcrity of these changes are not significant
and do not change the ability of the action to meet the
performance standards. Significant changes in scope, cost, or
performance are documented by an explanation of significant
difference. This doc~ment, if it were' to be prepared, would be
placed in the site repository wi~h a notice in the press.
Fundamental changes i~ scope, co~t, or performance must undergo
public comment. No significant or fundamental changes were made
to the NTCRA as a result of the design. The consideration of
alternative materials would not be a significant or fundamental
change. EPA risk assessment guidance requires that the human
health or ecological impact of any action be evaluated as part of
the .FS or design. EPA had evaluated the potential impact of the
potential design changes (sewage sludge and shredded tires) and
determined that no unacgeptable public health risk would result
from the use of these materials. To provide the public with an
opportunity for involvement in the design, the EPA placed ~ll
design documents. in the Rockingham Free Public Library as soon as
each document was released.
o
"
Comment b: A comment was provided stating that the TAG program
must be modified to wcrk more quickly based on SACM. In
addition, VPIREF indicated that VPIREF and their technical
advisors had only been re-imbursed $611 from EPA as of the date
of the comments. VPI~=:F also questioned the responsiveness of
the TAG program in responding to these concerns.
. Response: VPIREF had submitted two additional requests for
reimbursement totalin~ $18,645. Both of these requests had
returned to VPIREF due to errors in their preparation. EPA
assisted VPIREF in t~e corrections that had to be made in an
to be
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10
effort to expedite the paYIT.e~t process. On July 28, 1994 EPA
approved and processed for payment $11,160 in Technical Advisor
costs, the balance of $7,485 in costs incurred by VPIREF & VPIRG
have beentemporarilly suspended due to a lack of documentation.
(,
EPA had previously meet with VPIREF & VPIRG and provided
instructions and manuals on the proper way to file requests as
well as other required reporting documents. Additionally, EPA
staff have made themselves available to the VPIREF to assist them
in any way needed.
EPA awarded the TAG to theVPIREF on September 27, 1993. VPIREF
chose to hire the .services of a Grant Administrator to manage the
TAG as allowed by.the regulations. VPIREF did not enter into a
contract with a .technical advisor until March 20, 1994, a
timeframe that is excessive with the assistance of a Grant
Administrator. The TAG Program acknowledges that SACM strains
the limits of TAG's in the ability to procure the services of a
Technical Advisor and keep pace with the activity at the site.
This is being addressed in the changes to be made when Superfund
is re-authorized.
Comment c: A comment was submitted stating that the public
participation has not. been adequate and that documents were
received too late. In addition, a co.mmentwas provided on the
difficulty in completing TAG applications and obtaining funding.
Response: EPA believes that documents have been available in a
timely manner for the Site. The initial Remedial Investigation
Report and Human Health Risk Assessment were released to the
public in May and June of 1993, one year before the release of
the Proposed Plan. The Ecological Risk Assessment and
Supplemental Remedial Investigation Report were released in March
and April, 1994 respectively. The Feasibility Study was released
at the end of May 1994, a full month prior to the $tart of the.
. public comment process.EPA has mad~ every effort to provide the
TAG group with timely and complete information. The seven public
meetings, four facts sheets, ~nd several press releases are
strong ind~cations of the opportunity for public involvement at
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12.
2.
COMMENTS R2GARD::);G THE REMEDIAT. ::-"I1EST7GATION A)JD
FEASIBILITY STUDY
,;
PRP Comments
Comment a: A comment was received sta:ing that RI and SRI
SUDDorts that bedrock around water in:eraction with the east (New
Hampshire) side of the~Connecticut River is unlikely. This is
further supported by large upward gradients in bedrock wells (K-
39 and K-40) near the Connecticut River on the west side.
Response: EPA agrees that the RI and SRI support tr.e discharge
of ground water into the Connecticut River and that bedrock flow
into New Hampshire is unlikely. '
~omment b: A comment was received stating that ground water had
been adequately characterized and that addition field
investigations are not necessary.
Response: The EPA agrees that the current site characterization
was adequate for the completion of the RI/FS and selection of the
remedy. However, further daca collection will be necessary to
track the ground water restoration. In addition, the northern
extent of the bedrock plume must be characterized to provide a
complete delineation of the extent of ground'water contamination.
The Long-Term 'Monitoring Plan will evaluate the need for,
additional studies to confirm the conceptual hydrogeologic model
and track ground water restoration. '
TAG Group and Citizen Comments
Comment a : A local resident requested
moni,toring well in the parking lot sub
wells tO,the sou~h of the landfill due
residences south of the landfill.
the installation of a
base and more monitoring
to' the number of
Response: A monitoring well in the sub base of the parking lot is
not necessary. Several excavations have been performed through
the parking lot which confirm the lack of water moving through
the sub base. In addition, the parking lot contains an
underdrain to remove storm water which would catch any seasonal
flow. There are several wells that monitor ground water quality
south of the landfill. The E cluster of monitoring wells is ne~r
the entrance to' the facility and defines the Southern extent o'f
the plume. In addition, three bedrock water supply wells
directly south of the landfill are sampled twice per year. These
, wells have not detected any contamination. Finally, the bedrock
ground water contours, which show the direction of bedrock ground
water flow, indicate that the bedrock ground water is moving
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'12
pa~king lot.
Comment b: A local resident questioned the lack of water quality
tes~ing in Charlestown, NH.
Response: Discussions with the Town of Charlestown N.H. indicate
tha: residents north of the Charlestown POTW, across the
Con~ecticut Rive~ from the Site are on public water. The
Charlestown water supply is upgradient of the river and is not
hyd~aulically connected to the Site~ Residences immediately
south of the Charlestown POTW have dug wells adjacent to the
Connecticut River which are not connected to the same flow regime
as the Site. In addition, all of the hydrogeologic data for the
Site supports the discharge of bedrock ground ,water to ~he
Connecticut River.
Comment c: A comment was made that the FS does not address the
continued flow at seep 6. '
Response: The.conceptual model for the capping of the landfill
estimates a substantial drop in leachate generation within five
years of the cap construction. This should result in an
elimination of flow at seep 6. In addition, recent observations
of seep 6 in July and August indicate tha~ seep 6 is not flowing,
into the Connecticut, River, but rather the water is lost to
infiltration and evapo-transpiration. This supports the
conclusion in the FS that seep 6 is contributing seasonal flow to
the Connecticut River. Also, it is important to note that
samples taken from the Connecticut River do not support a
continued impact to the River. Seep 6 flows at less than 1 gpm
during the majority of the time. This low level of flow would be
substantially diluted by the Connecticut River, further reducing
the potential for impact. Finally, seep 6 is being addressed as
part of the non-time-critical removal action (NTCRA). Current
NTCRA actions include a design of an extension to the ground
. water trench to collect t,hewater that is discharging 'at seep #6.
Comment d: A comment was made stating that measurable impacts
have occurred in the Connecticut River.
Response: Current sampling data does not support the conclusion
that measurable impacts are occuring in the Connecticut River.
The historical data base does show that levels of certain metals,
including aluminum, iron, and' lead, have been periodically
detected above ambient water quality criteria in samples from the
. Connecticut Rive~. However, there is no data to support that
measurable impacts to the Connecticut River occured during the
time period these samples were obtained. In addition, levels of
aluminum, lead and iron were not detected above fede~al or state
ambient water quality criteria in the Octobe~ 1992, August 1993,
and May 1994 sampling events. The sediment samples ot the areas
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13
long-term loading c: contamination to the Connecticut ~iver from
the Site.
c
Comment e: A comme~~ was provided on the selection of target
cleanup levels for ~he Connecticut River and the defin~~ion of
significant impact ~~ the Connecticut River and landfill related'
impacts.
Response: The SRI d:~a support that significant impacts are not
occurring in the Cc~,ecticut River. There have not been any
exceedances of ambi:~t water quality criteria in the Connecticut
River detected since March 1992. Significant impacts. are those
that have the poten~ial to adversely effect human health or
ecological receptors. Consistent levels of contaminant~ above
reference standards {ambient water quality criteria or sediment
quality criteria} wc~ld be considered a significant impact.
Target cleanup leve:s for the Connecticut River were not
specified because V:rmont water quality standards will be used as
the reference criteria. Using ~hese criteria will assure that
the Connecticut River is adequately protected. Landfill related
impacts are defined as those impacts that are caused by the
release of contamin:~ion from the landfill.
Comment f: A comme~: was made stating that the FS should state
that sampling was o=~en limited, with respect to locations and
analyses run.
Response: EPA consideres the sampling efforts at the Site to be
satisfactory. Whil: not all parameters were sampled during each
sampling event, the list of parameters was focussed on those
compounds that would best track the extent of contamination and
which represented the most significant risk assessment concerns.
The RI and SRI and data tables provide the reader with an
understanding 'of the analyses run.
Comment g: A comment was made that the overburden contaminatio~
extends beyond the edge of. Route 5.
Response: The overburden contamination does currently extend
across Route 5 to the edge of the drainages along Route 5. While
some of this water contains residual contamination from former
seeps and the existi~g flow at seep #6, only seep #6 is currently
observed to discharge this overburden ground water to the ground
surface. Even if tr.e plume is extended across Route 5, the
overburden plume sti:l exists in a very narrow area between the
landfill and the ed~e of the drainages along Route 5. .Data
collected as part of the Long-Term Monitoring Program will
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14
Comment h: A comment was made stating tha: :here is no evidence
that the residences below the landfLII are not usina their wells
or that other ~edrock water supplies h~ve not been ~ontaminated.
ResDonse: Two of the three residential wells east of the landfill
have been observed to be in disrepair by EPA. The condition of
the third well is unknown. EPA will seek to obtain permission
from the property owners to formally abandon the former water
supply wells by grouting. There is a substantial data base to
support that other water supplies have not been contaminated. In
addition, ground water flow contoUrs do not support the movement
of contamination towards residences with current water supplies.
Three water supply wells on the south side of the landfill and
one on the north side of the landfill have been sampled twice per
- year for 10 years. Two of the wells on the south side of the
landfill are active pumping wells in close proximity to the
landfill. These wells have not been impacted. In addition,
several residential water supplies in the area were sampled twice
during the 1'980's and have been sampled twice, in 1993 and 1994,
during the RIfFS. No contamination has been detected in any of
the existing water supply wells in the area of the landfill. The
elevated arsenic levels in one well north of the landfill are not
considered Site related as the monitoring wells on the north side
of. .the landfill do not have elevated arsenic ccmcentrati-ons.
Comment i: A comment was made that the unquantified risks from
dermal contact and inhalation of bedrock ground water should have
been discussed in the FS.
Response: The potential risk from inhalation of vapors from
ground water was qualitatively addressed in the Human Health Risk
Assessment. Risks that were qualitatively discussed in the Human
Health Risk Assessment, such as ambient air, were addressed in
the Remedial Action Objectives. See the Human Health Risk.
Asse~smentresponses for additional response to this comment.
Comment j: A comment was submitted stating that the assump~ion
that bedrock ground water will be used as a water supply is not
conservative as indicated by the FS due to previous use of the
bedrock ground water.
Response: Former residential water use in the area of the
landfill was the basis for selecting this pathway for evaluation
in the Human Health Risk Assessment. The future use.of the
bedrock ground wat-er is considered conservative based upon the
limited potential for a future water supply well being installed
given the availability of a water line. .
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15
Comme~t k: A commer.: was submitted that both unquantified ar.=
quantified risks stculd be discussed in the FS and tha: tota:
risk at a location should be evaluated.
Response: Tte Human Health Risk Assessment is the most
appropriate forum fer discussing unquantified risks. EPA
considers both quan:ified and unquantified risks in developi~g
the Record of Decision. The FS did address unquantified risks as
part of the remedial action objectives. Total risk fo~ the
swimming pathways was presented in the ROD. .
Comment 1: A commer.: was submitted stating that institu~ional .
controls in the:FS.are not adequately characterized.
Response: As stated in the ROD, DSI is implementing institutional
controls on its property to prohibit use of the property in a way
that would be detri~ental to the response actions and to prohibit
use of contaminated ground water. In addition, BFI-VT has aareed
to p~ovide a water supply to owners of the contaminated wells for
twenty years after full and final closure of the solid waste
facility and to convey the system to those owners free at the end
of that period. EPA will evaluate the need for, an if it deems
appropriate, require additional institu~ional controls if these.
prove ineffe~tive ~n preventing the extraction of contaminated
ground water or altering the migration patterns of contaminated
ground water. '
Comment m: A comment was received regarding consideration of
sewage sludge in the FS.
Response: Sewage sludge will not be used at the Site. However,
the EPA Section 503 sewage sludge land application regulations
were designed for the surface application of sewage sludge.
Comment n: A.comment was submitted stating that the ecological
risks should be described in the same manner as the human health
risks.
Response: Ecological risks are not as strictly defined as human
health risks. The actual impact of a concentration in a surface
water sample may represent a potential concern, but estimating
the actual impact is often not possible. Ecological risks a~e
discussed more qualitatively for this reason.
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16
Comme~: 0: A comment was s~bmitted that ~oderate risks were
esti~a:ed in the Eco:ogical Risk Assessme~t (ERA) for the
Connes:icut River sur:ace water. That t~e Connecticut River is
disc~ssed as an after thought on page 82.
"
Respor-se: The protec~ion of the Connectic~t River is one of the
primary objectives 0: the remedial action. EPA established a set
of remedial action objectives, which are presented on page 56 of
the FS, regarding the protection of the Connecticut River. While
modera:e risks were estimated as a results of the evaluation of
the Oc:ober 1991 and March 1992 data, there were no elevated
levels of chemicals and elements in the Connecticut River.
detec~ed in the October 1992, August 1993, and May 1994 sampiing
events. The FS focussed on actions beyond the source control
actions previously iffiplemented or under construction. In
addition, the control of seep 6 is being addressed under the
NTCRA not the FS.
Cornmen: p: A comment was submitted stating that two of the four
justifications for generating cleanup goals only for bedrock are
in error. The comment also questioned why background data was
not used to establish cleanup goals.
Response: The question' regarding background data has been
addressed in other responses. The comment is correct in stating
that all seeps have not been addressed. However, target cleanup
levels were not established by EPA for the Connecticut River
because the Vermont water quality standards will be compared with
the data from surface water results to determine if future
impacts are occurring and the last three rounds of samples from
the Connecticut River do not support a current impact. Following
the completion of the cap the only surface water discharge from
the Site will be snow melt and storm water run-off.
Comment q: A comment was submitted stating that the arsenic found'
in the bedrock results from the landfill.
Response: Chapter 4 of the FS provides a detailed discussion of
the occurrence of arsenic in the bedrock ground water. The FS
concluded the arsenic, while mobilized by the landfill leachate,
is contributed by the naturally occurring arsenic in the bedrock
fractures. This is supported by the low levels of arsenic in the
overburden and the highly variable levels of arsenic across the
Site. The elevation of arsenic in some Site wells as compared to
off-site wells ~lso supports this conclusion. The detection of
arsenic in many wells outside the plume supports the presence of
arsenic in the bedrock. The landfill leachate has caused the
mobilization of this arsenic. Regardless of the source of
arsenic, the remedia: action objective is to restore affected
bedrock ground water to drinking water standard for all compounds
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17
comment r: A co~~en~ was submicted seating that the description
of the screening 0: :echnologies was limited.
Response: Table 3-3 of the FS provides the basis for che
screening of tect~ologies. This table provides a comprehensive
evaluation of all the technologies evaluating in the screening.
The limited number 0: alternatives developed at the Site was
based upon the li~ited options available to address bedrock
ground water contamination and the actions included in the NTCRA.
Comment s: A com~ent was submitted stating that monitoring of the
Connecticut River is not listed in the bullets on page 86 for SC-
2. The comment also noted that not addressing the ground wat~r
objectives is not a'parenthetical issue and that alternative SC-2
did not address seep 6. '
Response: Alternative SC-2 did not include surface water
sampling. However, sampling of the Connecticut River will be
included in the Long-term Monitoring Program under the selected
remedy. Not addressing ground water objectives was listed as a
parenthetical because source control actions directly addressed
the other remedial action objectives but only indirectly
. addressed the ground water objectives. However, ground water
remedial action objectives are very important components of the,
source control action and should not be considered less. important
, by the' use of the parenthetical. . Seep 6 is being addressed under
the NTCRA.
Comment t: A comment was submitted stating that under MOM-1
institutional controls for the BFI property are not the same as'
institutional controls for the entire Site. Also, this
alternative did not include surface water and sediment sampling'.
Response: It is appropriate that institutional controls be
different for the BFI property and other properties given the
differing r~sponse objectives ,for those ,properties.' The ROD
clearly makes this distinction. Surface water and sediment
sampling is included in Table 3 of Appendix E of the FS .which
discusses the monitoring program and costing for each alternative
in detail.
Comment u: A comment was submitted requesting clarification
regarding the applicability of the study by Matisoff and
Associates (1982).
. Response~ . The Macisoff study was an eval~ation of the occurrence
of arsenic in the drinking water of a residential area of Ohio.
The relevant aspects of the study were the support of the
relationship between elevated arsenic concentrations and reducing
conditions in a natural system with no outside source of arsenic.
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18
Com~e~t V: A comme~t was s~bmitted sta~ing tha: Secti~n 5.1.2
failed to indicate that alternative SW-1, No F~rther Action, does
not ~eet the baseline assuiliDtion in the HHRA a~d ERA that the
land=ill will be capped and~the cap mai~tained.
"
Respcnse: The comment is correct. SW-1 could not be selected as
the remedial action based upon the HHRA and ERF.. The EPA.
Guidance: Conducting Remedial Investigation/Feasibility Studies
for CERCLA Municipal Landfill Sites and the Presumptive Remedy
for ~unicipal Landfill Sites allow the HHRA and ERA to be
streamlined. The streamlining of these documents based upon the
presumption that the landfill will be capped results in an
insufficient data base to select a No Action alternative.- .
Therefore, a more detailed HHRA would be required before SW-l
could be selected. A statement was included in the HERA that it
would not support a complete no action decision for the Site.
Comment w: A comment was submitted questioning whether it would
be feasible to treat the collected ground water and leachate in
addition to the bedrock ground water. The combination of the
treatment of the overburden ground water and leachate witn the
treatment of the bedrock ground water could make SW-3 more cost
effective,
Response: The cost savings by.treating the collected leachate and
overburden ground water on-site would reduce the cost of SW-3.
However, SW-3 would still be significantly more expensive than
SW-2. While there is a benefit of eliminating the need to
transport the collected leachate and overburden ground water off-
site, the technical concerns regarding the ability to
successfully implement SW-3 must also be considered. Also, SW-3
does not achieve ground water restoration in a time period
significantly different from SW-2. In addition, the negotiation,
design, construction, and start-up testing for ~he ground water
extraction system would require 3~5 years. By the time the pump
and treat system was ready to treat the collected leachate and
ground water the cleanup model predicts that the water levels in
these systems will have decrease significantly. This decrease in
volume will decrease the costs savings of treating this water on-
site. The costs for transporting and disposing the water during
the 3-5 year period would still be incurred even if alternative
SW-3 had been selected.
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:9
Co~ment x: A comme~~ was s~bmit:ed sta~ing
clearly state. that SW-3 ~~7olves :reac~ent
water and SW-2 does not. In addi~ion, the
additional clarification ef the short term
that the FS does not
of the bedrock ground
comment requested
impacts of SW-3.
o
ResDonse: The comme~t is correct in stating that SW-2 does not
involve treatment of the bedrock ground water. However, the
natural discharge of bedrock gro~nd water under alternative SW-2
does not impact the Connecticut River. In addition, discharge of
the nonhazardous water to an off-site facility is considered
treatment. The ROD clear~y identifies SW-3 as providing
treatment of the bedrock ground water.
The 'short term human impacts under SW-3 are minimal and could be
successfully prevented using good construction practices and
proper industrial hygiene. The habitat impacts under SW-3
referred to the dis~urbance caused by clearing and grubbing
woodland for space for the treatment plant. The retention pond
washout in June 1994 did not adversely impact habitat.
Comment y: A comment was made questioning what would happen after
thirty years and hew will the decision be made to stop
remediation. . The comment. also stated that the 24 point-of~
compliance wells should be sampled until compliance is reached.
Additionally the comment questioned how long-term monitoring data.
will be evaluated to insure that remediation is being achieved.
How will new constituents be monitored?
Response: The selected remedy requires the cap be continuously
maintained to sustain the protection achieved, even beyond the
thirty years used to cost the alternatives. . The ground water
collection trench and leachate collection system will be sampled
and mainta1ned until they are dry. The gas management system
will be operated and maintained as long as the cap, unless a
determination is made to EPA andVTDEC that the system can be
shut down without impact to public health or the environment.
Sampling of the point of compliance wells will occur until. the
ground water has been at or below cleanup levels for three.
consecutive years. Long-term monitoring data will be observed to
check trends in ground water flow and concentration levels.
Periodic reports will be produced to compare expected values with
actual levels. Additional parameters, SVOC and pesticides, will
periodically be included in the sampling program to check the
levels of these constituents. The landfill ~s currently
considered anaerobic. The Long-Term Monitoring Program is not
expected to identify any new constituents. However, the data
will be reviewed to check for changes in the occurrence and
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20
Comme~t z: A com~:~t was submitted sta:ing t~a: add~:ional data
mus: be collected :0 evaluate the effective~ess of t~e cap and
thac the FS does ~~t demonstrate that capping will adequately
prevent exposure ty off-site receptors to Site-related
contaminants.
ResDense: EPA bel~eves that sufficient data was Drese~ted in the
RI,.SRI, and FS to determine that the cap and other existing
controls should be capable of the restoration of bedrock ground
water. However, the collection of Long~Term Monitoring data to
confirm this hypothesis is critical. If the Long-Term Monitoring
data qoes not sup;ort,the hypothesis regarding the ground water
restoration, then .further actions need'to be evaluated. EPA
considers all off-site exposure pathways to be satisfactorily
addressed by the selected remedy. '
Comment aa. A com~ent was submitted stating that the cap planned
and work associated with the CAP, due to its close proximity to
Route 5, could im;act Route 5. As recently demonstrated by a
retention pond failure, it is essential that all regulations
regarding work at or around public roadways be considered. The
comrne!lt recommended that ARAR's other than "e~vironmental" ARAR's
be included ~n'the Feasibility Study (FSI. Local, state, and', ,
,federal regulatior..s should be considered. Also, as the CAP'
material is from effsite sources and will need to be transported
onsite (as well as, leachate being trucked offsite) regulations
promulgated by the United States Department of Transportation
should be included under the Operation and Maintenance section of,
table 5 "ARAR"S for Compliance".
Response: Every effort is being made as part of the en-going
activities at the Site to minimize the impact of the construction
and the long-term action on Route 5 and local reside!lts. EPA,
VTDEC, VTAOT, and the PRPs contractor, Dames and Moore, have been
,working' coope~ativelyto design 'a drainage system that will not
adversely impact Route 5 or the residences along Riverfront Road.
The contractor performing work at the Site is responsible for
complying with all applicable regulations, including VTAOT and
USDOT. This also applies to the transportation of material to
and from the Site. It is not the purpose or intent of the FS to
provide a detailed listing of all local, state, and federal
regulations that apply to an activity. The contractor is
expected to be knowledgeable of local and state construction
requirements. In addition, EPA, and the State review the project
to ensure compliance. ARARs, by definition, are federal or state
environmental or facility siting laws that are applicable or
relevant and appropriate under the circumsta!lces at the site.
ARARs apply to the on-site aspect of a remedial action. Any off-
site action must comply with all existing federal, state, and
local regulations. On-site actions must be performed in a manner
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21
.)
and local regulatio~s tha~ are not incl~ded in the definition of
ARARs. . A permit is =-.ot required for ar.y activity performed
entirely on-site as =efir-ed by the National :Continge~cy Plan.
While the Site acti'l~ties have caused excess run-off onto the
road during a few s:~rm events, several of the Site actions,
particularly the grc~nd water trench, have improved the stability
of the road.
Comment ab. A comme~t was submitted questioning whether the cost
estimate presented i~ Table 5-4 for site wide alternative SW-2
under "Operation anc. Maintenance, Landfill Leachate Collection
System" was updated :0 include changes due to an alternative
disposal site being.required? How do these changes, if any,
effect the present .werth cost using a 7% discount rate before
taxes and after inf~ation?
Response: The non-r.azardous waste water is currently being
shipped to a commerc~al industrial waste facility.. This shipment
will likely continue until another POTW has been determined to be
. acceptable for rece~;t of the waste water. The cost of the
industrial facility does increase the cost of SW-2. However,
both SW-2 and SW-3 would be'equally effected for the first three
years when the costs are highest. Thereafter, the costs will be
less due to a reduced volume. The cost of using an industrial
waste ~acility doubles the trea~ment'cost under SW-2 adding.
approximately $70,000 per year in cost. This would not be a
significant change to the cost estimate.
Comment ac. A comme~t was made stating that the leachate
collection trench will likely be expanded due to continued
discharges at seep 6, the costs for this additional work should
be included in all t~e appropriate cost estimates.
Response: The control of seep #6 is being performed as part of
the non-time-critical removal action at the Site. 'These costs
. are independent from the costs of the alternatives evaluated in
the FS and should no: be included. However, there will be an
additional costs due to the increase in flow to the ground water
collection trench.
Comment ad. A comme:1t was made stating that "Site Chronology,
Disposal Specialists, Inc. Feasibility Study, Rockingham,
Vermont, Table 1-1" doe not present any "Site Related Activities"
other than the January 1992 entry "Supplemental Remedial
Investigation ~eport to the .EPA" in 1994. As the Feasibility
. Study is signed and dated May 27, 1994, the F.S. should include
all activities, incl~de onsite meetings, sampling related to cap
material alternatives, all sampling events, the Palmer Plant
issues, and public ~eetings, both formal and informal.
- Additionally, no where in the chronology is the issue of
exploring and sampli~g al:ernative cap materials presented.
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22
all citize~s and i~~eres::d parties.
Res~8nse: A detai:ed ch~8~010gy of Site activities is attached
to che ROD and a de~ailed chronology of community re:ations
activities is attached to the responsiveness summary.
Com~ent ae. A comffient was made that alternatives SW-2 and SW-3
presented should have considered incorporating aspec:s of both
SW-3 and SW-2. Fc~ instance, should the landfill caD fail to
eliminate overburden groundwater flow under the cap,-then
consideration should be given to pumping "clean" groundwater from
stra~egically placed wells immediately upgradient of the landfill
foo:print. The technical feasibility as well as an estimate of
. costs should be presented in all appropriate sections of the
feasibility study.
Res~onse: Upgradie~t pumping wells were eliminated from
consideration due to the limited effectiveness of pumping the
fractured bedrock in the past. However, if the actions
implemented as par: of the NTCRA and ROD do not achieve ground
restoration, then additional actions will be considered. The
additional ~nv~stigations and cor~esponding decision is outside
the scope of this action.
. .
Comment af. Several comments were made that questioned the
identification of the extent of bedrock ground water
contamination due to the detection of low levels of VOCs in the
new K cluster.
Response: The detection of low levelVOCs in the K well cluster
in the north east section of the Site indicates that the VOC
portion of the plume may extend north of the current delineation.
However, the natural gradients in the area would do not support
contamination extending much further north. Additional
monitoring wells will be installed as part of the long-term
.monitoring program to define the nor~h east extent of the plume.
It should be noted that only very low concentrations of VOCs were
detected at the K cluster. The arsenic and manganese
concentrations were much lower at the K cluster than other wells
in the plume. The arsenic concentrations were well below the
cleanup standard and the MCL. The manganese level was higher
than the cleanup level, but it was not significantly different
from the level detected in some background wells (e.g. interceptor
well) .
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23
Ce~ment ago Several cs~ments reques~:i further in=~rmation
and/or modeling to sup~~rt that disct;rge to theCc~necticut
Rb-er by the ground wa::r does not ha't: any impact en the river.
In addition, further sa~pling 0: sedi~ents along a cross-section,
of the river was recorn~ended.
"
Response: First, sa~~ling of the Co~~ecticut River sediments
and surface water do net indicate a s~gnificant impact from
ground water contamination. (also see response to comments c and
d) The limited areas 0: elevated iron levels in the river were a
result of surface water discharge fro~ seeps along Route 5. Two
of the three seeos have been eliminat:d and the third seeD will
be controlled as- part ef the NTCRA. Second" the voluT'[Ie of ground
water flow 'from the bedrock to the Con~ecticut River is very
small in comparison to the overall flew in the river. Section
5.3 of the RI included a calculation of the total flow of
contaminated water fro~the Site to tte Connecticut River and the
potential resulting maximum contaminan: levels in the river.
Based upon Si.te data a:-.d calculations presented in Appendix B of
the FS, the range of bedrock flow fro~ the Site drainage area
into the Connecticut River is between. 08 cfs and 6 cfs. . Based
upon data from the RI, che average flew in tbe Connecticut River
is 9330 ~fs and the 7QIO mean low flow rate calculated for the,
river is 993 cfs. ,The '7Q10 mean low flow rate is a staridard,
calculation used in surface water hydrology and water resource
planning to provide an estimate of the lowest flow levels that
can conservatively be expected over time. Using the average flow
rate of the Connecticut River, the ratio of bedrock ground water
flow to the total Connecticut River flow ranges from 1:1,555 to
1:116,625. Use of the 7Q10 low flow rate results in a ratio
ranging from 1:166 to 1:12,412. Use of either the average flow
or the 7QIO mean low flow values in a calculation of the maximum
concentration of contaminants in the river resulting from
discharge of bedrock ground water to the river. indicates that,
such concentrations would be substantially below federal and
state drinking water and surface water standards. Cross-sectional
sampling of the Connecticut River will be evaluated as part of
the long-term monitoring program. However, given the very low
levels predicted by the dilution factor, the value of this
sampling is uncertain. The majority of the bedrock recharge to
the Connecticut River is likely occurring in the area adjacent to
the Site where the bedrock is in close proximity to the river.
The depth of overburden increases substantially across the river.
This decreases the potential for discrete break-out areas in the'
river. '
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24
Comme::.:: ah:
for c2.eanup. '
COffi~e~ts were made regarding the 13 year estimate
Respo::.se: The 15 yea~ time frame for ground water clea~~D is
descri~ed in Section 4 of the FS. The time frame was ~as~d upon
the ti~e requi~ed to d~ain the unsaturated waste to field
capaci::y following capping (approx. 50 days), the time required
to drain the saturated waste to a level resulting in 98~
reduction of the former leachate contribution to bedrock (14
years), and the additional time required to flush the bedrock (1
year). The monitoring wells used for the estimation are listed
in table 4-7 of t::.e FS. All wells outside the Waste Ma~acrement
, Unit, which is defined as the edge of the landfill, are e~pected
to meet the cleanup levels within this time period. In addition,
a substantial reduction in concentrations, approaching 90%, is
expected within 5 years of the completion of the landfill cap.
Comment ai: A comment was received requesting information
regarding the predicted and actual trench flow.
Response: The predicted trench flow was 2 gpm and the actual
flow varies from 1.8 to 3 gpm. An increase in trench flqw was
observed early this year due to the reduction in vegetation over
the landfill following the regrading project in 1993. Section
3.5.2 of the Remedial Investigation Report presents the initial
flow estimates for the overburden ground water.
Comment aj: A comments was made regarding the recharge of
overburden by bedrock and the potential for an exposure pathway.
Response: In areas with an upward gradient, the bedrock may
discharge into the overburden. The potential for an overburden
pathway is small due to the limited area of potential recharge of
overburden from contaminated bedrock ground water, the limited
potential for access or use of this overburden ground water, and
the relatively low levels of contaminants. Several factors'
influence the extent to which the overburden, whether recharged
,by the bedrock or 'the landfill leachate, is an exposure pathway.
The overburden is made of fine silts, sand, and clay and has a
very low permeability. In areas where the overburden contains
ground water, the yield is very low. The overburden ground water
that is highly contaminated exists in an area adjacent to the
Site between the landfill and the slopes of the ravines along
Route s. This aiea has a very steep topography an is unsuitable
for development of a residence or a water supply. The overburden
ground water is of limited extent as indicated by the lack of
overburden ground water in piezometers P-l, P-2, MW-l, and MW-2.
In addition, two borings along Route 5 did not encounter
overburden ground water until the bedrock interface. The new K
well cluster did not detect a zone of saturated soil in the
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25
J
de'lelopment was re~ha~ged by the bedrock, t~ere would not be an
exposu~e pathway d~e to the low yield of t~: ove~bu~den and the
availability of bed~ock as a wate~ su~ply. Finally, neither the
bed~ock nor the ov:~bu~den contain levels or VOCs that could
reoresent a indoor ai~ concern in the areas suitable for
development. The VOC levels in the g~ound water in this area are
in the low parts per billion range.
Comment ak: A comment was made requesting an increase in the
sampling frequency of immediately downgradient wells and the
trench to detect the possible increase in contaminant levels due
to a reduced dilution factor. .
Response: EPA ag~ees that an increased frequency' of monitoring
may be necessary for the trench and leachate tank as the dilution
factpr is reduced. However, the need to sample othe~ wells more
frequently is less obvious. This comment will be considered
during the development of the Long-Term Monitoring Program.
Comment al: A comment was made stating that a trail tha~ starts
approximately 1/2 mile south of the landfill and travel around
the site, exiting on Rt. 5 just north of the sit~, be included in
all maps for the site.
.Response: EPA is not aware of such a trail. . Areal photographs 'of
the Site from 1963 to 1990 do not show the trail nor was the
trail located in various EPA inspections of the area west of the
landfill. However, if VPIREF will provide more information.
regarding the location of the trail, EPA will inspect the trail
and consider the need to include the trail in future Site maps.
Comment am: A comment was made stating that sufficient
information does not exists to confirm the discharge of Site
contamination to the Connecticut River and that continued impact
to the Connecticut River is unacceptable. .
Response.: The RI, SRI, and FS all provide hydrogeologic data
support the conceptual model for the Site. Further information
will be collected as part of the Long-Term Monitoring Program.
The data and eval~ations performed as part of the RI/FS support
that no impact to the Connecticut River will occur under the
selected alternative. EPA believes that sufficient information
was presented in the administrative record to support the
selected remedy.
Comment an: A comment was submitted stating that upgradient
diversion should be evaluated in more detail.
Response: Upgradient diversion was attempted in the early
eighties and found to be unsuccessful. Upg~adient diversion in
bedrock can be very expensive and difficult to implement. The
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'26
successfully remediated ~~der the existing controls a~dna:~ral
restoration. If ~he se:ec: remedial action does not achie7e the
restoration of grcund water, then further studies would be
implemented to de:ermi~e the best mechanism for meeti~g tte
cleanup levels.
"
Comment ao: A comment was submitted stating that the Site's
impact on the stabili~y of Route 5 needs to be studied and that
VT AOT ARARs should ~e researched.
Response: AOT regula~io~s are not ARARs. They are applicable
state standards that app:y to any Site activity covered by the
AOT regulations. The co~~ractor working at the Si~e is re~~ired
to comply with AOT regulations. The stability of Route 5 tas
been consistently evaluated throughout the RI/FS and NTCRA. One
;reason for the installation of t,he ground water trench was to
stabilize Route 5 by red~cing pore pressure. Forty foot sheet
piles were left in the overburden to provide additional
stabilization. The design of the NTCRA has also included an
evaluation of ~oute 5., :he decrease in overburden ground water
resulting from the cap will stabilize Route 5 and a new drainage
culvert to handle flow from 'the landfill will also improve Route
5. However, Route 5 was built in an unstable formation and the
existing u~derdrain and,storm drain systems are' corroding.
'Unless the storm drain .system is repaired, continued
deterioration of the road will occur.
Comment ap: A comment was submitted stating that the residences
along the river be referred to a "homes" as opposed to "car::ps".
Response: This change will be made in future documents.
Comment aq: A comment was submitted stating that pump and treat
options for the overburden ground water and/or extending the
existing trench along Route 5 should have been considered as part
,of the proposed remedy. ,'",
Response: Pump and treat options were not developed for the
overburden ground water for several reasons. The control of the
seeps along Route 5 was a NTCRA objective and this issue is being
addressed as part of the current construction program. The
leachate levels in the overburden ground water will be
effectively reduced by the cap. The overburden ground water was
not considered a realistic exposure pathway due to the limited
extent of the contamination and steep slopes. The permeability
of the overburden groundwater would make pump and treat'
impractical. The Route 5 trench is being extended as part of the
NTCRA. Further measures to control seep # 6 will be evaluated as
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27
()
3.1 COffiments Re~ardinc the Human he~lth Ris~ Assessment
PRP Comments:
~
Comment a: A ccmment was submitted stating the EPA human health
risk assessment was overly conservative. A human health risk
assessment was indepe~dently prepared and submitted as a comment.
This risk assessment does not consider the ingestion of bedrock
ground water as a pathway. The risk assessment did evaluate and
present similar conclusions to the other pathways evaluated in.
the EPA risk assessme~t.
Resp6nse: EPA beli~vesthat the EPA human health risk assessme~t
provides a reasonable assessment of the potential for future
human health risk at the Site in the absence of any action except
capping. With respect to the risk assessment submitted as a
comment, EPA does not agree with the elimination of the bedrock
ground water.ingestion pathway. EPA considers potential future
use of bedrock ground water to be. a historically documented and
likely future pathway. The failure to include the ground water
ingestion pathway limits the usefulness of the document. EPA has
not reviewed this document in detail at this time.
~AG Group and Citizen Comme~ts:
Comment a: A comment was made stating that Figure 1-1 does not
accurately reflect the Site arBa and that the HHRA does not
reference the presence of residences with the Site.
Response: "The exposure assessment section of the HHRA (Section.
4) identifies the potentially exposed receptors and evaluates the
corresponding exposure pathways. The text in this section
includes the identification of all nearby receptors. In addition,
all figures in the HHRA identify residences near the site except.
Figure 1-1. The.goal of Figure1~1 is to provide a perspective of
the site's location within the State of Vermont."
Comment b: A comment was made stating that well B13D should be
the middle of the plume, not the northeast edge.
Response: Section 3.4.4.1 of the RI provides a detailed
explanation of the extent of overburden ground water. Well B13D
is at the northeast corner of the southeast moving plume as
. indicated by the lack of overburden ground water in. wells MW-l,
. MW-2, boring MW-S, the boring for MW-8, the boring for MW-A11,
and piezometers 1 and 2. All of these data points support the
current delineation of the overburden plume.
Comment c: A comment was made stating that the HHRA did not
accurately present the bedrock plume. The HHRA stated that the
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28
comment further stated that the 1979 sampling confirmed the
presence' of VOC and elevated metals beneath these residences.
Response: The 1979 sampli~g confirmed contamination in the
Lester/Danforth well south of the current residents. No VOCs or
elevated metals were detected in the area of the current '
residences. The water line was extended to this area as a
protective measure based upon the contamination at the
Lester/Danforth well. The VOC and manganese plume in bedrock has
increased since the HHRA. This expansion, however, would not
change the outcome of the HHRA since maximum contaminant
concentrations in t~e entire plume are already incorporated into
the risk calculations. The outcome considering this new.
information, remains the same, that is that an unacceptable human
health risk would result from a lifetime ingestion of bedrock
groundwater in the area of the plume.
Comment d: A comment was made stating that only unfiltered
samples should be used in the HHRA and that the use of filtered
samples should have been more specifically mentioned in the HHRA.
Response: EPA typically seeks to use unfiltered samples ~o assess
risk to public health from ingestion of groundwater. Samples
collected by this method typically produce data which are the
most representative or a resident's exposure to groundwater. The
groundwater sampling at this site occurred prior to EPA's
involvement and consisted of 'filtering the samples in the field
prior to laboratory analysis. Near the completion of the HHRA,
(October, 1992), EPA required that both filtered and unfiltered
groundwater samples be collected from all monitoring wells to
determine whether filtered data collected previously and during
the same round would produce comparable results as unfiltered
data. Both filt~~ed and unfiltered rounds were found to have.
comparable results for all compounds detected. A slight increase
in arsenic occurred in both filtered and unfiltered samples
collected in October, 1992, but concentrations between both
samples were similar and the .filtered sample contained the
highest arsenic concentration. Thus the use of filtered data at
this site was considered appropriate for estimating exposure to
groundwater. In addition, the use of filtered data allowed for
the preparation of the risk assessment much sooner than would
have occurred if EPA had waited for the unfiltered data. This
provided the public with a basic presentation of the distribution
of risk and the major contaminants of concern early in the
process.
J
All groundwater data collected since October, 1992 has consisted
of unfiltered samples. Compliance with cleanup levels will be
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29
"
Comment e:'A Gomment
included as a COC in
stated that NH ARARs
River.
was made stating that lead should have been
Connecticut River Surface. The comment also
should have been used for the Connecticut
Response: Lead was excluded as a COC in Connecticut surface water
because it was only detected once out of six times sampled and
was well below levels of concern for the potential human health
pathway. While the Connecticut River is within New Hampshire,
Vermont provides the permit review and enforcement of discharges
which originate in Vermont. New Hampshire ARARs are addressed
through the Vermont 'review process. ,New Hampshire surface"
quality standards and classifications are included in the ROD.
Comment f: A comment was made stating that household vapors were
quantified in the HH~ Report as indicated. The comment also
stated that doubling the risk would not be appropriate if the
toxicity factors for inhalation and ingestion were equivalent.
The comment questioned whether just VOCs or other COCs were
evaluated for. inhalation.
Response: In 1991, the Risk Assessment Forum issued a memo
entitled "Guidance on Est:imating Exposure to VOCs during, .
. Showering. ,,' Based on the results of a colloquium sponsored by
the Forum and a review of literature by the Forum Exposure
Oversight Group, it was concluded that exposure to VOCs in tap
water during showering was approximately equivalent to the
exposure from ingestion of 2L/day of the same water. It follows
that if the systemic dose is the same, then the total dose and
risk could be estimated by multiplying the oral dose from
ingestion by two. This method contains a fair amount of
uncertainty and does not evaluate portal of entry effects,
however, . given the lack, of a validated showering model at this
time,. this approach. provides a reasonably conservative way of
considering additional exposures from inhalation of VOCs.
Comment g:A comment was made stating that both basement vapors
and household vapors from potable water use should have been
evaluated as pathways. The comment also indicated that
additional pathways for consideration should include: ingestion
of game, inhalation of trench vapors, inhalation of basement
vapors and dermal contact with basement seeps, ingestion of
irrigated plants. The comment also suggested changing the titles
of "ingestion of vapors" to "inhalation of outdoor vapo~s" and
"ingestion of soil" to "ingestion of soil/sediment" and "dermal
contact with soil" to "dermal contact with soil/sediment".
Response: EPA concluded that basement vapor were not a potential
exposure pathway. Although the bedrock plume does extend beneath
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30
parts per billion 0= TCE as the highest level). These levels
would not represent a pote~:ial vapor threat. In addition, there
is no evidence of contaminated overburden grdund water beneath
the residences. Bedrock outcrops are present in the yard for one
of the residences a~d the =asement of a second home is reported
to have been built on bedrsck. The lack of overburden ground
water north of MW-8 also s~pports this conclusion. Further
evaluations of the potential for overburden ground water in the
area of the residents will be performed as part of the Long-Term
Monitoring Program. Household vapors were considered in the ris~
assessment from a qualitative perspective. Page 6 of Section 5
presents the assumption that household vapors from the use of
contaminated water. could double the ground water ingestion risk
for VOCs. The ingestion 0: game was not considered a viable.
exposure pathway due to the lack of occurrence and concentrations.
of contaminants that could bioaccumulate at the Site. The
inhalation of trench vapors was a very low frequency exposure.
Only Site workers would be exposed to these vapors. The health
and safety plan for trench sampling will consider this issue.
Ingestion of plants was not considered a complete exposure
pathway as the former water supply wells are not in use and
contaminants in ground water are unlikely to bioaccumulate in
vegetables typically grown in backyard gardens due to their
physical .and chemical properties and low levels in ground water
at. the Site. The changes in 1;:itles sugges'tect were' considered i,n
describing the' risks' in the ROD.
"
Comment h: A comment was made stating that the household vapor
from overburden pathway was not properly evaluated. The comment
stated that data from the Site, including well B-13D, the
landfill gas screening data, high levels of contamination in the
bedrock monitoring wells in the northeast section of the landfill
and the inadequacy of monitoring wells MW-l, MW-2, and MW-8.
Response: MW-l, MW-2, MW-8, and the boring for MW-5(nextto MW-
6), which wa$ nO.t.installed due to' a lack of ov~rburden ground
water, have not been sampled due to a lack of overburden ground
water at these locations. These wells are adequate evaluations
of the state of overburden ground water. Landfill gas levels in
the northeast corner were much lower than on the west side of the
landfill. In addition, the HNu readings were less than 1 ppm,
indicating the presence of methane. The monitoring wells in the
northeast corner of the landfill include wells All and A12. Well
K39 and K40 are along the road northeast of the landfill and
wells 'J3? and J38 are along the Riverfront Road adjac~nt to the
residents. None of these wells detected high levels of VOCs.
Even if the bedrock were to recharge the overburden seasonally,
levels of contamination. detected in the bedrock would not
represent a vapor concern.
Comment i: A comment was
rr:ade
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31
...::,.
not include all the data used in the HHRA and this additional
data sr.culd be included i? the report.
Response: Data used in the HHRA is presented in Ta~les 2-1
through 2-14 in Section 2. No additional data was ~sed to
calculate exposure point concentrations for each media. This is
stated in the text on page 31 of Section 2, " All statistical
summary information is based on Round 1 and Round 2 data produced
by Balsam Environmental Consultants, and was compiled in the same
way for all media. All of the data collected and reported for
the detected analytes in each exposure zone were used in
determining spatial and temporal averages, and maxi~a." And
later, on page 9 of Section 4, "The average and maximum exposure
point concentrations as well as their method of calculation are
'presented in Section 2 of this report." '
Comment j: A comment was made stating that the HHRA should show
the trench and that the FS does not demonstrate that the trench
collects the majority of the overburden ground water.
Response: Figures in the FS and ROD show the location of the
trench. Based upon the correlation between estimated trench
(2 gpm) and actual (1.5 - 3 gpm) and the lack of overburden
ground wa~er north of B13~D, the trench is assumed to be
collec~ing the majority of the c~ntaminated overburden ground
water.' ,
flow
Comment k: A comment was made stating that the toxicological
profiles are not understandable to the lay reader.
Response: The toxicological profiles contained in Section 2
represent a summary of all the information contained in the
toxicological database for each chemical and are directed toward
the lay reader. Some of'this information may have been too
technical in nature. EPA also attempts to address' specific
concerns about chemicals in fact s~eets and in public meetings.
Comment 1: A comment was made stating that the risks from
inhalation and dermal contact with ground water should be
discussed. In addition, exposure to seep water should be
combined with seep sediments and surface water and sediment
exposure at the drainage pond should be combined.
"
Response: The ROD presents the risk due to exposure to the
drainage pond as a combined surface water and sediment risk.
Inhalation and dermal contact with potable water are not included
in the quantitative risk estimates due to the uncertainty in
assessing this pathway (see comment f above). EPA policy is to
discuss these risks in the text or uncertainty section. Exposure
to seep surface water was not estimated due to the fact that
there is not enough surface water present in the seeps to result
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identified at the site only one remains.
Comment m: A comment was made stating that the overburden ground
water fate and transport was not accurately presented:
Response: As stated in previous comments, EPA believes the RI/FS
to provides a sufficient characterization of the overburden
ground water to support the selected remedy.
Comment n: A comment was made questioning whether the exceedance
of AWQC for iron and nickel referred to. the acute and chronic
criteria or the human health criteria.
Response: The exceedance was based upon the acute and. chronic
criteria for aquatic life, not the human health criteria.
Comment 0: A comment was made questioning the lack of established
background concentrations.
Response: A conservative approach used at many sites is to assume
all compounds and elements detected at the Site to be Site-
related. If a compound identified as a cac appears to be at
background concentrations, then a more complete background
assessment is performed. At this Site, no 'compounds were
.eliminated from consideration based upo.n background levels',
therefore, there was not a need to establish statistically based
background levels.
Comment p: A comment was made questioning why iron was eliminateq"
as a cac when it exceeded Vermont ground water standards.
Response: Iron levels in ground water only exceeded the Vermont
secondary standards. The Vermont secondary standard are not
health based standards. Therefore, the Vermont secondary
standards were not used for establishing COCs and iron was
eliminated as ,a COCo . .
Comment q: A comment was made identifying that the acroaym CAS
was not defined.
Response: CAS is Chemical Abstract Service Registry Number and it
should have been defined. CAS will be defined in future
references.
Comment r: A comment was made that the text and figures report
. different facts for the number of permanent residents below the
landfill.
Response: At this time there are two of the four homes are
permanent residents, one is a rental property, and the fourth is
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33
Comment s: A comment was made stating that dermal ex;osure would
represent an additional exposure and that could be s~gnificant.
Response: EPA does not currently estimate the risk :~om dermal
exposure to potable water because this pathway is expected to be,
a minor sou~ce of exposure relative to the ingestior- route. The
risk based upon ingestion and inhalation of VOCs in aroundwater
greatly exceeds EPA's target risk range and conseque;tially
contamination in bedrock groundwater will be addressed as part
of the remedy.
Comment t: A comment was made stating that the HHRA did not
consider the gas from the gas extraction unit.
Response: The gas extraction unit treats the landfill vapors by
burning the gas at 1600 degrees. The landfill gas flare was
performance tested by BFI and subsequently approved by the State
of Vermont. Landfill gas in the area of the flare will be
evaluated as part of the NTCRA.
Comment u: A comment was made questioning why the de~al exposure
to the drainage pond and Connecticut River were evaluated
together:
..Respon,se: . The combination of the dermal pathways for the
Connecticut River and drainage pond is an error. If dermal risk
to the Connecticut River and drainage pond is calculated
separately the cancer risks are 3E-08 and 6E-08, respectively
based on the RME scenario. The hazard index for the RME for the
Connecticut River and drainage pond would be 6E-04 and SE-02,
respectively. Both cancer and noncancer estimates are well below
EPA's target risk range and the conclusions based upon the HHRA
concerning surface water remain u~changed.
Comment v: A comment was made questioning the meaning of the word
"threshold levels" on page 26 of Section S.
Response: The threshold levels were considered the 10-4 - 10-6
target risk range.
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Comment x: A comment was made suggesting that "the same chronic
oral reference dose" should ce substituted for "identical
. toxicity" .
Response: EPA will consider making this change in future risk
presentations.
3.2
Comments Recrardincr the Ecoloqical Risk Assessment
Comment a: A comment was made questioning the selection of the.
background location used for the Ecological Risk Assessment. The
comment also questioned the statement that no significant impacts
to the Connecticut River were observed.
Response: The background sample used in the Ecological Risk
Assessment has been replaced by a new location. However, there
is no change in the conclusion that no significant impact is
occurring. No samples collected since October 1992 show an
impact to the Connecticut River. In addition, the elimination of
two seeps and the control of seep 6 will eliminate the potential
for future impact to the Connecticut River.
Comment b: ~ COmment was.made stating that the elevated levels of
phosphorl,ls should have. been evaluated. in the Ecological Risk.
Assessment. .
Response: CERCLA only authorizes EPA to address releases of
hazardous substances into the environment. The release of
phosphorous into the environment does not fall under the CERCLA
authority. However, the elimination of two seeps and the control
of seep 6 will also eliminate the phosphorous loading to the
Connecticut River.
Comment c: A comment was made stating that the Connecticut River
.is entirely within New Hampshire and. that New Hampshire.standards
should be used.
Response: As stated by a previous comment, Vermont is the
permitting authority for discharges from the Vermont side of the
river.
Comment d: A comment was made stating that the Hazard Indices
indicate moderate risk and that the risk should not be minimized.
,).
Response: The risks to the Connecticut River were not minimized.
The data collected at the Site and presented in the RI/FS do not
support a significant risk or impact to the 'Connecticut River.
In particular, the sediment evaluation did not support an adverse.
impact. The designation of the significance of the impact is due
to an evaluation of the consistency of the impact and an
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the background location used in the Ecological Risk Assessment
did nc~ detect levels of compounds or elements significantly
above ambient water quality criteria:
Comme~t e: A comment was made stating that the Ecological Risk
Assess~ent did not evaluate receptors, it only provided a
compa~ison of reference criteria and concentrations detected.
Respo~se: The comment is correct. The Ecological Risk Assessment
perfo~ed an evaluation of the detected concentrations with
refe~ence criteria. 'Based upon the resu~ts of this evaluation, .
the data collected since October 1992, and the elimination of two
seeps, it was determined that a receptor based Ecological Risk
Assessment was not necessary. The locations which w~re used to
evaluate the ecological risks were conservative. The river
sample locations were directly adjacent to the seep discharges
and were in an area that is above the water level when the river
is drawn down. . If the river samples had been at a further
distance from the seeps, then even lower impacts would have been
detec~ed. .
4 .
COMMENTS REGARDING "THE PROPOSED PLAN
PRP Comments:
Comment a: A comment was submitted stating that SW-2 will
achieve the remedial action objectives for source control, ground
water and surface wate~, and provides the best balance among the
criteria in the NCP.
Response:
EPA agrees with this comment.
Comment.b: A comment was submitted stating that SW~3 would be
difficult to.implement .and has serious technical concerns. In
particular, the steep topography surrounding the landfill, the
variability of fracture system and hydraulic connections between
fractures, the low probability of receptor exposure, and the high
cost make SW-3 an unacceptable alternative.
Response:
EPA generally agrees with this comment.
Comment c: A comment was submitted stating that other ground
wate~ controls, such as upgradient controls, have been shown .to
be' unsuccessful at the Site. The comment also stated that the RI.
supports that ground water does not discharge to the waste.
,)
Response: EPA agrees that previous attempts to control
upgradient ground water have been unsuccessful and that the
current Site hydrogeologic model does not support ~ignificant
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36
fully successful at controlling the generation of leachate and
the subsequent contamination of bedrock ground water, there may
need to be further studies of the potential for additional ground
water controls.
TAG Group and Citizen Comments:
Comment a: A comment was made questioning whether other Sites
have been successful with a natural restoration approach.
Response: Other sites have selected natural restoration as the
remedial action. However, the natural restoration process is
still underway at most. of these sites.
. Comment b: A comment was made that. capping alone will not
significantly reduce the migration of chemicals from the
landfill.
Response: The FS supports the conclusion that capping will
significantly reduce ~he migration of chemicals by reducing the
rate of infiltration through the landfill into underlying ground
water and, in turn, by reducing the mobility of the chemicals in
the landfill as well as chemicals in the bedrock which may be
mobilized by leachate from the landfill. The Site hydrogeology,
presented in the RI and SRI Report.s, provides the basis for. the
conceptual. hydrogeologic model for the Site. The cap will
significantly reduce infiltration, which is the major component
of flow into the waste. The model used to estimate ground water
restoration included the potential for a small component or
horizontal flow. Even with a small component of horizontal flow,
the ground water should be restored within IS years of cap
completion. In addition, the gas collection and treatment system
and ground water collection trench provide additional control
over Site contamination. .
Comment c: A comment was, made that it is unacceptable to address
the discharge of contaminants to the Connecticut River as a
remedial action.
Response: Long-term discharge of contaminants to the Connecticut
River is being controlled through the capping of the landfill and
the natural restoration of the ground water. Substantial
reductions in concentration levels are expected within five years
of cap completion. In addition, discharge to a water body is an
acceptable practite as long as the discharge does not impact the
receiving water body. The dis'charge of the Site bedrock to' the
Connecticut River is a natural process. The current situation
does not present any adverse public health or environmental
threat. In addition, the Site cleanup model estimates that a 90
percent reduction of, contaminant concentrations will be achieved
within 5 .years of cap completion. To negotiate, design, and
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37
,;
years. Given the difficulties associated with developing a pump
and treat system tha: can capture a bedrock plume, the
topographical limits regarding the installation of bedrock wells,
and the limited bene::t accomplished a bedrock pump and treat
system was not consi=ered to be a practical option and the
natural restoration a:ternative was selected.
Comment d: A comment ~as submitted stating that the Safe Drinking
Water Act Maximum Co~:aminant Level for Arsenic of 50 ug/l is not
protective and that a~ alternative cleanup level, such as
background, should be developed for Arsenic.
Response: Arsenic is a compound for which the excess cancer risk
at the MCL is outside the risk range in the absence. of any risk'
management factors. ~ecent studies indicate that many skin
tumors arising from oral exposure to arsenic are non-lethal and
that the dose-response curve for the skin cancers may be
sublinear (in which case the cancer potency factor used to
generate +isk estimates may be overestimated). It is Agency
policy to manage these risks downward by as much as a factor of
ten. Therefore, the risk of the cleanup level is withiri the
acceptable cancer ris~ range. The NCP allows for a
reconsideration ofc:eanup levels if new information indicates
that the current .clea~up level is not protective. Therefore, if
EPA were to low~r the MCLfor arsenic, the cleanup level would.
also be reconSidered. The ground water restoration model
estimates final arsenic concentration in the ground water of 9 -
21 ppb. It is diffic~lt to estimate the final arsenic
concentration since naturally occurring background levels will
set the lowest level than can be achieved. Background arsenic
levels in the bedrock ground water in the vicinity of the Site
range from nondetect at 1 ppb to 63 ppb in a residential weil
north of the landfill. Arsenic concentrations in bedrock ground
water is often fracture specific and is controlled by the
percentage of arsenic bearing minerals in the fracture. The
spacial yariation of arsenic concentration at the Site and in the
residential wells supports this fact. Therefore, the only true
background level for a given fracture is the upgradient.ground
water within that fracture. The range of background levels in
non-impacted areas can be used to evaluate the Site cleanup
levels. The cleanup level of 50 ppb and the predicted final
levels of 9 - 21 ppb fall within the range on nondetect to 63 ppb
seen in background wells. EPA will evaluate the risk posed by
the ground water at the end of the restoration period before
determining that the remedial action is complete. . If the grounq
. water' represents an unacceptable risk, then further actions wi'll
be considered.
Comment e: A 'comment ~as submitted that EPA has not adequately
defined the extent of contamination at the Site.
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38
well K40 indicates that the northern extent of the plume is not
fully confirmed. However, the existence of contamination at this
location does not change the basis for .the selected remedy. It
is not necessary to know the exact extent of the plume in each
direction to evaluate the remedial alternatives for the Site.
The basic remedial alternatives for ground water contamination,
No Action, Natural Attenuation, and Pump and Treat were all
included in the Proposed Plan and FS. The Long-Term Monitoring
Program will provide additional data to further delineate the
extent of contamination. The need to install additional wells
will be evaluated in the Long-Term Monitoring Plan. EPA believes
that the selected remedy addresses all contaminant exposure
pathways at the Site in a manner that will success~ully eliminate
the potential for an unacceptable exposure to human health and
the environment. .
"
Comment f: A comment was made indicating that there is no mention
of whether filtered or unfiltered data was used to estimate risk
or establish cleanup levels.
Response: EPA typically seeks to use unfiltered samples to
assess risk to public health from ingestion of groundwater.
Samples collected by this method typically produce data which are
the most representative of a resident's exposure to groundwater.
The groundwater sampJ,.ing -at this site occurred prior to EPA's -
involvement and consisted of filtering the samples in the field-
prior to laboratory analysis. Near the completion of the HHRA,
(October, 1992), EPA required that both filtered and unfiltered
groundwater samples be collected from all monitoring wells to
determine whether filtered data collected previously and during
the same round would produce comparable results as unfiltered
data. Both filtered and unfiltered rounds were found to have
comparable results for all compounds detected. A slight increase
in arsenic occurred in both filtered and unfiltered samples
collected-in October, 1992, but conCentrations between both
. samples were similar and -the filtered sample contained- the
highest arsenic concentration. Thus the use of filtered data at
this site was considered appropriate for estimating exposure to
groundwater. In addition, the use of filtered data allowed for
the preparation of the risk assessment much sooner than would
have occurred if EPA had waited for the unfiltered data. This
provided the public with a basic presentation of the distribution
of risk and the major contaminants of concern early in the
process.
All groundwater data collected since October, 1992 has consisted
of unfiltered samples. Compliance with cleanup levels will be
measured with unfiltered samples.
Comment g: A comment was made that iron, aluminum, and lead
should be included in Table 1 as ecological contaminants of
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39
Respor.se: The ground water trench has been success:~l at reducina
the impact of the Site on the Connecticut River. A review of th~
Connecticut River surface water results for sampling events
10/92, 8/93, and 5/94 do not show an exceedence of water quality
'standards for any compounds or elements. Aluminum levels were
elevated in all sample rounds. The Connecticut River will be
sampled under the Long-Term Monitoring Program. River 'samples
will be compared with ambient water quality criteria to determine
if a potential impact is occurring. However, given the result of
the most recent sampling events, specific cleanup levels for the
Connecticut River are not necessary.
Comment h: A comment was submitted that if there was a larger
community impacted by the Site, the natural restoration' ,
alternative would not have been considered and that the remedial
action would have focussed on treatment.
Response: EPA does not agree with this comment. EPA is committed
to the protection of human health and the environment. The
CERCLA Statute has a preference for treatment, but it also has a
requirement for cost effectiveness. EPA has implemented pump and
treat remedies for communities the same size as Rockingham. The
major factors inFluencing the evaluation of the treatment
alternatives at this Site where the uncertainty regarding the
technical practicability of bedrock ground water extraction, the
lack of currerit'ieceptors, ,and the estimated time frame for
achieving cleanup levels under the natural restoration approach.
In addition, a significant amount of source control will have
been implemented at the Site with the completion of the cap. The
2 year differential in time frame for cleanup, the technical
difficulties associated with implementation, and the substantial
difference in cost made the pump and treat option the less
preferred ,appr.oach at this Site.
Comment i: A comment was submitted that the extent of BFI
property is not indicated in the Proposed 'Plan.
Response: The extent of the BFI property is shown in figure 1-4
of the RI.
Comment j: A comment was submitted asking what deed restrictions
are going to be in-place for the areas not within BFI property
lines, but underlain by impacted ground water? Is a well
advisory planned for the entire impacted area? Is this adequate
to address cpntaminated property not owned by BFI?
Response: BFI-VT in under an existing agreement to provide a free
supply of water to the affected residents and convey the water
line to the residents twenty years after full and' final closure
of the solid waste facility., EPA will seek the permission of the
property owners to remove the existing water supply wells, and
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40
advis=~y. If EPA determines that these institutional controls
are i~effective at preventing future use of the impacted ground
water it will evaluate and require additional measures.
Comme~: k: A comment was submitted that a fence is not included
in the Proposed Plan.
Respo~se: A fence will be installed as part of the NTCRA at the
end o£ the construction activities. Activities implemented under
the ~~CRA were assumed in place under the Proposed Plan.
Comme~: 1: A comment was submitted that access controls are
needed for seep # 6.
Response: The EPA 'Human Health Risk Assessment did not show an
unacceptable risk of exposure to the seeps. Therefore, EPA
cannot require the area to be fenced. However, BFI has installed
a pe~anent chain link fence to restrict access to seep 6.
Commen: m: A comment was submitted that the FS did not evaluate
risks from the proposed use of sewage sludge or paper sludge.
Response: Neither sewage sludge nor paper mill sludge is
currently proposed for use at the landfill. However, under Part
Bof the EPA Risk Assessment Guidance, potential risks associated,
' with a remedial action are evaluated in either the FS or design.
EPA evaluated the potential exposure to sewage sludge as part of
the design process and determined that no unacceptable exposure
would have resulted from the use of the material. BFI withdrew
the proposal for use of the material based upon schedule
concerns.
Comment n: A comment was submitted that discharge of the Site
overburden ground water to a POTW is not treatment, but rather
dilution.
Response: Discharge of waste water to a POTW is an acceptable
practice provided the discharge does not adversely impact the
receiving ~ody of water or the operational ability of the POTW.
EPA performs an evaluation of the potential discharge based upon
the EPA Guidance: CERCLA Discharge to POTWs and the FATE model.
If no adverse impact is demonstrated by the evaluation, then the
discharge may be considered acceptable.
Comment 0: A comment was submitted that EPA should not have
assumedthatseep'6 only flows during the spring and that the
current discharge at this seep represents an erroneous assumption
in the Proposed Plan.
Response: Seep 6 became dry in 1993 during the summer following
the ccnstruction of the ground water collection trench along
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41
..:;
6 was proposed. ~oweve~1 during 1994, seep 6 has c~ntinued to
flow throughout ~~e summe~. Cbservation of this flow on July 20,
1994 indicated tr.at the discharge did not reach the Connecticut
River. Further control or seep 6 is being addressed as par~ of
the NTCRA. An ex~ension to the existing ground water collection
trench will be i~stalled durinc this fall in an attemDt to
eliminate the discharge of la~dfill impacted ground water at seep
6.
Comment p: A com~ent was submitted that the background location
for the Connectic~t River was within the area of im=act and that
site-related contaminants have impacted the Connect~cut River.
Response: Data from 1991 and early 1992 suggests that .el~vated
levels of some me~als were detected in the Connecticut River.
However, three s~bsequent rounds of data collection do not
support an impact to the Connecticut River at any of the sample
locations. EPA will re-evaluate the location of the background
sample 'as pa~t or the Long-Term Monitoring Program.
Comment q: A com~ent was submitted that vinyl chloride should be
listed as a major contaminant.
Response: While vinyl chloride was not identifieQ as a major
contaminant in the FS, vinyl chloride is contaminant of concern.
'and a cleanup level of 2 ppb has been established for this'
compound. The basis for stating that arsenic and manganese are
the major contaminants at the Site is that arsenic represents 97
percent of the carcinogenic risk and arsenic and manganese
represent the vast majority (97%) of the non-carcinogenic risk.
EPA considers all contaminants detected above federal and state
standards or acceptable risk levels to be of concern.
Comment r: A comment was submitted that the possibility of
intermittent ground water in ::-::=: 'ricinity of the residences
between the landfill and the C~nnecticut River has. not been.
addressed as evidenced by the continued flow of seep 6.
Response: Seep 6 is at a substantially higher elevation and is
side gradient to the area of the residences. An overburden
boring north of seep 6 did not encounter ground water until
immediately above bedrock. Even if overburden in the area of the
residences was recharged by the bedrock there would not be an
exposure pathway due to the low levels of VOC in the bedrock
ground water. The overburden is not a water supply and the VOC
concentrations in the bedrock are not sufficient to support an
inhalation pathway.
(.
Comment s: A comrr.ent was submitted that "no effort" on page 8 of
the Proposed Plan should include a statement that no effort
includes .an assumption that the cap and gas system are operated
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42
ResDonse: The No F~rther Action alternative did not assume the
successful operation and mai~eenance or cap and gas system. This
assumption provided a major reason why the No Further Action
alternative was nee considered prbte~tive.. In addition, the
Human Health Risk Assessment was streamlined based UDon the
Presumptive Remedy and Landfill Guidance approach. As stated in
the Limitations section of the Risk Assessment, the current Human
Health Risk Assessffient could not support a complete No Further
Action alternative.
Comment t: A comme~t was submitted that the extent of bedrock
contamination and the conceptual hydrogeologic model have changed'
since the Human Health Risk Assessment and Ecological Risk
Assessment were completed.
Response: The Human Health Risk Assessment was completed after
the October 1992 sampling event. This sampling event documented
the contamination at the J well cluster. More recent data
indicates the presence of low levels of VOC contamination at the
K-40 well located northeast of the' landfill. As stated in
previous responses, the current extent of contamination to the
north of the landfill will be defined in the Long-Term Monitoring
Program. However, this does not change the basis for the
selected remedy. .
Comment: u: A comment was submitted that 'iron~ aluminum, and lead
should be sampled in the Connecticut River. A comment also
questioned whether additional parameters should be sampled as the
landfill becomes anaerobic.
Response: The Connecticut River and any surface water discharges',
storm water or seeps, will be sampled for the full target analyte
list for metals. This will include aluminum, iron, and lead.
The constituents' listed in Table 1 of the Proposed Plan were
developed to provide a focus to the ground water monitoring and
more particularly, the tracking of ground water restoration.
Additional parameters will be periodically added to the analyte
list during the Long-Term Monitoring Program to confirm. that new
constituents are not present based upon changes to the Site as
the effect of the cap and gas system are begin. The landfill is
currently considered to be in an anaerobic state due to the high
methane generation, the reducing conditions in the leachate, and
the effect of the gas collection system.
Comment v: A comment submitted stated that additional studies are
. needed to address the effectiveness of the cap in reducing
. exposure via all relevant pathways; the risk assessment must be
re-evaluated in light of the additional pathways; and the cleanup
levels must be re-evaluated to look at background and .the.
protection of human health.
".
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43
v
and those being i~~leme~~ed as part 0: the NTCRA will fully
add~ess all releva~t ex~osu~e pa~hways at the Site. EPA does not
consider the inhalation of indoo~ vapors to be a complete
exposure pathway due to the lack of significant VOC levels in the
ground water in the vic~nity of the residences. Seep 6 was not
determined to represent an unacceptable risk to human health or
the environment based u~on the human health risk assessment and
the Connecticut River sa~ple results do not show any landfill
related impacts. If the cap is not effective at restoring the
ground water or if the Long-Term Monitoring indicates that the
assumptions regarding additional pathways was incorrect, then a
re-evaluation of the. risk assessments would be considered. EPA.
considers all of the cleanup levels to be protective of human
health. The cleanup levels for arsenic and manganese are within
.the range of concentrations detected in background wells. If new
information is presented that indicates that any of the cleanup
levels are not protective then the cleanup level will be changes.
The final predicted arsenic concentration in the bedrock is
expected to be well below the cleanup level for arsenic.
~
Comment w: A local resident who is supplied water due to
contamination at the Site questioned whether a new water supply
well would be installed for his residence when the ground water
is restored.
Response: The selected remedy includes the replacement of the
wate~ line with water supply wells when the water beneath the
residences is determined to be acceptable for use as a drinking
water supply by EFA and VTDEC.
Comments x: A comment was submitted that seep #6 should have been
. included in the proposed remedy and that actions should be taken
to collect the wate~ in seep #6.
Response: EPA is addressing seep #6 as part of the. non-time-
critical removal action. The interceptor trench. installed in
January 1993 was designed to eliminate the flow in seeps 2, 3/4,
and 6. Seep #6 still exhibited flow during the. spring of 1993,
with periodic flow after rain event. Seep #6 continued to
exhibit flow during the spring and summer 1994. In July 1994,
EPA required BFI-VT to prepare a plan to prevent the continued
flow of seep# 6. An outline of the plan was delivered to EPA on
July 29, 1994. The plan calls for an extension of the existing
trench. If the trench extension is not successful, then a sump
will be installed to intercept the flow underground.
EPA will continue to monitor the conditions at all former seep
locations, includir.g seep#6, as part of the selected remedy. It
should also be noted tha~ while seep #6 was flowing during July
1994, the seep water eva~crated or infiltrated prior to reaching
the Connecticut River ar.d no flow into the Connecticut River was
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~~
Comment y: A comment was submitted re~~esting that interim target
cleanup levels be develcoed to determine if the remedy is meeting
its cleanup o~jectives. -
Response: Final target cleanup levels have been established in ,
the Record of Decision. Interim goals to track the restoration
of ground water will be developed as part of the Long-Term
Monitoring Plan. The interim goals will likely be based upon
several factors. Water levels measurements, contaminant
concentration levels, and trench flow volume will all be
considered in evaluating the effectiveness of existing control.
This information will be used to evaluat'e the conceptual model
for the Site. If the collected information confirms that the
selected remedy will not achieve the cleanup levels, then further
actions will be considered. ' '
-;,
Comment z: A comment was submitted stating that the volume of
leachate will increase dramatically after the landfill closure is
complete.
Response: EPA does not agree with this comment. All evaluations
performed at the Site predict a steady decline in the volume of
leachate generated by the landfill after the cap is installed.
While the placement of the cap could cause a short term increase
in leachate generation, thi~ was not predicted to be substanti~l..
A' 90% drop in 'leachate gerieration is predicted a£ter 5 ye~is 6f
cap completion.
Comment aa: A comment was submitted questioning whether ARARs
other than environmental laws were considered.
Response: ARARs, by definition, are federal or state
environmental or facility siting laws that are applicable or
relevant and appropriate under the circumstances at the site.
ARARs apply to theon-site aspect of a remedial action. Any off-
. site ac~ion must comply with all existing .feqeral, state, and
'local regulat{ons. On-site actions must be performed in a manner
consistent with ARARs and all other applicable federal, state,
and local regulations. A permit is not required for any activity
performed entirely on-site, as defined by the National
Contingency Plan. However, it is EPA practice to only list
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v
5.
COMMENTS REGARDING N~:~ ACT~VITIES
"
Comme~t a: A local reside~~ questioned w~en sediment which washed
onto tis property after a ~ain event in ~une 30, 1994 would be
removed.
Response: A rain event on June 30, 1994 caused a retention pond
in the northeast section 0: the landfill to overflow. In
addition, the drainage ditch along the landfill overflowed and
caused water to run down R~ute 5. This water combined with the
storm water drainage along Route 5 and ca~sed several areas of
soil to wash onto the residents properties. These areas were
sampled for VOC, SVOC, Metals, and pesticides. The results
demonstrated that no unacceptable levels of hazardous substances
were in the soils deposited on the priva~e property. Since the
soils cover a very small area and are not contaminated, the soils
will not be removed.
Comment b: A local resident stated that the recent wash out.
caused $3,500 damage to his property, that his property value has
dropped, ,and that sink holes are a concern.
,')
Response: EPA considers the protection 0: the private property
'adjacent to the Site to be a major concern. BFI' ,has indi'cated to
EPA that they will correct any damage caused by run-off from the
Site. However, a significant portion of the problem in this area
is the steep natural slopes and the Route 5 storm drainage
system. There is no way to change the natural drainage from the
slopes. The landfill construction project will involve a re-
design of a substantial. portion of the Route 5 drainage. A new
culvert will be installed to direct landfill run-off and Route 5
run~off directly to the Connecticut River. This should decrease
the chance for future washouts. In addition, soils or water that
flow off the Site are clean rain water o~ cover soils. The area ,.
of, the landfill facing 'Route 5 has been covered with at least 36
inches of cover material as of September 15, 1994. Proper~y
values are a common concern at CERCLA sites. EPA cannot change
the real estate market, but EPA is willing to provide information
or an explanation to any person considering the purchase of
property near the landfill regarding the nature and extent of
contamination at the Site. The sink hole along Route 5 that has
appeared three times this year appears to be caused by a storm
drain that is aausing soil erosion. VT AOT is aware of this
problem. '
Comment c: A local resident stated that he opposed the use of
shredded tires at the Site.
Response: Shredded tires a~e being used as drainage material on
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46
to the C?nnecticut River. There does not a~~ear to be any human
health r~sk concerns resulting from the use of shredded tires.
EPA considered the use of shredded tires to be a beneficial use
of a recycled material. -
Comment d: A local resident expressed an opposition to the use of
sewage sludge on the cap.
Response: Sewage sludge is no longer proposed for use.
Comment. e: A local resident expressed concern over the lack of
fencing and large obvious warning signs.
-Response: A partial fence has been erected at the Site. A
complete fence will be installed after construction is complete.
Since the risk assessment concluded that the seeps along the
landfill did not represent a public health threat and the
landfill was covered with at least 10 inches of clean soil, it
was considered acceptable to install the fence at the end of
construction. - The construction activities would have made
installing a fence difficult. There are signs identifying the
Site as a Superfund Site posted around the landfill. The phone
number of state and federal contacts is listed on the signs.
Comment f: A comment was -submitted requesting that a .rapid --
response-plan be developed to handle future Site washouts, that
sampling be performed within 24 hours, and that EPA establish a
forum for property compensation.
Response: A significant weather event plan has been developed
for the landfill since the June 30, 1994 storm. A local
individual is designated to observe conditions-and mobilize
contractors if a washout occurs. Sample bottles are available
for sampling any soils or water requiring characterization. EPA
and VTDEC official are notified of any event. EPA has the
-responsibility for notifying the press. Samples will be
collected as soon as possible after the event. EPA does not
become involved in financial settlements or discussions between
parties outside of the CERCLA action. EPA's responsibility and
authority fs limited to controlling the release of hazardous
substances from the Site.
Comment g: A comment was submitted stating that the cap should be
desired to handle a 100 year storm event.
Response: Existing federal regulations for solid waste closure
recommend a design storm of 25 year 24 hour event. The down
chute and new drainage culvert are being designed to handle the
50 and 100 year storm events.
Comment h: Several comments were received indicating an
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47
especially given the detection of dioxin in t~e sewage sludge.
"
u
Response: On August 1, 1$94, E?A was. notified by .BFI ~hat sewage
slu~ge was no longer being proposed for use i~ the cap. Comments
reaardina the use and risk assessment of sewaae sludae are no
lo~aer r~levant to this decision. However, E?A continues to
sup~ort the beneficial use of materials such a sewage sludge.
Comment i: A comment was made that the current fence is not
sufficient and that the entire la~dfill should be fenced prior
to the completion of construction.
Response: The immediate construction of a fence is not justified
at this Site. Public access and trespass has not been a reported
problem on. the landfill in the past. The landfill is 'an'
.operating facility with perso~nel on-site who would detect
trespassers. The current construction program results in
subs~antial activity at the landfill six days per week. The
entire 'landfill has a one foot interim cover and the entire
landfill will have five feet of material over the waste at the
end of construction in November 1994. The EPA risk assessment
does not support the need for a fence from an public health
exposure pathway. The only b~sis for a fence now or in the
future is to prevent public access that might result in damage to
the cover or personal injury from a fall or from construction
activities. The landfill will be fenced at the completion of
construction.
The immediate installation of a fence is not justified based upon
public health or trespass concerns. The landfill is currently
posted with "No Trespassing" signs that indicate that the
landfill is a'Superfund Site. Furthermore, access to the site is
currently limited by the Site topography and there have been no
indication of trespassers. Construction of a fence would hamper
the con9truction of the landfill cap.
Comment j: A comment was submitted that alternative method be
explored to minimize the chance of washouts if a grass cover is
not in place by winter.
Response: The landfill cap design approval requires that a plan
be prepared and implemented tQ prevent erosion and protect the
landfill cap during the winter/spring 1995. Preventing erosion
and establishing a grass cover are major objectives of the
landfill cap construction program. The i~stallation of erosion
control geotextiles" hay bales, silt fence, and erosion control
blankets are all being considered as part of the erosion control'
strategy.
Comment k: A comment was submitted that a response plan to
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48
Response: A significant weather event response plan has been
developed as part of the NTCRA activities. During the
c~nstruction of the cap and the timeperi~d until vegetation is
well established the cap is susceptible t~ erosion. Erosion
control is a major objective of the Site activities. The
significant weather event plan requires tiat individuals be on
call to address Site related weather issues. The local press are
notified of events as soon as possible. EPA contacts the
effected residences to confirm that there concerns are being
addressed. EPA does not make a determination regarding property
damage. The property owners and the facility must discuss the
potential for the recovery of damages between themselves. It
should be noted that a factor contributing to the washout or
deposition of soil ori ~esidential property is the poor condition
'of the Route 5 drainage system and the condition of Riverfront
Road. Sampling of Site run-off, both water and sediments, will
be performed based upon best professional judgement with input
from the residences. Samples will obtained as soon as possible
after the event. Sample results from the June 30, 1994 storm
event confirmed EPA's initial position that Site released
contamination is not present in the sediments that washed from
the Site. .
Comment 1: A comment was made regarding the capacity of the
proposed down chute on the cap and the relationship between the
doWn chute and the storm drain. A further comment also reqUested
the design storm event.
Response: The proposed down chute will carry surface discharge
from an approx. 1 acre area of the cap to the storm drain along
Route 5. The current storm drain is not functioning properly.
new storm drain, designed by the Vermont AOT, will be installed
to provide better water management and capacity for the water
from the down chute and water draining along Route 5. The
capacities of the down chute and the storm drain are being
considereq as part of a large~ scheme to handle Site run-off.
The design storm event required by the federal solid waste
regulations is the 25 year 24 hour event. There is no design
storm event requirement in the Presumptive Remedy. The down
'chute and Route 5 drainage are being design based upon an
evaluation of the 50 and 100 year storm events.
A
6.
Comments Reqardinq the Lonq-Term Monitorinq Plan
. Comment a: A comment was submitted stating that the Long-Term
Monitoring Plan does not provide for the collection of sufficient
background data. In addition, the comment indicated a need to
sample the existing cover and cover materials placed as part of
the caD. The comment also indicated that SVOC, dioxin, furans,
and PCBs should be included in the Long-Term Monitoring Sampling.
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49
v
Respc~se: Sampling of the landfill caver is not necessary prior
to cap placement. An interim cover was placed ove~ the landfill
afte~ closure in November 1991. In addition, the majority of the
land:ill is covered with clean fill placed d:..:.~ing t::e regrading
of the la~dfill in August 1993. Once the cap is complete, the
land:ill waste and interim cover will be bu~ied under five feet
of cap mate~ial. In addition, EPA guidance ~egardi~g tpe
inves~igation and capping of landfills does not support the need
for characterization of the landfill cover soils unless "hot
spots" are identified. While several areas of stained soils are
prese~t on the landfill surface, these are not considered "hot'
spots". To confirm this determination, the areas of stained
soils we~e tested during the remedial inves~igation and evaluated
in the risk assessment. The testing and risk assessment did not
indicate the potential for an unacceptable risk from these areas.
EPA does not see the need to sample the inte~im cover materials
prior to cap construction.
The overburden and bedrock ground water at the Site has been well
characterized and additional characterizaticn will occur as part
of the Long-Te~m Monitoring Program. PCBs were not detected in
any of the BFI 10/91 samples or the EPA 10/92 and 8/93 samples.
Pesticides have not been detected in either the BFI 10/91 or EPA
10/92 and 8/93 bedrock samples. Trace levels of pesticides were
detected in well B-13D. As a result of these previous
detections, B-.13D was sampled for pesticides during the May 1994
sampling event. B-13D will be continue to be sampled for
pesticides as part of the Long-Term Monitoring Program.
Additional wells will be sampled for pesticides during the five
year review. Dioxin and furans were not analyzed in the
overburde~ and bedrock ground water samples. Dioxin and furans
have a very low mobility and solubility. Based upon the above
discussion and the results of the remedial investigation,
supplemental remedial investigation, and EPA sample results,
there is not a need to re-sample bedrock and overburden ground
wate'r prior to cap construction. . .
The surface water and sediments of the seeps have also been well
characterized for Site-related contaminants. PCBs were not
detected in any of the BFI 10/91 or EPA 10/92 and 8/93 samples.
Very low levels of pesticides were detected the surface water and
sediments of a few seeps. Two of these seeps have been
eliminated by the ground water trench. The Long-Term Monitoring
Program will include the periodic sampling of those seeps that
are not controlled by the trench. Pesticides wil~ be further
evaluated for inclusion in ,the revised Long-Term Monitoring Plan.
The surface water and Sediments of the Connecticut River have
been sampled for PCBs and Pesticides by EPA in 10/92 and 8/93.
No PCBs were detected. Pesticides were not detected in the
surface water of the Connecticut River. While pesticides were
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50
of these detections do not indicate a significant concern.
Surface water run-off from the cap and water from the drainage
layer ~ithin the cap will discharge to ~etention basins
surro~~ding the Site. Two of the retention basins will drain to
the Cc~necticut River. The water from these discharges, which
will f:'ow during the spring melt and major storm events, will be
sample~ for VOCs, sVOCs, metals. These constituents are also
suffic~ent to characterize the discharge from the areas of the
drainage layer containing tire shre~s. Additional constituents
may be added to the sampling of the two discharge culverts based
upon tte results of the sewage sludge sampling.
Commen': b: A comment was submitted stating that re'sidential
wells should be sampled for SVOCs and that unfiltered d~ta should
be col:'ected.
Response: Residential well samples are unfiltered. EPA will
consider the addition of an occasional SVOC sampling as part of
the residential well monitoring program.
Comment c: A comment was submitted stating that monitoring wells
C-1S, C-16,and J-35 should. be included in the Long-Term
Monitoring Plan. .
Response: Monitoring wells MW-C1S and MW-C16 are located
edge of the landfill between the landfill and the Route 5
Water levels in the wells are useful in supporting ground
migration towards the trench. However, the usefulness in
sampling these wells in not clear. Well E21 provides a plume
delineation point outside of C1S and C16 and Well B13D is a
better overburden ground water indicator well. Well J-3S does
provide an indication of the deep overburden quality just
downgradient of the Route 5 trench. The VOC levels in this well
were very.low in the 1992 sampling event. Well J-35.will be
considered.for inclusion in .the LTMP.
Comment d: A comment was made regarding air emissions from.sewage
sludge.
at the
trench. .
water
Response: As sewage sludge is no longer proposed for use, a
response to this comment is not .necessary.
Comment e: A comment was submitted stating that the pH of each
non-VOC sample should be checked.
<;>
Response:
The pH of each sample will be checked.
Comment f: A comment was submitted stating that only one VOC vial.
should be filled per bailer and that VOCs should not be collected
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v
Response: While certa:~ pumps are not appropriate f6r the
collec'tion of VOC sa~;:es, low flow pumps may be used to collect
VOC samples. Low flch pumps are typically used for VOCs when the
collect~on of low flch metal results is being performed.
Standard sampling prc=edures allow for the collection of multiple
vials for a single Vc~ sample from a single bailer to ensure
adequate sample volu~e and to allow for potential breakage of a
vial during sample ha~=ling and shipment. Additionally, when
split samples are collected, it is common procedure to collect
both samples from a si~gle bailer to ensure reproducability.
Comment g: A comment has submitted stating that a well should be
flushed at least three well volumes, even if the test parameters
(pH, temperature, and conductivity) have stabilized and up to
five well volumes if ~ie test parameters have not stabilized.
The comment also state= that samples should be collected
immediately after flus~ing.
Response: Well flushi~g will be ,performed according to EPA
protocol. Samples will be obtained as soon as practical after
flushing.
Comment h: A comment was submitted requesting clarification of
the residential well sampling procedures and indicated that the
purge rate should not exceed 3 gallons per minute and the flow
rate should not exceei 1 gallon per minute for 5 minutes
preceding and during sampling for VOC.
Response: Residential wells will be sampled to minimize the
disturbance of the sa~ple while collecting a sample
representative of residential exposure.
Comment i: A ,comment was submitted stating that surface water
VOC samples should be obtained at some depth by submerging the
vial upside down and then gradually tilting to fill. Sediment
samples should be collected after surface ' water samples. Sample
procedures should be clearly specified in the Long-Term
Monitoring Plan.
Response: EPA protocal allows a collection device to collect the
surface water sample which is carefully decanted into a pre-
preserved vial. This avoids health and safety concerns regarding
carrying acid on a boat. Sediment samples will be obtained
following surface water samples.
Comment.j: A comment was submitted requesting more detail
regarding the sampling of the above ground storage tank and
underground storage ta~k. The comment stated that the tanks
should be sampled pri8r to any decontamination water being
collected in the tank. The comment indicated that the sampling
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52
Response: The curre~t ~ethod of sampling involves either lowering
a bailer or obtaining a sampling from the exit pipe. Both of
these methods are believe' to provide a representative samples.
The method will be specifically described in the Long-Term
Monitoring Plan and will address decon water.
Comment k: A comme~t was submitted stating that an HNu should be
calibrated at the beginning and end of each day and after each
time the instrument is shut off.
Response: HNu calibration will follow the protocol in the
standard operating procedures in the Long-Term Monitoring Plan.
This procedure requires daily calibration of the meter.
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53
G
IV. REMAINING CONCERNS
PRP Comments:
Comment a: A comment was received statincr that while residential
waste, old appliances, tires, empty drum;, and stumps have been
observed during Sitei::vestigations of the area near the
Connecticut River, no "drum fields" have been observed and that
such a statement was false and misleading.
Response: EPA perfor~ed an independent inspection of the area
along the Connecticut River after the report of a "drum field" by
the TAG Group. No drum field was found. EPA agrees with ~he. .
comment.
TAG Group and Citizen Comments:
Comment a: A comment q~estioned whether monitoring wells and a
drainage diversion were installed in a right of way.
Response: A drainage d~version was installed at the request of a
reside~t of Riverside Road. The monitoring wells. were installed
prior to EPA inv6lveme~t. EPA has requested BFI.to.determine if.
a right of way exists at this location. .
Comment b: A comment s~ated that a large number of 55 gallon
drums were disposed in a. ravine below the Site and requested
testing of these drums.
Response: EPA and VT D~C investigated the ravines after the July
20, 1994 public hearing. There is a substantial amount of trash
and debris in the ravi~es that was dumped by the previous
property owners. These inspections revealed approximately 5
emp~y drums a~d.a propane cylinder. These drums will be removed.
However, analytical results of the Connecticut River surface
water and sediments and direct observation did not show-any
support for the drums representing a chemical concern.
Comment c: A comment questioned whether the VT AOT has personnel
trained to work in the area impacted by the Site.
Response: The VT AOT has individuals with the necessary training
to work at the Site.
Comment d: Several comments requested that indoor air be tested
in the four residences below of the landfill.
Response: Indoor air was not identified as a potential exposure
pathway in the RIfFS. This was based upon the very low level of
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54
locations. Any overb~rden ground water in the area of these
homes is likely to be of a similar concentration as the bedrock
ground water. The overburden ground, water containing VOCs is
further south 'and side gradienc to the residences. There is no
evidence that the contamination the overburden that discharges a~
seep # 6 extent further north than seep # 6. Monitoring well MW-
8 was inscalled to monitor overburden flow north of seep # 6.
The boring for this well did not encounter significant water
bearing zones until just above the bedrock, approximately 50 feet
below ground surface. The stratigraphy of the area consists of
horizontal layers of silts and clay with small sand seams. The
nature of these deposits causes water to flow horizontally and
discharge at areas where the ground surface intercepts the water
bearing zones. No seepage areas have been observed in the areaS
north of seep # 6 on the east side of Route 5. Based upon the
information within the RIfFS, EPA does not consider indoor air
sampling to be necessary.
Comment e: A comment was submitted requesting that additional
background sampling is necessary to provide basis for future
comparison.
Response: The Site database regarding the chemical
characterization of ground water is sufficient to provide a
baseli,ne for future comparison.' As part of, the Long-Term
Monitoring a 'better understanding of the background levels of
certain metals will be obtained. However, it is not the intent
of EPA to use background levels to adjust cleanup levels below
existing standards or risk based levels. The purpose of
background data is to prevent the establishment of cleanup levels
below existing background levels~ Background levels may be
considered in the future if the metal concentrations in ground
water are not reduced below the cleanup levels. The air testing
performed during the RI and the NTCRA will provide the basis for
determining the need for future air sampling.
Comment f: A comment was submitted that flare emissions and
efficiency be tested as part of the Long-Term Monitoring Program
and Proposed Cleanup Plan. VPIREF also stated that the State of
Vermont does not have adequate personnel or resources to
continuously monitor the flare. In addition, further comments
suggested that the State of Vermont did not adequately consider
the treatment and possible emissions from the flare.
Response: The landfill gas combustion flare was installed
pursuant ~o a permit issued by the Vermont Air Division. 'The
success and efficiency of the flare is based upon maintaining a
temperature of combustion over a retention time. . The flare has a
thermocouple that does not permit the flare to operate at
temperatures below 1600 degrees. The operation and maintenance
manual for the flare covers the actions necessary to maintain the
systems effectiveness. EPA believes that the State of Vermont
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has t~e personnel to exper~ly review the existi~g information and
deter~ine the complia~ce 0: the flare with respect to federal and
state air regulations. The State of Vermont Air Pollution
Control Regulations, which are imple~ented through the Air
Pollution Control Division (the permitting authority for the
flare), are specifically set up to prevent the release of
hazardous constituents into the a~r.
~
Comment g: A comment was made stating that the current method
for transporting and disposing of the leachate collected at the
Site was haphazard.
Response: The leachate and ground water collected at the Site are
stored in tanks prior to shipment oft-site for disposal. The'
water collected in these tanks is sampled to determine if' the
material is a hazardous waste. All sampling conducted since 1993
supports that the material is not a hazardous waste by
characteristic. The water is disposed at an off-site industrial
treatment facility at the present time. In the future, the
material may be shipped to a POTW. The material was shipped to a
POTW until spring 1994. The shipment to that POTW was suspended
due to an inv~stigation into improper operations of the POTW for
other activities relating to septic sludge hauling. The
investigators pave net reported any improper activities related
tQ the Site discharge. All shipments of the leachate or ground'
. water from the Site are accompanied by a manifest identifying the
material. The disposal of the collected ground water and
leachate at the Site will be controlled by the characteristics of
the material and federal and state regulations relating to
transportation and disposal.
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October 1992
u
October 1992
April 1992
May ,1993
June 1993
July 1993,
August 1993
56
ATTACE~1ENT A
EPA issues Press Release announcing the signing of
the administrative order for the RIfFS.
EPA holds a public information meeting for the
RIfFS and to announce the proposal to install the
ground water collection trench.
EPA issues the community relation plan for the,
S'i te'.
EPA issues a Fact Sheet summarizing the results of
the remedial investigation and human health risk
assessment.
EPA issues a Fact Sheet describing the proposed
non-time-critical removal action to cap the
landfill.
EPA holds a public information meeting to discuss
the nQn~time-criti9al removal action and update
citizens regardin~ the Site.
EPA holds an informal public hearing to receive
oral comment on the proposed non-time-critical
removal action.
September 1993 EPA signs an Action Memorandum with an attached
Responsiveness Summary.
March 1994
April 1994
April 1994
May 1994
May 1994
June 1994
EPA provides a Site tour for TAG Group and
Technical Consultants.
EPA issues a Fact Sheet announcing the completion
of design and upcoming construction activities and
updating citizens regarding RI/FS activities.
EPA hold a public information meeting to discuss
the fact sheet.
EPA issues a Press Release describing residential
well sampling and announcing a' public information'
meeting.
EPA holds a public information meeting to discuss
reside~tial well sampling
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June 1994
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July 1994
57
EPA issues Press Release announcing issuance of
Proposed Plan and upccming public in:ormation
meeting
EPA holds public info~ation meeting to discuss
the Proposed Plan
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ATTACHMENT B
PUBLIC HEARING TRANSCRIPT
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E~IIRONMENTAL PROTECTION AGENCY
BFI PUBLIC HEARING
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t~[plr
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THZ BFI PUBLIC HE~~ING
to receive comment on the proposed
6
plan for the BFI-Rockingham Landfill Superfund Site taken before
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Tamara A. Violette, Professional Reporter and Notary Public, in
and\for the State of Vermont, at :the Hit or Miss Club,. RouteS,.
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Rockingham, Vermont, at approximately 7:07 p.m.
\
, ,
Appearanges:
Mary Jane O'Donnell
Chief" Maine &, Vermont Sup'erfund Section
Edward Hathaway
Remedial Project Manager for
the BFI-Rockingham ~andfill Site
Brian Woods
State Project Manager for,
the BFI-RockinghamLandfill site
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(The Hea~:~g cornrne~ced at 7:07 p.m.)
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MS. C'DONNE=.L:
Welcome to tonigh~'s public
3
hea~ing for the SFI La~dfill.
My name is Mary Jane O'Donnell,
4
I work for the EPA in Eoston.
With me tonight is Ed Hathaway
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who is t~e project manage~ for the site, also Brian Woods who
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is the State of Vermon~'s project manager, who is he~e
7
tonight.
a
The purpose of tonight's hearing is to formally accept
9
your comments on EPA's proposed plan for the site.
I'd like
10
.
to emp~asize the word, formal.
\. .
As you can see, tonight's
11
hearing is a bit more structured than the meeting we had at
12
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the ~nd of June.
As you can see the entire contents of the
13
meeting tonight is going to be transcribed.
The reason for
14
that is that the comments made tonight will. become part of th'e
1S
administrative record for the site.
Also, any written or orai
comments that we receive tnighte during the formal part of the
hearing, and those comments received during the time period
I
I
!
will be responded to in a document called a responsiveness
. summary.
This responsiveness summary will summarize EPA's
responses to the comments received during the comment period.
They will also be included as part of the record of decision
which is EPA's legal document, which explains its rational for
its preferred. alternative.
In terms of the agenda for tonight's meeting, I'm going
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t~ very briefly give a description 0: the hearing procedures,
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then I'm going to turn things over t~ Ed, who's going to give
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a su~~ary of the presentation that he gave on the June 29th
4
meeting.
He's going t~ discuss the preferred alternative: how
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the public can comment on the preferred alternative: and also
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some of the studies that we've done.
In addition to
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commenting at tonight's meeting, he will also summarize some
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of the studies that have recently been done: a summary of the
nature and extent of contamination: the risk at the site' from
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both a'.. human health and ecological prospective: the other
11
alternat~ves we looked at in addition to the preferred
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alter:1ative:
and also a proposed plan and basically what
13
happens after tonight's meeting.
14
. .
Upon the conclus~on of Ed's presentation' I'm goin~ to.
15
open the floor to comment.
I'd ask you for those of you who
16
wish to make a comment, if you could just come to the front of
17
the room just to help Tammy transcribe what tonight's comments
18
are.
If you come to the front of the room just identify
19
yourself and your affiliation to the site.
At some point I .
20
may ask you to slow down if it appears it's difficult for us
to transcribe what your comments are.
I also reserve the
right to limit each oral comment to ten minutes.
Although I
don't expect that to be a problem tonight, I may have to
impose that restriction.
During the formal part of the evening's hearing EPA and
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BR.~TTLEBORO. 1,705304
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Vermont people here tonigh~ will not be able to respond to
2
your comments and questions when they are asked.
However, at
3
the close of the formal part of tonight's hearing we'll
4
certainly be available to answer whatever questions you may
5
have and hopefully provide you with some answers.
6
As you already know, the comment period for the
7
proposed plan began on June 30th and is scheduled to conclude
8
on July 30th of this month.
Therefore, if you wish to, submit
9
written comments, and I encourage you to do so, they should be
10
.
postma~ked no later than July 30th.
All written comments
1 1
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should be mailed to Ed Hathaway at EPA's Boston office.
i
will .giv~ you the mailing address, but it's also in the
Ed
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proposed plan that hopefully you have all received copies of.
14
, '
If you didn't receive a copy there 'are additional copies in
15
the back of the room.
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Finally, I'd like to note, again, the entire contents
17
of tonight's hearing is being transcribed and will become part
of the administrative record for the site.
Are there any'
questions in terms of the procedurai aspect of tonight's
meeting?
MR. VEITCH:
I have a question.
If someone
wants to split the comment could they make part of the
comments and then reserve time later on in the comment period?
.,
MS. O'DONNELL:
Oh sure, you mean',
submitting written comments --
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l-f_>=(. VEITCH:
No, tonight in the verbal --
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we're here to make co~~ents, right?
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MS. O'DONNELL:
That's correct.
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MR. VEITCH:
If someone wants to speak for
5
five minutes and come back at the end of the meeting and speak
6
for another five minutes --
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MS. O'DONNELL:
That's fine.
That's no
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problem.
Any qther questions?
I'm going to turn things Qver
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to Ed. Hathaway.
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MR. HATHJ..WAY:
Good evening everyone, I'm
. .
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Ed Hathaway, I'm EPA's project manager for the site.
What I'd
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like .to ~o is just start off by summarizing the preferred
alternative, EPA's proposal that we are here to comment on
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tonight.
That alternativ~ is entitled, Natural
RestorationjManagement of Existing Site Controls.
The major
components of .this action are to continue to maintain the
landfill cap' once it's constructed: to operate and maintain'
the leachate collection and ground water collection system;
and ensure that they are shipped to an offsitefacility for
treatment and disposal: to operate and maintain the gas
collection and treatment system: to ensure that the
institutional controls are maintained that will prevent any
future use of the landfill cap that could damage it: to make
sure that ground water in the area of contamination is not
used; and assure water supply to any residents with site
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ccnta~inated ground wate~.
It also i~volves continued long
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te~m monitoring of the seeps, ground wate~, collected ground
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water, leachate, Connecticut River surfacewate:::- to confirm
4
the nature and extent of cor.tamination and confirm the
5
restoration process.
I should also add that the:::-e will be
6
continued monitoring of residential wells.
All EPA
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alternatives that involve leaving waste in place will include
8
a +eview of site conditions every five years acco:::-ding to the
9
statt.:.te.
This alternative essentially relies on previously
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implem~nted activities to achieve ground water clean up; and
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it's estimated that ground water clean up will be achieved
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within l~ years of the completion of the cap.
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As discussed earlier by Mary Jane, tonight is an
'14
. important part of the public comment process.
We actively'
15
seek public comment on these alternatives.
The public comment
16
period is at least 30 days, and in this case runs from
17
June 30th to July 30th; and all public comments received
before the end of the comment period will be evaluated by EPA
18
in a documen~.known as a Respo~siveness Summary. . There are
two meetings that are usually included in a public comment
process.
One is a kick off informational meeting, that was
held June 29th right here.
Another is the public hearing,
that's tonight, that's the purpose of tonight's
meeting.
EPA
will finalize the decision by incorporating a sel~cted
"
alternative into a Record of Decision, which is signed by the
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regional administrator.
Just as a reminder, if you would like
2
to make written comments, they should be sent to EPA
.3
postmarked no later than July 30~ 1994 to my attention, u.s.
4
EPA, Waste Management Division, JFK Building, Boston, Mass.,
5
02203-2211.
This address is in all the proposed plans.
6
Hopefully you all have received one.
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Just a quick, sort of provide the setting.
I think
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everyone here knows where we are, that we're talking about .the
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DSI/BfI Rockingham Landfill.
It's directly across the street
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from us. . It sits in southeastern Vermont, adjacent to the
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Connecticut River.
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I~d like to just spend a little bit of time going over
12
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some of the technical foundation for our decision.
Remedial
14
Investiga~ion Report:
The Remedial Inyestigation is the
15
studies and related reports that characterize the nature and
16
extent of contamination at a site.
The RI serves as the
17
foundation for the Risk Assessment: both.human health and
18
ecological risk assessments.
Based on that we prepare a list
of clean up options known as Feasibility Study.
At this site
. there is both a Remedial Investigation Report and a
Supplemental Remedial Investigation Report, both of which are
complete and available in the library.
A summary of the results of these reports were that we
did a series of air investigations ranging from generic field.
screening type evaluations to very quantitative air
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evaluations, and the results of these are that trace levels of
2
four organic compounds were detected in the lanc:ill area
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itself, but no detects -- nothing was detected outside the
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perimeter of the landfill.
As far as sediments go, there was
5
no significant contaminant to the Connecticut River, nothing
6
that we would consider of concern.
There were some what we
7
consider very low level of pesticides detected in a few EPA
8.
samples taken in October of '92; none were subsequently
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~etec~ed in August of '93.
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As far as other sediments,
\
sedime~:~ in seepage areas along Route 5, for the seepage area
that's historically been up on the landfill, there have been
volatile ,organic compounds, semi-organic compounds, metals.
When I say VOCs I mean solvents like Trichloroethene;
semi-volatiles, things that 'we establish as phenols, 'metals
typically they are arsenic and manganese are essentially the
major ones we find.
The surface water, for all the samples'
we've taken in the five rounds of samples we've taken so far'
we've found the. Connecticut River has consistently met
drinking ~ater standards.
As far as seeps go, the seeps have
shown consistently shown landfill impacts of the same type of
parameters we found in the sediments; the volatile organic
compounds, semi-volatile organic compounds, some metals and
some trace pesticides in certain cases.
One thing to note is
that two of three seeps have been essentially dried up by the
installation of a ground water trench.
One is still flowing,
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it's something that we'r~ looking a~ right now a~d t~ying to
get a better understanding of and develop a pla~ to address.
And the seep in the l'andfill will te covered by the cap and
will no longer exist after that.
The ground wate~ which is
the area of primary concern at the site, we have seen volatile
organic compounds, semi-volatile organic compounds, metals,
some. trace pesticides in overburden, but not the tedrock,and
.,
no PCBs have been detected in any media onsite to date.
I'd like to focus a little more closely on the bedrock
grOUnd'\Water, because that is where we consider the most
important area of concern to the site. What we have seen to
j
date ,in what we call the overburden ground water, that is the
soil zone above bedrock, the ground water ~hat moves through,
th~t,there's an area of contamination that emanates from the
landfill itself that moves, basically, over to about Route 5,
that historically discharged at the seepage areas along Route
5.
The area that is shaded here is areas where federal and
. state drinking water standardS are exceeded.
The area that's
dotted over here i~ an area where there have been some
contamination but not above established drinking water
standards.
And what we see now is the trench, that's fairly
, successfully intercepted two of the three seeps.
There is
still one seep down here that is flowing and we're going to
try to address that.
Occasionally there is still a little bit
of water under the road that the contamination sort of dots
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cu~ over here, but isn't breaking out in the
see;::s anymore.
2
As far as the bedrock ground water is concerned, what
3
we see is a similar pattern, but is more widespread.
The
4
bedrock ground water is pervasive.
The overburden only exists
5
in that area, that extends from just around this Hit or Miss
6
building here to only about halfway down the hill, and then
7
becomes all bedrock.
We see an area, a very focused area,
e
running from the ,landfill coming right across Route 5 and
9
headi~g to the Connecticut River; where we see the major area
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of irn~act; where we see elevated arsenic, manganese with VOC
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contaminations. We have some other areas adjacent to those on
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the side ,and we have a new well here and we kind of dash that
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off a little bit., Proving once again,these levels aren't
exceeding - fed-eral drinking water standards for most
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compounds.
We may get a hit that's just above a standard in
16
one round but not above the next round, slightly elevated
manganese concentrations, but generally arsenic concentrations
in these two areas are relatively low.
The overall schematic of ~he ground water movement at
the site is shown by this figure which shows that i? general,
you've qot rain water or other sources of water infiltrating
into the waste.
That water has two options; it can either
move into what we're calling overburden ground water, the
water tends to move into that horizontally 'along toward the
slope where it breaks out.
It does that because the material
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ge~s fine~ and tighte~ with depth, so it's easie~ for the
wa~er to move horizontally than it is ve~tically, which is why
we're getting the breakouts at the
seeps.
We also have water
t~at is either -- waste that is either in direct contact or .
near contact with the bedrock that is causing leachate to flow
i~to the bedrock, and it's moving along the bedrock.
We see
higher levels in the shallow bedrock. than we do in the deep
1:e.::rock.
Our perception is. of course, that. bedrock is then'
disch~rging to the Connec~icut River.
One thing to note, once
the cap is installed over the landfill, the inflow of water
... .
will be stopped and we expect to see a drying of the waste; a
gradual decrease in the amount of leachate generated; a
substantial decrease in the amount of water collected in the
seeps; and as 'estimated for alternative, a restoration of the
bedrock ground water in 15 years.
In addition to a Remedial Investigation, human health
and ecological baseline risk assessments are developed from
the results of the Remedial Investigation.
Human health risk
assessment is an asse~sment of the potential adverse human
health effects current or future caused by hazardous
substances released from the site.
It has a standard four
step process; that is, to. identify the contaminants of
concern, focus on what potential health effects might occur as
a result of exposure to those, determine what ways in which
people might come into contact with those materials and then
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to es~imate or charac~erize any potential risk.
At this site,
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in the risk assessment for the human health risk assessment,
:)
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the focus was upon potential ing~stion of bedrock ground water
4
in~o drinking water supply; ingestion of drainage pond
5
sed:ments by, basically, going over and playing in those
6
sediments; ingestion of the seep sediments by playing in the
7
seep, ingesting the soil; ingestion of drainage pond surface
8
water, hop the fence, go for a swim in there and ingest some
9'
of that.
The same thing with the Connecticut River; if you go
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dow~ a~d play in the Connecticut, swim in the Connecticut,
ingest the water, and also. dermal contact with the
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Connecticut River or the drainage pond.
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When we do a risk characterization it's important to
1-4
realize that risk is the result of both the toxicity and
15
exposure.
There has to be both a hazardous compound, and then
16
there has to be a way in which someone comes in contact with
that on some type of frequency that could cause an effect.
The carcinogens, the risk is expressed as a probability.
The
agency typically considers, excess cancer risk between one in a
million to one in 10,000 acceptable range.
The accept,able
range for non-carcinogen compounds we use what is called a
reference dose, which is essentially a ratio of safe dose to
the dose you might be exposed to, which, you know, if you're
exposed to a level that's five times the safe dose, the 'ratio
would be five, and that would be your 'non-carcinogenic
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C)
eX:;:OSi.lre level.
The resul~s of the risk assessme~t for t~e site
esse~tially only identifies one'pathway under which an
unacceptable expcsure might occur, which would have risk
outside our acceptable risk range.
That was for the future
potential ingestion of ground water; were someone to install a
well out in the area where the contamination exists as a water
supply, to drink the highest level of contamination £or 30
years. at tNO liters a day, that would result in an
unacceptable carcinogenic risk and unacceptable
non-carcinogenic risk.
All' other pathways evaluated at the'
site 'were considered to, be well within EPA'~ acceptabie risk
range.
That incl~des exposure to the seep surface water and'
'the seep sediments.
Now, EPA also performed an ecological risk assessment
and the results of that -- this risk assessment was performed
on data collected prior to the installation of the ground
water collection trench, the seeps were actively flowing and
it was based upon samples of seep water back at that time. .
The results of that is that the seep water sediments would be
unacceptable aquatic habitat.
The Connecticut River is
periodically impacted at levels above what are called ambient
water quality criteria.
Those are standards that are
est9blished for reference criteria for ecological health.
Samples were taken right at the base of ~~e ravines where the
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wate= directly intersec~ed the Connecticut River and in that
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s~all area there were seeps above ambient water quality
3
'.... .
crl....erl.a,
but several feet away .there were not.
One thing to
4
note that is very important, is since the installation of the
5
trench we did not see a repeat of those seeps, especially
6
iron, which was a concern early on.
We have not seen elevated
7
levels of iron since t~e installation of the trench.
8
Based upon the Remedial Investigation, the risk
9
assessment and all the data collected at the site, EPA
10
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identified what its objectives for the site were.
These are
11
essentially to prevent the ingestion of landfill impacted
i
bedrock ground water that exceeds federal and state drinking
12
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water standards, and to try to restore the .bedrock ground
water at the landfill to drinking water standards.
15
We also established objectives for the surface water;
that are to protect.ofrsite surface water, specifically the
16
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Connecticut River by preventing the occurrence of landfill
impacted seeps; to meet the federal and state standards in any
.dischargethat may be necessary to the Connecticut River; and
to provide long term monitoring to ensure that the Connecticut
River is protected.
I should note the long term monitoring is
also the component of sort of every objective that is
mentioned.
There is also generic objectives just for the landfill~
Very quickly, what they are is to prevent water to come in
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contact with the waste material; to try to prevent the
generation of any future seeps; to control landfill gas; to
try to prevent the migration of contaminated ground water
outside the landfill boundary; to minimize the potential of
any slope failures; to prevent any direct contact with the
landfill debris material.
I should note that all these
pbj~ctives were incorporated in the decision that was made
..
last year which is to cap the landfill, and that is how we.
feel ~hese are being addressed.
.
,
\NOW, to provide numerical guidance on the clean up and
focus on~the contaminants that were most frequently detected
j
and identified as our contaminants of concern, EPA developed a
list of. compounds or a chart of compounds for clean up.
One
thing to note, just because .a compound isn't on here doesn't
mean it will be ignored.
There will be periodic testing for a
variety of additional compounds.
At the end of the clean up
process, for it to be deemed successful, the ground water will
have to meet all federal and state drinking water standards.
These were the ones we focused on and, in part.icular '. there'
were two; Tetachloroethene and Xylene, where there are two
standards proposed.
The reason there is two is these are
standards where there is a marked difference between the EPA
and the state standards, the state standard being the lower
The EPA believes the federal standard is. protective. and
one.
what we're providing here is an opportunity that if the state
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dces change the s~andards in the future to the federal
2
standard, that they would then become the clean up standard
3
for the site.
However, in no case would we ever allow a
4
standard less stringent than the federal drinking water
5
standard.
6
Once all this is done you've got a risk assessment,
7
you~ve got an RI, you've pulled together your objectives for'
8
clean up, you perform a feasibility study.
A feasibility
9
study. takes your alternative that you've pulled together to
10
.
. try t~\.evaluate what options you have to deal with the site,
and the evaluation is based on nine criteria. There are two
j
stars before the first two criteria. For the EPA to recommend
11
12
13
any alternativ~, it. must protect human health and the
environment anq be compliant with federal and state laws and
15
regulations.
We then use long term effectiveness, reduction
16
in the toxicity, mobility or volume through treatment, short
17
term effectiveness, implementability and cost, is the
balancing factors to figure out which of the alternatives meet
the first two criteria best, are our best choices.
Th,e ne}(t
two criteria are used as part of our comment process.
We
actively seek the state's input and recommendation and the
reason we're here tonight, the reason there is a public
comment process, we look for the community's acceptance for
the pr,?posa,l.
For this site there were three alternatives given
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se~ious conside~ation.
The first, and this one is required in
all feasibility analyses, is to take no furthe~ action,
essentially, for us to leave, go. away .and decla~e the site
done.
All's we would do is collect monitoring data over the
next 30 years, do an assessment of the site eve=y five years,
but we would require no further maintenance of any existing
controls at the site.
The cost of this would be $110,000 a
yea~ and over 30.years, the NPV at seven percent would be
1.4 million dollars.
.
., .
~\A~other alternative that was evaluated for
consideration was to, what's called management and ground
i
water extraction.
This one would essentially take all the
components. that were discussed in the preferred alternative
. .
but add, the installation of several bedrock extraction wells,
most likely along Route 5 right here.
These wells would then
treat the ground water and most likely the ground water wo~ld
be treated for metals and volatile organic compounds, and be
discharged in the Connecticut River in compliance with federal
and state standards.
Wi~in this alternative s~me of the
, .
issues that really came out were the number and location of
wells would need to be determined by extensive pump tests and
predesiqned testing.
The topography out here is very steep
and would be very difficult to locate wells and success in
extracting and treating qroundwateris something that is
subject to quite a bit of debate these days.
Under this
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alternative it is estimated that ground water clean up could
2
be met within 13 years, annual operating cost wculd be
3
$600,000 in the long term cost over 30 years would be 6.5
4
million dollars.
5
The third alternative then was evaluated as discussed
6
before, is called natural restoration and management of
7
exi~ting site controls.
I won't go through the components
8
again, theY've., already been discussed.
The key to focus on
9
,for t~e preferred alternative is that ground water clean up
levels\..a~e expected to be reached within 15 years of
10
11
completion 'of the cap, the annual operating costs are
i
estimated to be $392,009 with a 30 year cost over seven
12
13
percent of 2.9 million dollars.
14
Now, as I,said this second alternative is EPA's
15
proposal.
Reasons that we have proposed that alternative are
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that we believe it's protective of human health and the
17
environment by restoring ground water to drinking water
18
standards within 15 years.
We believe it is protective of the
19
Connecticut ~iver by shutting down the lea~atethat goes ,into'
the landfill which will eliminate landfill seeps.
It will
prevent direct contact with landfill material.
It will
control the release of landfill gas; maintain water line for
the residents down below until that water is acceptable for
drinking; it collects the shallow ground water and leachate;
it has long term monitoring to confirm that restoration is
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actually being achieved; incorporates fi'le year reviews of all
2
site activities to make sure the site is protec~ive throughout
3
the environment.
This alternative will meet federal and state
4
standards.
We believe it's cost effective and the particular
5
factors that also influenced the decision is there is no
6
current exposure to the contaminated bedrock ground water;
7
that there is a water line that is currently available to
8
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9
provide drinking water to residents that were formerly in the
area ~- that are currently in the area that have contaminated
10
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water;\~~at the concept~on model supports that by examining
migration is that ground water is discharged into the
i
Connecticut River and not migrating off, further away from the
11
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site; and that there is a very low probability of the future
14
use of the bedrock ground wa.te~ in the area between the site
and the Connecticut River, except in those areas where there
15
16
are camps today.
17
One thing I also wanted to note is there's a quote here
18
and it's, quote, from federal regulations, that essentially
19
states that the Government EPA recognizes that when we say
20
we're going to use natural attenuation or natural restoration
21
it doesn't mean that we've written off the ground water or ~he
22
aquifer.
It means that we're going to rely on natural
23
processes such as biodegradation, dispersion, dilution and
24
absprption to effectively reduce contam~nation, and that
25
institutional controls such as part of the remedy, may be
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necessary until t~e time period in which clean up is achieved.
2
w~at are the next steps in the process?
These are the
3
same slides I used on July 29th 'because ,it's the same next
4
s-:eps.
Public comment period from June 30 to July 30; please
5
send any and all of your comments to myself, postmarked by
6
July 30; the meeting notes are being transcribed; once I'm
7
,thr?ugh the floor will be open for us to receive, via a
8
transcript, formal comments on our, proposal.
All comments
9
will pe addressed in a Responsiveness Summary that will be
.
10
prepa;\~d .
A Record of Decision will then be prepared by EPA.
11
, We will then issue a news release acknowledging whether the
j
proposed alternative was selected, and whether there were any
12
13 '
changes to that.
We'll then hold an informal meeting in t?e
fall to discuss the neXt steps after the alternative 'is
selected.
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We'll then enter negotiations with BFI to accept
the responsibility to implement the action by Record of
Decision, and the long term monitoring plan as it currently
exists will be amended based upon public comments,
requireme~ts of selected alternatives,and all the, information
we've collected to date.
I appreciate your patience, I thank you all for coming
out tonight, and with that I'd like to turn it back over to
Mary Jane to open the formal comment period.
MS. O'DONNELL:
Thank you, Ed.
In'my
introductory comment, if you wish to make a comment today I'd
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ask you to, first of all, identify yourself, your affiliation
2
with the site, and I appreciate it if you could come to the
3
front of the room so we could accurately. transcribe what your
4
comments are.
5
MR. JOHNSON:
Wayne Johnson, I'm a neighbor
6
down the road here.
After the ground water is supposedly
7
cle~rified (sic) and that, is BFI going to return out artesian
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weIrs and our pumps and so forth to the way we had them?
. 9
had ap artesian well and pump in the beginning, until they
10
\ .
were contaminated.
.... .
11
MS~ O'DONNELL:
As I mentioned at the
12
beginning of the meeting, the purpose, basically, of tonight's
meeting is just to accept comments on the preferred
13
14
We're not in ~ po~ition to comment.
However, at
alternative.
15
the conclusion of the meeting we'll be more than happy to
16
answer the qu~stion that you have.
17
MR. JOHNSON:
Okay, I'll change my
18
...
ques"'.l:0n.
What about after this last rain storm, which Ed was
19
there, all this rain water and all that washed me out, my
20
neighbors, we ended up with a lot of bad stuff, run off, bad
21
run off from the dump.
Nothing's been done yet as far as our
22
culverts are plugged.
It was supposed to be acted on very
23
quick.
24
MR. HATHAWAY: Wayne, I guess the purpose .of
this part of the meeting is to receive your ~nput fOr1nally for
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the rec~rd as t~ what your comments are on the proposal.
At
2
the end of this we'll be glad to talk to you about what's
3
going on and whateve~ concerns you have, but if you want to
4
make a statement such as, you may have made earlier, the
5
statement may be, you know, how will these things be
addressed, make a statement and it will go into the record and
6
7
we'~l formally respond to those statements in the
..
8
ResPonsiveness Summary.
Then at the end -- as soon as the
9
forma~ part is closed I'll be glad to talk to you.
10
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MR. JOHNSON:
So this meeting was sort of a
waste of:my time, then.
i
MR. HATF.AWAY:
No, these comments are going
13
to go right into the formal record.
These are going into the
14
official record.
They will be. responded to.
AS'soon as we're.
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done we'll talk to you, probably in about half an hour.
16
MR . JOh"'NSON:
I've bene rushed out so many
17
times now --
18
MS. O'DONNELL:
You stick around, we'll be
happy to answer it.
MR. JOHNSON:
What does it matter?
Everything's going to the river.
Everything's going on my
lawn.
It took eight days to get the EPA down here to check my
ground sample after the last wash out, after two more storms,
which definitely did away with some of the. contaminants.
MR. HATHAWAY:
Wayne, we're saying this is
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a very structured meeting that's here to receive formal public
2
comments --
3
MR. JOHNSON:
I shouldn't have come here,
4
actually.
I'm pretty mad.
5
M.~. VEITCH:
Wouldn't it make sense for
6
this resident -- my name is M~chael Veitch, I'm with the
7
Vermont Public Interest Research Grou~.
. .
We were awarded a
8
'.
technical assistance grant by the EPA tO,assist citizens in
,under~tanding and commenting on this particular site.
9
10
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\ ,
wouldn'~.,t ;it make sense to give this gentleman time to, at
least ask his question, even though he may not get his answer
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12
until the end of the meeting?
It seems entirely reasonable
13
that ,he be given an opportunity to ask questions that would go
14
into the record..
So, you know, give him an opportunity to ask
15
his questions and let it go into the record.
16
, MR. HATHAWAY:
We just said that, Michael,
17
we said, please ask your questions but we can't respond until
after the meeting.
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MR. JOHNSON:
So you don't want to give a
20
comment until after this meeting's closed?
21
MR. HATHAWAY:
We're not allowed to.
22
MS. 0' DONNELL:
That's correct.
23
MR. HATHAWAY:
We're not allowed to until
24
after because of' the structure of this meeting.
MR. VEITCH:
I mean, you are encouraging
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him to ask his question~
You do want to hear what he has to
2
say.
3
MS. O'DONNELL:
That;s :why we're here.
4
MR. JOHNSON:
I just saw about three things
5
back there, there's no top water run off.
Ed, you were down
6
here the other day in the main storm there, and you saw it,
7
you,smelled it, yeu stood in it.
.,
My neighbor, Huck Rummel was
8
told to get the hell out of the ~tuff because it wasn't safe.
9
That ~tuff's running right down into the river, it's running
10
\
across'. the lawns.
'\ .
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a few bails of hay
i .
I;know this
I've
The problem hasn't been cured.
You've got
11
down there.
12
thing's been going on and on and on.
13
lived there for 12 years, 14 years I've ow~ed that place.
First my water went dead because the state said, oh, it's safe
15
to build a dump up there.
Our water went bad, now
16
everything's gone bad.
I got washed out two weeks ago, got
$3500 worth of my labor and building costs into my wall, and
it's just going to happen again.
Sink holes; I can't let the kids go up in the
backyard.
I'm afraid they're going to sink down and out of
sight.
My vehicles; driving down the road, there's a culvert
that let loose down there.
I don't know if I'm going to be
driving down the road and lose my Stealth one day.
No one know's where the water's going.
No one knows
where the ground's going.
All of a sudden there's sink holes
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everywhere.
2
The public hasn't heard this stuff.
I haven't sounded
3
off yet.
I'm pre~ty damn mad about the whole situation.
I'm
4
sorry I own the place.
I wanted river frontage for enjoyment,
5
and I do have enjoyment, but, boy, what a hassle it is.
6
MR. HATHAWAY:
Thank you.
7
MR. .JOHNSON:
I can't say anything much
8
more other than you can't give the places away.
You can't
9
sell ~ place down there.
A little old lady on side of me
10
,
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trYing~~~' sell, ~,other neighbor trying to sell.
They can't
11
give their places away.
,
Eight years ago I was worth a quarter
12
of a 'million on t~e river.
I'm lucky to get thirty out of it,
13
if that; and I got a damn nice place. , I'm sorry.
That's all
;
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14
I got to say about this meeting.
I'm heading off, I think, .
15
unless you're going to respond later.
16
MS. O'DONNELL:
We'll be happy to respond
17
later, but as we said before, we have to wait until the
18
conclusion of the meeting, and in terms of how long that will
19
take, it'depends on how many people have. comments.
Any
20
additional comments?
Yes, sir, if you could just cQme forward
21
and identify yourself.
MR. MURRAY:
My name is George MUrray, and
I'm a member of a group of residents who are working with
VPIRG on the technical assistance grant, and these are our, '
concerns:
We're concerned about the use of shredded tires in
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place of sand in the d~ainage layer of the cap.
We are
2
opposed to the use of sewage sludge on the top layer.
It's
3
own potential as a pollutant makes ,its use too great a risk.
4
Also, another mud slide would make a stinking mess.
We're
5
concerned about the lack of security fencing and large obvious
6
warning signs.
We are alarmed that the trench along Route 5
7
failed to stop all the seeps.
We want ,to see more monitoring
a
wells, particularly parking lot sub ,base sampling and south of
9
the site 'as more than half the residential wells being tested
10
.
,
,
are l6~a~ed in this direction.
We are concerned about the
11
seemingly haphazard method of transporting and disposing of
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12
leachate:collected at the site in the past.
We assume that
13
steps have been taken.to improve the safety of this process as
volume of leachate will increase dramatically after closure. '
15
As a member of a group of neighbors opposed to landfill
expansion in 1988 we, feared the risk of adding 40 to 50
vertical feet to the already overflowing landfill.
The result
of this expansion can been seen now as the seep slopes are
subject to damaging mud slides and wash outs: one of which I
was a witness to and what Mr. Johnson has been talking about.
We are concerned that the cap will be difficult to erect and
maintain at such grades.
We question the lack of water
testing in Charlestown, New Hampshire.
And, finally, we are
in agreement with.VPIRG on any issues I'have not mentioned
yet~
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MS. O'DONNELL:
Thank you ve~y much.
Michael, if you could just come forward, please.' Just for the
court stenographer, if you could. just identify yourself,
again,
please.
MR. VEITCH:
My name's Michael Veitch.
I
am here representing the Vermont Public Interest Research
Gro':!p.
We were awarded a $50,000 technical assistance grant
by the EPA in October of 1993 to assist residents living near
the s~te, helping them to evaluate the accelerated clean up,
and to\.c~mment on proposals and issues of concern at the site.
VPIRG has hired John Snow Institute out of Boston, also ENSA .
i
Tri-s Division to work with us as technical advisors on this
site.
They w~ll be delivering comments of a more technical
,
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nature regarding. the proposed plan' later this evening.
I
would like to acknowledge their work ~n behalf of VPIRG and
the citizens who live in the area.
Their efforts have been
outstanding up to this point and we feel we have assembled an
exceptional' team of advisors to assist us on the site.
Even
more remarkable is the fact they have worked diligently up to
this point without having been paid; this being due to the
fact that VPIRG has, to date, only received $611 from the EPA
in reimbursement for the technical assistance grant.
We thank
our advisors for their patience and we are waiting patiently
ourselves for a quick resolution to this troublesome aspect of
the project.
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I would li~e to discuss the public process issues
2
related to clean up proposal and cornmen~ period.
While we
3
appreciate EPA's desire to restrict cO~uents at this time to
4
the proposed clean up plan, we feel that given the
5
acceleration of activities at the site and the ever increasing
6
list of issues, that it is very difficult to comment on the
7
proposed clean up without also commenting on cap design, on
8
the health risk assessment, the enviror~ental risk assessment,
9
the f~asibility study, long term monitoring plan~ public
10
.
.,
proces~ and assorted other issues which, you know, we're
, ,
hearing about new issues tonight.
I
There is a symmetry to
12
these issues that we feel we use them all together sort of a
13
proposed clean up umbrella.
For this reason, some of the
14
comments ~ade by us and by some of the tec~ical advisors this
evening will be on some of those other issues that I
15
16
mentioned.
17
VPIRG is adamantly opposed to any further contamination
of the site.
I'm speaking specifically about dioxin
. contaminated sludge proposed for the cap.. We feel that this
site has extremely steep slopes, has a history of slope
failure and a risk of not achieving adequate vegetation growth
by this winter.
And, you know, all of this together, you
know, points in the direction of another serious wash out or
failure .similar to what we witnessed a few weeks ago at the. .
site.
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,)
A~other point I would like to mention is that the risk
assessme~t and the proposed plan have assumed t~at clean
material would be used on the cap.
50 there seems to be -- I
mean, t~ere is a gap here in
terms of developing risk
assessment versus, you know, what the actual risk may end up
being based on changes in the cap design.
We're calling for
the termination of biomix experiment and we would like to see
. return to the certifiably clean. cap material to be used on the
cap t~at, you knew, were used to develop the risk assessment,
! .
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and th~ ~5 were assured as part of that process.
r:would like to speak briefly about a site visit that r
made 'earlier today; did have an opportunity to go down and
visit with the property owners.
One of the property owners
doWn in the lower road, and first of all, I feel that to refer '.
to these houses as camps is a mistake.
These are beautiful
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homes that, if were placed out in the middle of a field, would
not be classified as a camp.
The fact that they sit on the
river, r mean, that just happens to be their location.
think the EPA should reev~luate an~ r~define these
r
residences.
It's clear at least two are permanent, year round
residences and possibly a third, and I'll try to verify that
for you.
I think that this is important, and I think that the
definition or the term, camps, is kind of a -- it qives a
misleading kind of a feeling about the nature of the
residences down there and their value to their owners.
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I heard some comments made today concerning a right of
2
way into property down on that lower road.
Apparently this
3
right of way had been breached in two places.
One area where
4
wells were placed directly in the middle of the right of way,
and very recently apparently a rather large drainage ditch was
5
6
placed across the right of way.
I think this is an issue that
7
needs to be clarified.
If in fact a right of way has been
I "
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breached, I w~uld, you know, VPIRG would urge the EPA and BFI
to wo~k out some sort of agreement with the property owners.
9
10
,
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for co~p~nsation.
In'the process of our site visit I also came across
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what 'I would characterize as a drum field down this area down
13
below all along the river.
There seems to ,be an area where,
14
at some point in the past, a large quantity of 55 gallon drums
15
were dumped. . There are a number of them visible.
It appears
16
that none of them have been tested, opened up, removed or
checked.
It's not clear to us at this time if these drums sit
on property that is owned by BFI.
I, again, VPIRG would urge
the EPA to include complete evaluation of this ~rea asp~rt of
. , .
their proposed clean up plan.
Specifically, we feel that
drums should be tested, sounded, you should make a
determination how many 55 gallon drums are actually there, and
if they in fact do contain any toxic material.
case they should be removed.
Then in which
In addition, we have some concerns about the efficiency
30
ROONEY & WOOD REPORTERS, INC.
P.O. BOX 8066
BR.4.1TLEBORO. v"T 0530-1
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,)
of the fla~e.
We believe that the flare should be tested and
2
monitored by EPA.
It is clearly a treatment of the material
. 3
that 1s b~ing generated by the ~uperfund site.
For this
4
reason alone we feel that it falls under EPA's jurisdiction
5
and not the State of Vermont.
6
We feel that the impact on the Connecticut River and
7
across the river into New Hampshire have not been adequately
.,
analyzed and a~sessed as part of the clean up process.
Otir
9
techn;i.cal people will go into this in a little more detail on
10
;
this l~t~r, and our written comments should contain even more
detail. .'. ~
i
11
12
The stability of Route 5 is -- I learned today, also, a
13
very .serious issue given the fact that, again, you have
14
permanent residents living below Route 5.
I think the danger
15
of a wash out is a very real possibility.
It's our concern
16
that ground water is leaving the landfill and is actually
17
undermining the road.
There are sink holes that are actually
18
visible alongside the road.
They were visible down below the
Route 5 area, and we have had some additional concerns that an
20
investigation into Route 5 is, apparently, 'according to my
discussion with Mr. Hathaway earlier this week, apparently is
21
being conducted by the agency of transportation.
We feel that
given the fact that this is a superfund site, the material
leaving the site may have contamination ~- may be contaminated
with VOCs, may have any number of contaminants in it.
We feel
31
ROONEY & WOOD REPORTERS, INC.
P.O. BOX8066
BR.4.TTLEBORO. VT 0530~
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that, you know, any work done to assess Route 5 in terms of
2
what the problem is should be handled by technicians who are
3
trained to work around toxic chemicals, similar to what we saw
4
when you built the trench.
Everybody dressed appropriately.
5
and with, you know, all measures taken to protect the health
6
of the construction workers.
7
We urge EPA to include .in the proposed clean up plan
8
.,
9
actual steps that will clearly define a rapid response to
future landfill washouts and disturbances that are going to
10
discha'~.g~', that are going to affect property owners beyond the
11
borders of BFI.
This rapid response should include testing
12
i
for all potential contaminants within 24 hours of the event,
13
complete removal of any and all sediment and run off that
.leave .the.site, and the establishment of a forum or a.
14
15
mechanism for restitution to property owners for losses
16
associated with landfill washout.
You know, as we heard
17
earlier this evening, we've hear~ that a property owner
suffered approximately a $3500 loss as a result of this
18
washout.
It is VPIRG's position that this is a responsibility.
. ,
of BFI to provide compensation to the property owner.
It's
strictly a good neighbor policy, and I think the EPA is in an
excellent position at this point in time to help facilitate
just such a mechanism for compensation.
Those are my initial comments.
I'd like to re~erve a
little time at the end if I need it to make any additional
32
ROONEY & WOOD REPORTERS, INC.
P.O. BOX 8066 .
BR..4.TTLEBORO, VT 05304
r802i 25;.5107
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9
10
.
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comments.
MS. O'DONNELL:
Thank you, Michael.
MS. SPENCE:
My name :is Lisa Spence and I
am submitting the following verbal comments which were
developed by myself, Anne Marie Desmarais, Terry Greene and
Dr. Richard Clapp for John Snow Incorporated on behalf of
VPIREF.
I would.l.ike to raise some of the more serious issues
regar~ing the effectiveness of the remedial alternative chosen
in the\.proposed plan and the basis for development of the
out complete comments will be submitted to Ed
proposed:plan.
j
Hathaway;in writing.
It is our opinion that capping of the BFI is a
necessary .part of the remediation of this si~e.
However, this
proposed plan does not demonstrate that capping alone will
significantly reduce the migration of chemicals from the
landfill. Furthermore, we find it unacceptable for the
proposed plan to address the discharge of site contaminants to
the Connecticut River as remedial solution.
Dilution is not
considered a legitimate clean up alternative.
We are concerned that the clean up goal for arsenic, 50
micrograms per liter, is not protective of human health.
value was selected solely on the basis of the maximum
This
I
contaminant level or HCL, developed under the safe drinking
water act.
This MCL is based on technological and economic
33
ROOiVEY & WOOD REPORTERS, INC.
P.O. BOX 8066
BR.4.TTLEBORO. "705304
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considerations in addition to health risks.
A concentration
2
of arsenic equivalent to the MCL of 50 micrograms per liter in
3.
drinking water results in a risk. estimate which exceeds EPA's
4
own acceptable cancer risk by a factor of ten.
5
Chemical-specific ~~s, such as the MCL, are typically one of
6
three types of potential clean up goals.
The proposed plan
7
ign~res the two ether types.
First,
safe concentration back
8
calCulated from ~he .risk assessment, and two, background
9
-concentrations.
Use of a background concentration for arsenic
10
.
would be more appropriate.
". ;
Background arsenic concentrations
11
are available for unimpacted bedrock wells as close to the
1
landfill:as the Hit or Miss Club, and the resident wells to
12
13
the east of the landfill.
Regardless.of the alternative ch~sen, the established
14
15
clean up goals will influence the amount of time that affected
16
residents are supplied with water, and will also impact the
17
long term monitoring.
18
Defining the extent of site-related contaminant
migration is the goal of the remedial investigation and
19
20
provides the basis for the development of clean up priorities
and the definition of the site.
We are not convinced that EPA
has defined the extent of site-related contamination.
Under
CERCLA regulations, a facility, quote, that is subject to
cleanup includes, quote, any site or area where a hazardous
substance has come to be located, end quote.
Results received
34
ROONEY & WOOD REPORTERS, INC.
P. O. BOX 8066
BRA. ITLEBORO. \/T 0530-1
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., 5
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8
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10
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, 14
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24,
25
'..'
The risk assessment states that, quote, it is unlikely that a
basement would be built within bedrock, end quote, ignoring
t~e existence of some overburden, material in this area.
The
assessment also ignores the fact that bedrock is a very
efficient transport path for vapors into homes.
Part of the chosen alternative involved institutional
con~rols designed to prevent exposur~s.
There are a number ,of
ins~itutional controls considered for use at the site but it
is no~'clear that they will be coordinated and cover the
,
entir;~~~ea of impacted ground water from the Hit or Miss Club
to Rumrill Spring.
j
Much of the discussion of institutional
controls:is limited to BFI property, but the impacted site
area extends well beyond'EFI property bqun4aries.
In
addition, some of those suggested controls have not yet been
,defined or even addressed in the proposed plan, such as
barriers to restrict access to seep 6.
Although it is still our opinion that a cap on ~'1e EFI
landfill is necessary, it is also our opinion that this may be
oniy part of the remedial plan required to prevent exposure to
site related contaminants.
We would like to see additional
documentation regarding the effects of the cap on the
potential for exposure via all pathways.
In addition, during
the closure process EPA has not had to formally evaluate the
sludge proposed as cap material ,and the effects their use
would have on human and ecological health.
The importance of
36
ROOiVEY & WOOD REPORTERS, INC.
p,o, BOX 8066
BR..4.TTLEBORO. 'l,T0530~
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. '24.
evaluating proposed capping materials has been highlighted by
2
First, elevated levels of dioxins were
two recent events.
3
found in the paper sludge initially proposed as the capping
4
As a result of this finding EPA has withdrawn this
material.
5
material for consideration.
Second, during the storm on
6
June 30th soils were washed off the landfill on to Route 5,
7
and down to the residences below, illustrating one probable
8
\
This is another
. .
path for sediment. runoff from the. cap.
9
pathw~y that was not addressed in the risk assessments or
10
,
"
eValUa\e~ in the feasibility study.
In summary, in its review of the proposed plan on
11
12
behalf of VPIREF, JSI agrees that a cap is needed.
However,
13
additional studies are also needed to. address the
14
effectiveness of the cap in reducing exposure via all relevant
15
pathways; the risk assessment must be reevaluated in light of
the additional pathways; and clean up levels must be
16
17
reevaluated to look at. background and the protection of human
18
health.
19
MS. OI,DONNELL:
Thank you very much.
20
MR. GAGNON:
My name is David G~gnon.
I'm
21
with Tri-S Environmental Services of America.
We were hired
22
by VPIRG as under their TAG grant and to provide technical
assistance ~o VPIRG. .I have the following comments:
23
Were ARARs other than environmental ARARs considered? .
25
For instance, regulations should be considered that are
37
ROONEY & WOOD REPORTERS, lNC:
P.O. BOX 8066
BR.~ ITLEBORO. IT 0530.J
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6
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8
9
10
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. 14. .
15
16
17
18
19
20
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22
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.24
25
(~
i~ July for the K wells newly installed near the Ru~rill
Spring show that the northeast edge of the bedrock ground
water contamination is still undefined.
The site area has
increased significantly since the completion of the risk
assessments which provide the driving force behind this clean
up.
In addition, we have found that the human health risk
assessment for the BFI site does not adequately address all
poten~ially important exposures to the site contaminants.
It
is nO~'f~~sible to rely on the risk assessment unless all the
pathways;have been evaluated. This incomplete evaluation of
j
exposure:pathways have served to artificially focus the
feasibili~y study or FS, and proposed plan on one response
medium, bedrock ground water.
. .
However, the FS and proposed
,
. I
j
plan do not demonstrate conclusively what effect capping will
have on ground water flow and contaminant concentrations in
the bedrock aquifer.
One example of incomplete pathway assessment is the
. dismissal of household vapor pathway..
The risk assesSment
ruled out any possibility of vapors entering homes built
between Route 5 and the river using faulty logic and an
inaccurate site characterization.
The possible existence of
overburden ground water beneath these residences has been
denied and. no investigation of the overburden material in this
area has been attempted or of these homes has been attempted.
35
ROONEY & WOOD REPORTERS, INC.
P.o. BOX 8066
BRXITLEBORO. vT 05304
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designed to protect roadways.
For example, construction next
2
to road~ays must not compromise the structural integrity of
3
tr.e highway or the roadway.
Does the volume of water
4
recovered by the interceptor trench match the predicted volume
5
as determined in the design calculation of the trench?
As
6
recently demonstrated by the observation of contaminants in
7
the K wells it is clear that the contaminant plume has not
8
been fully determined.
As mentioned previously, the plume
9
definition is necessary to finalize the long term monitoring
10
.
\ .
plan. \~ireview of the Dames and Moore l€tter dated July 8,
11
1994, the attached map entitled landfill watershed areas
12
j
indicates a proposed downchute whose discharge could be a
potential route for eroded material to escape the site during
13
14
the cover stabilization period.
Was the capacity of Route 5
15
storm water control design fully evaluated to determine if the
volume of water from this down chute could be handled by the
16
17
storm water culvert on Route 5?
What was the design storm
18
event specified by the presumptive remedy for landfill
. closure?
How was the 15 years to clean site developed?
Has
this been achieved at other sites with similar contaminants
and similar situations involving bedrock?
Does the bedrock
aquifer recharge the overburden aquifer below the landfill at
its junction resulting in transport of contaminants from the
.. landfill into the overburden aquifer?
The interceptor
trenches effectiveness as a means of migrating overburden
38
ROONEY & WOOD REPORTERS, INC.
P.O. BOX 8066
BR.4.TTLEBORO. vT 0530-1
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3
4 '
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6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
c"
aquifer contamination for moving offsite has not been fully
demonstrated.
Seep 6 provides substance to the need for more
detailed evaluation of thi~ trenth.
Should it be determined
that the offsite migration of contaminated ground water cannot
be controlled by this trench, or a modification thereof, then
the SW3 alternative involving the pump and treat system should
be reconsidered as a possible added alternative to' the capping
.,
and trench system.
We feel that the issue regarding ' discharge '
to the'Connecticut River has not been adequately addressed,
.
specii\c~lly detailed fate transport analysis should be
completed assuming that the discharge is entering the river'
I
basin.
And finally, regarding the landfill gas factor
characterization as Michael Veitch mentioned earlier, this
flare is burning the discharge of'site~related chemicals from
the EFI superfund site.
Therefore, a characterization should
be conducted by EPA.
The performance test reviewed by the
Vermont Air Pollution Control Division are not adequate.
That's the' end of my comments.
MS. O'DONNELL:
Thank you.
Would anyone,
else like to make comments at this point?
I guess seeing as
there are not more comments the formal part of tonight's
hearing is now closed.
(The Hearing concluded at 8:10 p.m.)
39
ROONEY & WOOD REPORTERS, INC.
P. O. BOX 8066
BR.4.ITLEBORO. IT 053fN
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>'.
(,
2
C E R T I FIe ATE
f;~~V
3
4
I, Tamara A. Violette, Notary Public, do he~eby certify
that the foregoing pages 1 through 40 inclusive, comprise a
5
6
full, true and accurate transcript, to the best of my ability,
7
of the BFI Hearing on July 20, 1994 held at the Hit or Miss
8
.
\
Club, Route.'S,.Rockingham, Vermont.
9
10
\
.,
\
Dated
\ .j
Vermont.. ~
j
,
this 24th day of August 1994, at Williamsville,
11
12
13
14 .
. ~tNilif~ V IdJ:J:\J-
Tamara A. Violette
Professional Reporter
and Notary Public
15
16
17
18
My commission expires:
February 10, 1995
19
20
21
40
22.
23
24
2S
. ,
ROONEY & WOOD REPORTERS, INC.
P.o. BOX 8066
BRATTLEBORO, \IT 05304
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'"
APPENDIX E
ADMINI~STRATIVE RECORD INDEX
-------
<,
-
'.'
BFI Sanitary Landfill
(Rockingham)
Administrative Record
NPL Site
Current Action
Compiled: June 28, 1994
. ,
.~~
Index
.
)
Prepared by
Region I
W aste ~1anagement Division
-------
Intro.auction
This document is the Index to the Administrative Record for
the BFI Sanitary Landfill National Priorities List (NPL) site
(Current Action). A previous Administrative Record was prepared
for the public comment on the Landfill Cap during June -
September 1993. Section I of the Index cites site-specific
documents and section II cites guidance documents used by EPA
staff in selecting a response action at the site.
The Administrative Record is available for public review at
EPA Region I's Office i~ Boston, Massachusetts, and at the
Rockingham Free Public Library, 65 Westminister street, Bellows
Falls, VT 05101. This Administrative Record includes, by
reference only, all documents included in the September 13, 1993
Administrative Record for this NPL site. In addition, the design
documents for the non-time critical removal action (landfill cap)
are available at the Rockingham Free Public Library and EPA
Records Center. Questions concerning the Administrative Record
should be addressed to the ,EPA Region I site manager. The site
manager, Edward Hathaway, can be-contacted at (617) 573-5782.
The Administrative Record is required by the Comprehensive'
Environmental. Response, Compensation" and Liability Act (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act
(SARA) .
-------
,)
-,
. . (
Volume I
2.0
3..0
Volume !I
3.0
Volume III
3.0
Vol ume IV
3.0
Volume V
3.0
4.0
)
BPI sanitary Landfi~l (Rockingham)
NPL Site Administrative Record
Table of Contents
2.6
Removal Response
Work Plans and Progress Reports
3.2
Remedial Investigation (RI)
Sampling And Analysis Data
Remedial Investigation (RI)
3.2
3.6
Sampling and Analysis Data
Remedial' Investigation (RI)
3.6
Remedial Investigation (RI)
Remedial Investigation (RI) Reports
3.6
Remedial Investigation (RI)
Remedial Investigation (RI) Reports
~emedial Investigation (RI)
3.6
Remedial Investigation (RI) Reports
3.10 Endangerment Assessments
4.6
Feasibility. (FS)
-------
.J
Volume VI
~.o
Feasibility (FS)
~.6
Feasibility Study (FS) Reports
volume VII
10.0 Enforcement
10.7 EPA Administrative Order
13.0 community Relations
13.1 Correspondence
13.4 Public Meetings
-------
"
section 1:
site-specific Documents
. \. i
c
'"
-------
'J
02.06
"-
ADMINISTRATIVE RECORD INDEX
BFI SANITARY LANDFILL (ROCKINGHAM)
CURRENT ACTION
Title:
REMOVAL RESPONSE - WORK PLANS AND PROGRESS REPORTS
09/19/94
Page 1
Addressee:
Authors:
Date:
Format:
AR No.
Construction Report, Route 5 Slope Stabilization
and Seepage System - Disposal Specialists, Inc.
[Available in Records Center and Repository]
DISPOSAL SPECIALISTS, INC.
BALSAM ENVIRONMENTAL CONSULTANTS, INC.
September 10, 1993
REPORT, STUDY
02.06.1
No. Pgs: 416
Document No.
Title:
000051
Addressee:
Authors:
Date:
Format:
AR No.
Project Manual For DSI Landfill Cap.
in Records Center and Repository]
DISPOSAL SPECIALISTS, INC.
BALSAM ENVIRONMENTAL CONSULTANTS, INC.
April 25, 1994
REPORT, STUDY
02.06.2
[Available
No. Pgs: 478.
Document No. 000050
Ti.tle:
Addressee:
Authors:
Date:
Format:
AR No. .
Biomix S~il Utilization at DSI Landfill,
Rockingham, Vermont, (Revised Plan), With Cover
Letter.
EPA REGION 1
BFI ORGANICS
May 17, 1994
REPORT, STUDY
02.06.3
No. Pgs: 54
Document No.
Title:
000048
Addressee:
Authors:
Date:
Format:
AR No.
Proposed Tire Shreds Drainage Layer, Disposal
Specialists, Incorporated.
EDWARD M. HATHAWAY - EPA REGION 1
DAVID W. ANDREWS, MICHAEL A. DEYLING - BALSAM
ENVIRONMENTAL CONSULTANTS, INC.
June 6, 1994
REPORT, STUDY
02.06.4
No. Pgs: 270
Document No.
-------
Title:
Addressee:
Authors:
Date:
Format:
AR No."
ADMINISTRATIVE RECORD INDEX
BFI SANITARY LANDFILL" (ROCKINGHAM)
CURRENT ACTION
09/19/94
Page 2
Palmer Water Pollution Control Facility,
Evaluation for Disposal Specialists, Inc.,
Landfill Waste Water Discharge.
EDWARD M. HATHAWAY - EPA REGION 1
JEFFREY S. HANSEN, MICHAEL A. DEYLING - DAMES &
MOORE
June 17, 1994
LETTER
02.06.5
No. Pgs: 61
Document. No.
03.02
000020
REMEDIAL INVESTIGATION - SAMPLING AND ANALYSIS DATA
Title:
Authors:
Date:
Format:
AR No.
Title:
Addressee:
Authors:
Date:
Format:
AR No.
*Attached
August 1993 Split
ARTHUR D. LITTLE ,
August 1993
PRINTOUT
03.02.1
sampling Analytical Data.
INC.
No. Pgs: 14
Document No.
000052
000053
Title:
Addresse"e:
Authors:
Date:
Format:
AR No.
Trip Report Technical Memorandum for AugUst,
.1993, With Transmittal Letter.
EDWARD M. HATHAWAY - EPA REGION 1
MARK HEUBERGER - ARTHUR D. LITTLE, INC.
October 21., 1.993
MEMORANDUM
03.02.2
to Document
No. Pgs: 21
. Document No.
No. 000052 In 03.02
Approval of Long-Term Monitoring Plan with
. Conditions.
DERRICK D. VALLANCE
INCORPORATED
MARY JANE O'DONNELL - EPA REGION 1
January 18, 1994
LETTER
03.02.3
BROWNING FERRIS INDUSTRIES,
No. Pgs: 5
Document No.
-------
.u
03.06
Title:
Addressee:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
.BFI SANITARY LANDFILL-(ROCKINGHAM)
CURRENT ACTION
Review of August, 1993 Analytical Data.
EDWARD M. HATHAWAY - EPA REGION 1
MARK HEUBERGER - ARTHUR D. LITTLE, INC.
March 17, 1994
MEMORANDUM
03.02.4
09/19/94
Page 3
No. Pgs: 9
Document No. _000054
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Long-Term Monitoring Plan, Disposal Specialists,
Inc., Rockingham, Vermont.
DISPOSAL SPECIALISTS, INC.
BALSAM ENVIRONMENTAL CONSULTANTS, INC.
March 28, 1994
REPORT, STUDY
. 03.02.5
No. Pgs: 388
Document No.
000001
T i tl e :
REMEDIAL INVESTIGATION - REMEDIAL INVESTIGATION REPORTS
Addressee: -
Authors:
Date:
Format:
AR No.
Approval of Draft Supplemental Remedial
Investigation. Report w;i. th - Conditions.-
DERRICK D. VALLANCE - BROWNING FERRIS INDUSTRIES,
INCORPORATED
MARY JANE O'DONNELL - EPA REGION 1
March 15, -1994
LETTER
03.06.1
No. Pgs: 23
Document No.
Title:
000017
Addressee:
Authors:
Date:
Format:
AR No.
Transmittal Letter for Final Supplemental
Remedial Investigation Report with Comments,
Responses to Comments, and Proposed Resolutions. -
.EDWARD M. HATHAWAY - EPA REGION 1
JEFFREY S. HANSEN, MICHAEL A. DEYLING - BALSAM
ENVIRONMENTAL CONSULTANTS, INC.
April 20, 1994
LETTER
03.06.2
No. Pgs: 26
Document No.
-------
Title:
Addressee:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
BFI SANITARY LANDFILL" (ROCKINGHAM)
CURRENT ACTION
Supplemental Remedial Investigation Report,
Disposal Specialists, Incorporated Landfill,
Rockingham, Vermont, Volume I of III.
DISPOSAL SPECIALISTS, INC.
BALSAM ENVIRONMENTAL CONSULTANTS, INC.
April 21, 1994
REPORT, STUDY
03.06.3
No. Pgs: 381
Document No.
09/19/94
Page 4
Title:
000002
Addressee:
Authors:
Date:
Format:
AR No.
*Attached
Supplemental Remedial !nvestigation Report,
Volume II of III.
DISPOSAL SPECIALISTS, INC.
BALSAM ENVIRONMENTAL CONSULTANTS, INC.
April 21, 1994
REPORT, .. STUDY
03.06.4
to Docu!:lent No.
No. Pgs: 695
Document No.
000002 In 03.06
000003
Title:
Addressee:
Authors:
Date:
Format:
AR No.
*Attached
"Supplemental Remedial Investigation Report,
Volume" III of III. . .
DISPOSAL SPECI~LISTS, INC.
BALSAM ENVIRONMENTAL CONSULTANTS, INC.
April 21, 1994
REPORT, STUDY
03.06.5
to DocuI:lent No.
No. Pgs: 706
Document No.
00()002 In 03.06
000004
03.10
Title: .
REMEDIAL INVESTIGATION - ENDANGERMENT ASSESSMENTS
Addressee:
Authors:
Da te : "
Format:
AR No.
*Attached
Human Health Risk Assessment," Disposal
Specialists, Inc. Site, Rockingham, VT,
II. [Received During the Formal Comment
DISPOSAL SPECIALISTS, INC.
BALSAM ENVIRONMENTAL CONSULTANTS, INC.
April 7, 1993
REPORT, STUDY
03.10.1
to Document No.
No. Pgs: 121
Document No.
000057 In 05.03
V.I of
period]
-------
, J
~
\,
04.0'6
~.
Title:
Addressee:
Authors:
Date:
Format:
AA No.
*Attached
ADMINISTRATIVE RECORD INDEX
BFI SANITARY LANDFILL' (ROC~INGHAM)
CURRENT ACTION
Human Health Risk Assessment, Disposal
Specialists, Inc. Site, Rockingham, VT
II. [Received During the Formal Comment
DISPOSAL SPECIALISTS, INC.
BALSAM ENVIRONMENTAL CONSULTANTS, INC.
April 7, 1993
REPORT, STUDY
03.10,2
to Document No.
No. Pgs: 174
Document No.
000057 In 05.03
09/19/94
Page 5
V.II of
Period]
000059
Title:
Site,
Addressee:
. Authors:
Date:
Format:
AR No.
Final Report for Baseline Ecological Risk
Assessment at the BFI Rockingham Landfill
Rockingham, VT.
EPA REGION 1
ARTHUR D. LITTLE, INC.
March 14, 1994
REPORT, STUDY
03.10.3
No. Pgs: 211
Document No.
000006
FEASIBILITY STUDY - FEASIBILITY STUDY REPORTS
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Notification to Proceed with Feasibility Study.
DERRICK D. VALLANCE - BROWNING FERRIS INDUSTRIES,
INCORPORATED ..
LISA A. SPENCE - EPA REGION 1
October 6, 1993
LETTER
04.06.1
No. Pgs: 5
Document No.
Title:
Addressee:
000019
Authors:
Date:
Format:
AR No.
Approval. of Feasibility Study with Conditions.
DERRICK D. VALLANCE - BROWNING FERRIS INDUSTRIES,
INCORPORATED
MARY JANE 0 I DONNELL - EPA REGION 1
June 21, 1994
LETTER
04.06.2
No. Pgs: 4
Document No.
-------
04~09
. 05...03
Title:
Addressee:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
BFI SANITARY LANDFILL. (ROCKINGHAM)
CURRENT ACTION
09/19/94
Page 6
Final Feasibility study Report, Disposal
Specialists, Incorporated.
DISPOSAL SPECIALISTS, INC.
BALSAM ENVIRONMENTAL CONSULTANTS, INC.
June 24, 1994
REPORT, STUDY
04.06.3
No. Pgs: 498
Document No.
000007
Title:
. . .
FEASIBILITY STUDY - PROPOSED PLANS FOR SELECTED REMEDIAL ACTION
Authors:
Date:
Format:
AR No.
EPA Proposes Cleanup Plan
Landfill Superfund Site.
_EPA REGION 1
June 1994
MISCELLANEOUS
04.09.1
for the BFI-Rockingham
No. Pgs: 32
Document No. .000063
Title:
RECORD OF DECISION - RESPONSIVENESS SUMMARIES
Format:
AR No.
Responsiveness Summary, EPA Region I ( )
(Filed and Included as an Appendix to Entry 1 in
5.4 Record of Decision].
05.03.1
Document No.
000065
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Comments on the U.S. EPA Proposed Plan for the
Disposal Specialists, Inc. Landfill, Rockingham,
Vermont. [Received During Formal Comment Period]
EDWARD M. HATHAWAY,.. EPA REGION-1 .
MARCEL A. GUAY, MICHAEL A. DEYLING - DAMES &
MOORE
July 29, 1994
LETTER
05.03.2
No. Pgs: 3
Document No.
-------
/ ,
Title:
L'
Addressee:
Authors:
Date:
Format:
AR No.
ADMIHISTRATIVE RECORD INDEX
BFI SANITARY LANDFILL. (ROCKINGHAM)
CURRENT ACTION
09/19/94
Page 7
Comments on Proposed Plan for VPIREF Tag Group.
[Received During the Formal Comment Period]
EDWARD M. HATHAWAY - EPA REGION 1
MICHAEL VEITCH - VT PUBLIC INTEREST RESEARCH
GROUP, INC.
July 29, 1994
LETTER .
05.03.3
No. Pgs: 11
Document No.
000060
Title:
Plan Developed for VPIREF
During the Formal Comment
Comments on Proposed
Tag Group. [Received
Period]
Addressee: EDWARD M. HATHAWAY -
Authors: LISA A. SPENCE, ANNE
RICHARD CLAPP - JOHN
Date: July 29, 1994
Format: . MISCELLANEOUS
AR No. 05.03.4
*Attached to Document No.
EPA REGION 1
MARIE DESMARIS, TERRY GREEN,
SNOW INSTITUTE
No. Pgs: 39
Document No.
000060 In 05.03
000061
Tit1.e:
Addressee:
Authors:
Date:
Format:
AR No.
*Attached
BFI Superfund Feasibility Study Comments.
[Received During the Formal Comment Period]
MICHAEL VEITCH - VT PUBLIC INTEREST AND RESEARCH
FUND
DAVE GAGNON, DAN FITZ.GERALD - ENSA, TRI-S
DIVISION
August 11, 1994
MEMORANDUM
05.03.5
to Document No.
No. Pgs: 4
Document No.
000060 In 05.03
000062
05.04 RECORD OF DECISION - RECORD OF DECISION
Title: Record of Decision for BFI (Rockingham) Landfill,
EPA Region 1 ( ) .
Format:
AR No. 05.04.1 Document No. 000066
-------
10.07
ADMINISTRATIVE RECORD INDEX
'BFI SANITARY LANDFILL '(ROCKINGHAM)
CURRENT ACTION
Title:
ENFORCEMENT - EPA ADMINISTRATIVE ORDERS
09/19/94
Page 8
Authors:
Date:
Format:
AR No.
Administrative Order By Consent for Removal
Action, In the Matt~r of BFI Rockingham Landfill
Superfund Site, Rockingham, Vermont.
PAUL G. KEOUGH - EPA REGION 1
September 24, 1993
LITIGATION
10.07.1
No. Pgs:92
Document No.
13.01
000015
Title:
COMMUNITY RELATIONS - CORRESPONDENCE
Addressee:
, Authors:
Pate: .
Format:
AR No.
Request to Delay Deadline for Comments on
Long-Term Monitoring Plan from VPIREF TAG Group.
EDWARD M. HATHAWAY - EPA REGION 1 .
JOAN MULHERN - VT PUBLIC INTEREST RESEARCH GROUP,
INC.
,January 2,' 1994 ,
LETTER
13.01.1
No. Pgs: 1
Document No.
Title:
000046
Addressee:
Authors:
Date: "
Format:
AR No.
Letter with Attached Table of Major Documents for
BFI-Rockingham Landfill Available for Review at
PUblic Library.
MICHAEL VEITCH - VT PUBLIC INTEREST RESEARCH
GROUP, INC.
EDWARD M. HATHAWAY - EPA REGION 1
January 18~ 1994
. LETTER'
13.01.2
, No. Pgs: 2
. Document No.
Title:
000045
Addressee:
Authors:
Date:
Format:
AR No.
Transmittal Letter for Remedial Investigation
Report and Long-Term Monitoring Plan as Requested
by VPIRG.
DAVE GAGNON - ENSA, TRI-S DIVISION
EDWARD M. HATHAWAY - EPA REGION 1
January 20, 1994
LETTER
13.01.3
No. Pgs: 1
Document No.
-------
"
Title:
<:
.J
Addressee:
Authors:
Date:
Format:
AR No.
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Title:
Addressee :.
Authors:
Date:
Format:
AR No.
ADMINISrRATIVE RECORD INDEX
BFI SANITARY LANDFILL' (ROCKINGHAM)
CURRENT ACTION
09/19/94
Page 9
Transmittal Letter for Human Health Risk
Assessment and Engineering Evaluation and Cost
Analysis as Requested by VPIRG.
TERRY GREEN - JOHN SNOW INSTITUTE
EDWARD M. HATHAWAY - EPA REGION 1
January 20, 1994
LETTER
13.0;1...4
No. Pgs: 1
Document No.
000044
Letter Concerning Delayed Revision of Long-Term
Monitoring Plan and Schedule of Activities.
MICHAEL VEITCH - VT PUBLIC INTEREST RESEARCH
GROUP, INC.
EDWARD M. HATHAWAY - EPA REGION 1
March 16, 1994
LETTER
13.01.5
No. Pgs: 3
Document No.
000042
'Action Items - Recommendations, Based on. 3/29/94
Site Inspection., , . .
MICHAEL VEITCH - VT PUBLIC INTEREST RESEARCH
GROUP, INC.
DAN FITZGERALD, DAVE GAGNON - ENSA, TRI-S
DIVISION
April 4, 1994
MEMORANDUM
13.01.6
No. Pgs: 2
Document No.
000041
Response to Initial 'Concerns of VPIRG Tag Group,
Including Attached Analytical Results.
MICHAEL VEITCH - VT PUBLIC INTEREST RESEARCH
GROUP, INC.
EDWARD M. HATHAWAY - EPA REGION 1
April 8, 1994
LETTER
13.01.7
No. Pgs: 19
Document No.
000039
-------
Title:
Addressee:
Authors:
Date:
Format:
,AR No.
ADMINISTRATIVE RECORD INDEX
BFI SANITARY LANDFILL'(ROCKINGHAM)
CURRENT ACTION
09/19/94
Page 10
Memorandum Instructing Visitors of Procedures on
Visiting the Site, with Attached Schedule of
Upcoming Activities.
BRIAN WOODS - VT DEPARTMENT ENVIRONMENTAL
CONSERVATION
EDWARD M. HATHAWAY - EPA REGION 1
April 9, 1994
MEMORANDUM
13.01.8'
No. Pgs: 2
Document No.
Title:
000038
Addressee:
Authors:
Date:
Format: '
AR No.
VPIRG Tag Group Action Items Based on April 8,
1994 Conference Call.
MICHAEL A. DEYLING - BALSAM ENVIRONMENTAL
,CONSULTANTS, INC.
EDWARD M. HATHAWAY - EPA REGION 1
';pril 11, 199,4
LETTER
13.01.9
No. Pgs: 2
Document No.
Title: :
000036
Addressee:
Authors:
Date:
Format:
AR No.
4/08/94 'BFI/Superfund Conference Call Follow-up,'
Concerning Installation of Perimeter Fence,
Leachate Testing, and Exposed Seep.
EDWARD M. HATHAWAY - EPA REGION 1
MICHAEL VEITCH - VT PUBLIC INTEREST RESEARCH
GROUP, INC.
April 11, 1994
MEMORANDUM
13.01.10
No.' Pgs: 2
Document No.
Title:
000037
Addressee:
Authors:
Date:
Format:
AR No.
FOllow-up Comments on Conference Call, Including
Fencing, Well Monitoring, Seep Runoff on Putney
Paper Lagoon Sludge Testing.
EDWARD M. HATHAWAY - EPA REGION 1
MICHAEL VEITCH - VT PUBLIC INTEREST RESEARCH
GROUP, INC.
April 24, 1994
MEMORANDUM
13.01.11
No. Pgs: 1
Document No.
-------
(~
Title:
\ J
Addressee:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
BFI SANITARY LANDFILL. (ROCKINGHAM)
CURRENT ACTION
09/19/94
Page 11
Follow-Up on April 13, 1994 Town Meeting,
Concerning the Use of Paper Sludge, Sewage
Sludge, and Shredded Tires for Cap Construction.
EDWARD M. HATHAWAY - EPA REGION 1
JSI, VPIRG
April 26, 1994
MEMORANDUM
13.01.12
No. Pgs: 2
Document No.
Title:
000034
Addressee:
Authors:
Date:
Format:
AR No.
Transmittal Letter for Biomix Reports, Dioxin
Testing Information, and Schedule of Site
Activities.
LISA A. SPENCE - ENVIRONMENTAL HEALTH SCIENCE
EDWARD M. HATHAWAY - EPA REGION 1
April 28, 1994
LETTER
13.01.13
No. Pgs: l'
Document No. - 000033
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Response to VPIRG Regarding Use of Sewage Sludge.
MICHAEL VEITCH - VT PUBLIC INTEREST RESEARCH
GROUP, INC.
EDWARD M. HATHAWAY - EPA REGION 1
May 5, 1994
LETTER
13 . 01. 14
No. Pgs: 2
Document No.
Title:
000031
. Addressee.: .
Authors:
Date:
Format:
AR No.
Summary of Private Water Supply Wells and Well
Construction Details in Vicinity of DSI Landfill,
with Transmittal Letter.
DAVE GAGNON - ENSA, TRI-S DIVISION
EDWARD M. HATHAWAY - EPA REGION 1
May 5, 1994
MISCELLANEOUS
13.01.15
No. Pgs: 3
Document No.
Title:
000032
Addressee:
Authors:
Date:
Format:
AR No.
Letter Expressing Concern about Sampling Event
Scheduled to Occur During High Water Conditions.
EDWARD M. HATHAWAY - EPA REGION 1
JEFFREY S. HANSEN, MICHAEL A. DEYLING - DAMES &
MOORE
May 11, 1994-
LETTER
13.01.16
No. Pgs: 2
Document No.
..,
-------
Title:
Addressee:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
BFI SANITARY LANDFILL. (.ROCKINGHAM)
CURRENT ACTION
09/19/94
Page 12
Letter Explaining Sampling and Analysis
Procedures for CPM Mill Short Paper Fiber
Material.
MICHAEL VEITCH - VT PUBLIC INTEREST RESEARCH
GROUP, INC.
EDWARD M. HATHAWAY
May 16, 1994
LETTER
13.01.17
EPA REGION 1
No. Pgs: 1
Documen"t No.
Title:
000029
Addressee:
Authors:
Date:
Format:
AR No.
Letter Regarding ~osting of Signs at Disposal
Specialists, Inc.
EDWARD M. HATHAWAY - EPA REGION 1
DAVID W. ANDREWS, MICHAEL A. DEYLING - DAMES &
MOORE
May 17, 1994
LETTER
13.01.18
No. Pgs: 1
Document No.
Title:
000028
Addressee:
Authors:
Date:
Format:
AR No.
Update of Issues. Since April 8, 1994 Confer.ence
. Call and May 18, 1994 Public Meeting, Including
Attached Table on SVOC Results.
MICHAEL VEITCH - VT PUBLIC INTEREST RESEARCH
GROUP, INC.
EDWARD M.HATHAWAY - EPA REGION 1
May 25, 1994
LETTER
13.01.19
No. Pgs: 5
Document No.
Title:
000027
Addressee:
Authors:
Date:
Format:
AR No.
Transmittal Letter For 1993 Fact Sheets and
Action Memorandum for the Landfill Cap..
LISA A. SPENCE - ENVIRONMENTAL HEALTH SCIENCE
EDWARD M. HATHAWAY - EPA REGION 1
May 26, 1994
LETTER
13.01.20
No. Pgs: 1
Document No.
-------
, J
-,
. )
Title:
Addressee:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
.BFI SANITARY LANDFILL' (ROCKINGHAM)
CURRENT ACTION
09/19/94
Page 13
Letter Concerning the Use of Shredded Tires and
Biomix on the BFI-Rockingham Landfill. .
MICHAEL VEITCH - VT PUBLIC INTEREST RESEARCH
GROUP, INC.
EDWARD M. HATHAWAY - EPA REGION 1
May 26, 1994
LETTER
13.01.21
No. Pgs: 2
Document No.
Title:
000026
Addressee:
Authors:
Date:
Format:
AR No.
Technical Comments Concerning the Long-Term
Monitoring Plan, with Transmittal Memo Dated May
29, 1994, to Edward Hathaway, EPA Region I.
MICHAEL V~ITCH - VT PUBLIC INTEREST RESEARCH
GROUP, INC.
LISA A. SPENCE, DAVE GAGNON, DAN FITZGERALD -
JOHN SNOW INSTITUTE AND ENSA
May 30, 1994
MEMORANDUM
13.01.22
No. Pgs: 7
Document No.
Title:
000023
Addressee:
Authors:
Date:
Format:
AR No.
Request for YPIRG TAG Group Response on Changes
to the Biomix Proposal Which Includes Sampling
and Analysis.
MICHAEL VEITCH - VT PUBLIC INTEREST RESEARCH
GR€>UP, INC.
EDWARD M. HATHAWAy - EPA REGION 1
June 3, 1994
.LETTER
13.01.23
No. Pgs: 2
Document No.
Title:
000021
Addresse~:
Authors:
Date:
Format:
AR No.
( ..
Memorandum with Attached Table of Action Items
from the Technical Assistance Grant Team for the
BFI/Rockingham Landfill.
EDWARD M. HATHAWAY - EPA REGION 1
MICHAEL VEITCH - VT PUBLIC INTEREST RESEARCH
GROUP, INC.
June 15, 1994
MEMORANDUM
13.01.24
No. Pgs: 5
Document No.
000024
~
-------
Title:
Addressee:
Authors:
Date:
Format:
AR No..
ADMINIS~RATIVE RECORD INDEX
BFI SMiITARY LANDFILL. (ROCKINGHAM)
CURRENT ACTION
09/19/94
Page 14
Memo Concerning No Response to "Action Items from
the Technical Assistance Grant Team for BFI
Landfill" Memo of June 15.
EDWARD M. HATHAWAY - EPA REGION 1
MICHAEL VEITCH - VT PUBLIC INTEREST RESEARCH
GROUP, INC.
June 22, 1994
MEMORANDUM
13.01.25
No. Pgs: 1
Document ;No.
Title:
000022
Addressee:
Authors: .
Date:
Format:
AR No.
Response to List of
to the Start of Cap
MICHAEL VEITCH - VT
FUND
EDWARD M. HATHAWAY
June 22, 1994
LETTER
13.01.26
Items to be Addressed Prior
Construction.
PUBLIC INTEREST AND RESEARCH
- EPA REGION 1
No. Pgs: 5
Document No.
13.04
000056
Title:
COMMUNITY RELATIONS - PUBLIC MEETINGS
Date:
Format:
AR No.
Summary of Public Meeting, BFI-Rockingham
Landfill, Held at the Hit or Miss Club,
Rockingham, Vermont.
April 13, 1994
PUBLIC MEETING RECORDS
13 . 04 .1
No. Pgs: 9
Document No.
Title:
000009
Addressee :'
Authors:
Date:
Format:
AR No.
. Summary of May 18, 1994 Public
Rockingham Landfill Site.
EPA REGION 1
ARTHUR D. LITTLE, INC.
June 24, 1994
PUBLIC MEETING RECORDS
13.04.2
Meeting, BFI ~.
No. Pgs: 16
Document No.
-------
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,~
13.05
Title:
Addressee:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
BFI SANITARY LANDFILL' (ROCKINGHAM)
CURRENT ACTION
09/19/94
Page 15
Summary of June 29, 1994 Public Meeting, BFI
Rockingham Landfill Site, Rockingham, Vermont.
EPA REGION 1
ARTHUR D. LITTLE, INC.
August 30, 1994
PUBLIC MEETING RECORDS
13.04.3
No. Pgs: 69,
Document No.
000064
Title:
COMMUNITY RELATIONS - FACT SHEETS
Authors:
Date:
Format: '
AR No.
EPA Environmental News - EPA Awards a $50,000
Grant to the Vermont Public Interest Research
, Education Fund to Monitor Landfill Cleanup.
EPA REGION 1
October 12, ~993
FACT SHEET, PRESS RELEASE
13.05.1
No. Pgs: 2
Document No.
Title:
000013
Authors:
Date:
Format:
AR No.
EPAEnvironmental News - EPA and VTDEC Announce
Meeting for Upcoming Construction Activities at
the BFI-Rockingham Landfill Superfund Site.
EPA REGION 1
March 24, 1994
F~CT SHEET, PRESS RELEASE
13.05.2
No. Pgs: 2
Document No.
Title:
000012
Authors:
Date:
Format:
AR No.
Superfund Program Fact Sheet, Information Update
#3 - Cap Design Complete, Feasibility Study for
Ground Water Under Review. '
. EPA REGION 1 .
April 1994
FACT SHEET, PRESS RELEASE
13.05.3
No. Pgs: 12
Document No.
Title:
000008
Authors:
Date:
Format:
AR No.
EPA Environmental News - EPA and VTDEC Announce a
Public Meeting to Discuss Residential Well
Sampling and Long-Term Monitoring.
EPA REGION 1
May 5, 1994
FACT SHEET, PRESS RELEASE
13.05.4
No. Pgs: 2'
Document No.
-------
Title:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
BFI SANITARY LANDFILL.(ROCKINGHAM)
CURRENT ACTION
09/19/94
Page 16
EPA Environmental News - EPA Proposes a Plan to
Restore Bedrock Ground Water at the
BFI-Rockingham Landfill Superfund Site.
EPA REGION 1
June 15, 1994
FACT SHEET, PRESS RELEASE
13.05.5
No. Pgs: 2.
Document No.
-------
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,~
Section II
Guidance Documents
c
).
-------
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u
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Page 1
GUIDANCE DOCUMENTS
EPA guidance documents may be reviewed at the Region I
Records Center in Boston, MA.
General EPA Guidance Documents
1.
U.S. Environmental Protection Agency. Office of Water
and Waste Management. Evaluatinq Cover Systems for
Solid and Hazardous Waste, 1980. [2202]
2.
"National oil and Hazardous Substances Pollution
contingency Plan, II Code of Federal Recrulations (Title
40, Part ,'300) , 1985.
3. '
"National oil and Hazardous Substances Pollution
contingency Plan, II Federal Reqister (Vol. 55, No.
46), March 8, 1990.
4.
U.S. Environmental Protection Agency. Office of
Emergency and Remedial Response. Community Relations
in Superfund: A Handbook (Interim Version) (EPA/HW-6),
september 1983. [C017]
5.
,U.S. Enviro~nta1 Protection Agency. Office of Solid
'Waste and Emergency Resporise~ Guidance on Remedial
Investiaations under CERCLA (ComDrehensive
Environmental ReSDonse. ComDensation. and Liability
Act) (EPA/540/G-85/002), June 1985. [C035]
6.
U.s. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. Guidance on Feasibility
Studies under CERCLA (ComDrehensive Environmental
ReSDonse. ComDensation. and Liability Act)
(EPA/540/G-85/00J), June 1985. [COJ4]
7.
u.s. Environmental Protection Agency. Hazardous Waste
Engineering Research Laboratory and Office of Emergency
and, Remedial Response. Covers for Uncontrolled
Hazardous Waste sites (EPA 540/2-85/002), september
1985. [2200]
8.
u.s. Environmenta~.Protection Agency. Office of
Emergency and Remedial Response. Superfund
Federal-Lead Remedial proiect Manaqement Handbook
(EPA/540/G-87/001, OSWER Directive 9355.1-1), December
1986. (2010]
9.
u.s. Environmental Protection Agency. Office of
Ground-Water Protection. Guidelines for Ground-Water
Classification under the EPA Ground-Water Protection
-------
10.
11.
13.
14.
15.
16.
)
Page 2
U.S. Env.iron~ental Protection Agency. Office of Waste
Programs Enforcement. Data Qualitv Ob;ectives for
Re~edial Response Activities - Example Scenario: RIfFS
Activities at a Site with contaminated Soils and
Groundwater (EPA/540/G-87/004, OSWER Directive
9355.0-7B), March 1987. [2102]
U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. Draft Guidance on CERCLA
Compliance with other Laws Manual (OSWER Directive
9234.1-01), November 25, 1~87. [C178J
12.
U.S. Environ~ental Protection Agency. Office of Solid
Waste and Emergency Response. Draft Guidance on CERCLA
Compliance 'with other Laws Manual (OSWER Directive
9234.1-01), August 8,1988. [C169]
U.S. Environmental Protection Agency. Office of
'Emergency and Remedial Response. A Compendium of
Superfund Field Operations Methods (OSWER Directive
9355.0-14), December 1987. [2100]
U.S. Environmental Protection Agency. Hazardous
Evaluation Division. Laboratorv Data Validation
Functional Guidelines for Evaluatinq Orqanics, February.
1, 1988. (2114) . , .
U.S. Environmental Protection Agency. Office of
Emergency and Remedial Response. Draft Guidance on
Conductinq Remedial Investiqations and Feasibilitv
Studies under CERCLA (Comprehensive Environmental
Response. Compensation. and Liabilitv Act). March 1988.
[C021J
~.s. Environmental Protection Agency. Office of
Emergency and. Remedial Response. Interim Final
Guidance on Conductinq Remedial Investiqations and
Feasibilitv Studies under CERCLA (Comprehensive
Environmental ReSDonse. ComDensation. and Liability
Act), October 1988. [C170)
17.
Site
18.
U.S. Environmental Protection Agency. Hazardous
Evaluation Division. Laboratorv Data Validation
Functional Guidelines for Evaluatinq Inorqanics,
1, 1988. [2113J
U.S. Environmental Protection Agency. Office of
Emergency and Remedial Response. CERCLA (Comprehensive
Environmental Response. Compensation. and Liabilitv
Act) Compliance with Other Laws Manual
(-EPA/540/G-89/006, OSWER Directive 9234.1-01), August
,1988 . [ 3 0 0 2 ]
-------
'-J
,
, '
t '"
\.
)
Page 3
19.
u.s. En~ironmental Protection Agency. Office of
Emergency and Remedial Response. Guidance for
Conductinq Remedial Investiqations and Feasibility
studies Under CERCLA (Comprehensive Environmental
Response. Compensation. and Liability Act) (Interim
Final) (EPA/540/G-89/004, OSWER Directive 9355.3-01),
October 1988. (2002]
20.
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. (7000]
21.
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