PB95-963701
EPA/ROD/R01-95/101
May 1995
EPA Superfund
Record of Decision:
Parker Sanitary Landfill
(O.U. 1), Lyndon, VT
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DECLARATION FOR THE RECORD OF DECISION
Parker Landfill Superfund Site
Lyndon, Vermont
STATEMENT OF PURPOSE
This Decision Document presents the selected remedial action for
the Parker Landfill Superfund Site in Lyndon, Vermont, developed
in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended, 42
U.S.C. ~~ 9601 et. sea. and the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) as amended, 40 C.F.R.
Part 300. The Administrator for EPA-New England has been
delegated the authority to approve this Record of Decision (ROD).
'The State of Vermont has concurred with the selected remedy.
STATEMENT OF BASIS
This decision is based on the Administrative Record which has
been developed in accordance with Section 113(k) of CERCLA and
which is available for public review at the Cobleigh Public
, Library, Lyndonville, Vermont, and at the EPA - New England Waste
Management Division Records Center in Boston, Massachusetts. The
Administrative Record Index (Appendix D to the ROD) identifies
each of the items comprising the Administrative Record upon whith
the selection of the remedial action is based.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from,this
Site, if not addressed by implementing the response action,
selected in this ROD, may present an imminent and substantial
endangerment to the public health or welfare or to the
environment.
DESCRIPTION OF THE SELECTED REMEDY
This ROD sets forth the selected remedy for the Parker Landfill
Superfund Site, which includes both source control and management
of migration components to obtain a comprehensive remedy.
The major components of the selected remedy include:
.
Multi-layer (or "composite barrier") caps on the SWDAand
three IWS areas. An active gas collection system will be
installed in IWS 2. The type of gas collection system for
the'SWDA and IWS 1 and 3 will be determined during design.
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.
replaced, preferably' on-site.
.
A source control groundwater extraction and treatment system
designed to contain contamination at the source (Landfill
and IWS areas) and allow for the natural restoration of the
downgradient aquifers. Extraction wells will be placed in
both overburden and bedrock. Specific treatment
technologies and method of discharge of treated wat'er will
be determined during the design phase.
.
Institutional controls will be established to protect the
capped areas and to prevent the use of groundwater
potentially impacted by the Site, and to inform future
purchasers of property of the groundwater restrictions
associated with the property. Restrictions on the use of
groundwater will include the current contaminant plume and a
buffer zone.
.
Long-term monitoring to evaluate the 'performance of the
groundwater treatment system and the overall effectiveness
of the remedy. '
A review of the Site every five years after the initiation
of the remedial action to assure that the remedial action
continues to protect-human health and the environment.
DECLARATION
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 satisfies the statutory
preference for remedies that utilize treatment as a principal
element to reduce the toxicity, mobility, or volume of hazardous
substances. In addition, this remedy utilizes permanent
solutions an~ alternative treatment 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.
:~ p' , \
Date'
/
'1 lc,q\
)
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ENVIRONMENTAL PROTECTION AGENCY
REGION I .
RECORD. OF DECISION
PARKER LANDFILL SUPERFUND SITE
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Contents
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
XI.
XII.
XIII.
PARKER LANDFILL SUPERFUND SITE
TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION. .. .
. . . . .
SITE HISTORY & ENFORCEMENT ACTIVITIES
A.
B.
. . . . .
Land Use & Response History
Enforcement History. . . .
. . . . .
. . . . . .
. . . . .
COMMUNITY PARTICIPATION.
. . . . .
SCOPE & ROLE OF OPERABLE UNIT OR RESPONSE ACTION
SUMMARY OF SITE CHARACTERISTICS.
. . . . .
. . . . .
SUMMARY OF SITE RISKS. .
. . . .
. . . . .
. . . . .
DEVELOPMENT AND SCREENING OF ALTERNATIVES.
A.
B.
. . . . .
Statutory Requirements/Response Objectives
Technology and Alternative Development
and Screening. . . . . . .
. . . . .
DESCRIPTION OF ALTERNATIVES.
. . . . . .
. . . . . .
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES.
A. Eva1uation Criteria. . . . . . . . . . . . . . .
B. Summary of the Comparative Analysis. . . . . . .
X.
The Selected Remedy is Protective of Human
Health and the Environment . . . . . . . .
The Selected Remedy Attains ARARs . . . . . . . .
The Selected Remedial Action is Cost Effective
The Selected Remedy Utilizes Per.manent Solutions
and Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable. . 52
The Selected Remedy Satisfies the Preference
for Treatment as a Principal Element
THE SELECTED REMEDY . .
. . . .
. . . . . .
. . . . .
A.
B.
Interim Groundwater Cleanup Levels. . . . . . . .
Description of Remedial Components. . . . . . . .
STATUTORY DETERMINATIONS
. . . . . .
... . . .
A.
B.
C.
D.
E.
DOCUMENTATION OF SIGNIFICANT CHANGES
. . . . .
STATE ROLE
.............
paere Number
1
3
3
4
5
6
7
1.3
18
18
19
20
25
25
27
35
35
39
47
47
48
51
54
55 .
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APPENDICES
APPENDIX A
APPENDIX B
TABLES AND FIGURES
APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARS)
STATE OF VERMONT DECLARATION OF CONCURRENCE
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
ROD DECISION SUMMARY
MARCH 1995
I.
SITE NAME, LOCATION AND DESCRIPTION
A.
General Description
The Parker Landfill Superfund Site (the Site), is located on Lily Pond Road
in the southeast portion of the Town of Lyndon, Caledonia County, Vermont
(Append~x A, Figure 1). The Landfill occupies approximately 25 acres of a
75 acre parcel on the southern side of Lily Pond Road, approximately 0.2
miles southeast of Lily Pond. The Landfill contains a Solid Waste Disposal
Area' (SWDA) and three smaller industrial waste areas (IWS Areas) (Appendix
A, Figure 2). IWS 1 and IWS 2 are immediately adjacent to the SWDA; IWS 3
is a more remote location to the east of the SWDA,. The general vicinity of
the Site is referenced in the following United States Geological SurVey
(USGS) 7.5' Series Quadrangles: Lyndonville,VT, 1986 and Burke Mountain,VT,
1988.
Three mobile home communities and seven single family homes are located to
the north of the Parker Landfill. A combination of pasture land, crop land
and woodlands are located to the north of Lily Pond. A hilly wooded area
is located to the east of the Site. Pasture land, crop land and woodlands
are located to the south of the Landfill. A private school and a nursing
home are located .5 miles south of the Site. Woodlands and approximately
forty residential homes are located to the west of the Landfill.
An unnamed stream traverses the Site, joins with two larger unnamed streams
immediately southeast of the Landfill, and flows south and southwest to the
Passumpsic River which is located approximately 0.5 mile southwest of the
Site. The Passumpsic River has been classified as Class B which should be
managed to maintain a level of quality compatible with good aesthetic
value; high quality habitat for aquatic biota, fish, and wildlife; public
water supply with filtration and disinfection; irrigation- and other
agricultural uses; swimming, and recreation.
A more complete description of the Site can be found in the Remedial
Investigation Report (May 2, 1994) in Section 1.
B.
Geology and Hydrogeology
The Site area is underlain by four major surficial geologic depQsits. An
esker (a linear landform resulting from deposition by glacial meltwaters),
located to the west of the Landfill, consists of coarse to medium sand,
gravel, and cobbles in graded and cross-bedded deposits. An esker delta
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
deposit, consisting of cross-bedded coarse to fine sand and gravel, trends
west to east just south of the Landfill. A Proximal Unit, consisting of
medium to fine sand and silty fine sand, extends in an easterly direction
from the esker. This Proximal Unit is extensive throughout the area under
investigation and underlies the SWDA and IWS areas. A Distal Unit,
consisting of very fine sand, silt, and clay overlies the lower Proximal
Unit and is overlain by an upper Proximal Unit in the immediate vicinity of
the SWDA, IWS I, and IWS 2. Both the Proximal and Distal Units pinch out
against the steeply rising bedrock just east of the Landfill.
The surficial deposits are underlain by two fractured bedrock formations.
The Waits River Formation, to the west, consists of a calcarious phyllite.
The Gile Mountain Formation, to the east, consists of a siliceous phyllite.
The contact of these two formations is gradational and is located .
immediately east of the SWDA. .
The Site contains three groundwater flow paths. The upper portion (upper
Proximal) of the aquifer underlying the Site has a southwesterly
groundwater flow direction. Tpe lower portion (Proximal) of the aquifer
exhibits a regional groundwater flow in a westerly direction. The
fractured bedrock aquifer exhibits groundwater flowing in a .
south/southwesterly direction towards the Riverside School (see Figure 2) .
Shallow groundwater flow in the upper Proximal portion of the aquifer at
IWS 3 is southwest toward IWS 2. Flow in the lower Proximal unit, the
principal water-bearing unit underlying much of the Site, is to the west-
southwest. It is believed that groundwater flow in the fractured bedrock
is generally south/southwest and could be related to a fracture zone along
the eastern margin of the SWDA. Groundwater in the vicinity of the Site is
classified by the State of Vermont as Class III Ground Waters which are
defined as suitable as a source of water for individual domes,tic drinking
water supply, irrigation, agricultural use,' and general industrial and
commercial use. '
According to the Groundwater Favorability Map of the Nulhegan-Passumpsic
River Basin, VT (Vermont Department of Water Resources and USGS, 1967), the
Passumpsic River from St. Johnsbury north through Lyndonville and along the
East and West Branches of the Passumpsic are "areas underlain by thick
deposits of coarse grained stratified glacial drift (which) have excellent
groundwater potential. (They are) ,suitable for exploration to locate wells
that should yield sufficient quantities of water to meet municipal and
industrial requirements. Deposits are thinner and wells would be less
productive along the margins of these areas."
The Village of Lyndonville water supply well, to the north of Lyndonville,
has been contaminated. Although groundwater from this well is now being
treated prior to distribution, there are limited areas in the vicinity of
Lyndon which are suitable for future expansion of this water system.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
The Passumpsic River from St. Johnsbury to East Haven is one of the few
areas in the region which has excellent potential for the development of
water supplies with sufficient yield for municipal and industrial uses.
This area is underlain by thick deposits of course stratified glacial
drift.
The Village of Lyndonville supplies water to the residences north and west
of the Site and to five residences and a school directly southwest of the
Landfill. Four residences directly downgradient of the Landfill utilize
private wells, as do residences further southeast along Red Village Road.
Presently, the area surrounding the Landfill is a
pasture, and wooded areas. Continued residential
around the Landfill in the future. A subdivision
directly south of the Landfill.
mixture of residential,
development is expected
is proposed' for the area
Additional information about the geology and hydrogeology of the Site area
can be found in Section 3 of the Remedial Investigation Report (May 2,
1994) .
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A.
Land Use and Response History
The area surrounding the Parker Landfill is composed of rural residential,
wooded, and agricultural land. Residential development has been ongoing to
the west and south of the Landfill over the last twenty years. It is
expected that the area to the west, southwest, and south of the Landfill
will be developed for residential use in the future. A subdivision has
been proposed for the land immediately southwest of the Landfill. It is
not expected that the steep, wooded land directly to the east of the
Landfill will be developed as a residential area.
The current Landfill was approved as a disposal facility for solid waste in
. 1971. Ray o. Parker & Sons,' Inc. began operating the facility in 1972.
Prior to 1972, the disposal area was used as a sand pit and a town disposal
area.
The SWDA was used for the disposal of municipal solid waste .and, at various
times, industrial wastes. Operation of the SWDA continued until July 1992.
The three IWS areas were used solely for the disposal of industrial wastes.
IWS 1 was used from 1972 until 1977, IWS 2 was used from 1977 to 1978, and
IWS 3 was used between 1978 and 1983.
Industrial wastes disposed at the Site included trichoroethene, sodium
hydroxide, 1, 1, l-trichloroethane, acetone, lacquer and stain sludge, paint
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
sludge, tetrachloroethane, barium chloride, chromium and nickel plating
rinse waters, polyester resin, mercury, electroplating sludge and water
soluble coolants. Approximately 1,330,300 gallons of liquid industrial
wastes and 688,900 kilograms of liquid, se~i-solid, and solid industrial
wastes were disposed of at the Site between 1972 and 1983.
Nine monitoring wells were installed at the Site in 1979 by Marshfield
Engineering for the Landfill operator. Routine'monitoring of the Landfill
by the Vermont Department of Environmental Conservation (VDEC) revealed the
pr~sence of chlorinated volatile organic compounds (VOCs) in monitoring
wells at the Landfill and in the unnamed stream adjacent to the Landfill.
Follow-up sampling detected VOCs above Federal Maximum Contaminant Levels
(MCLs) in five private wells south of the Landfill. VDEC subsequently
installed additional monitoring wells in this area (1984)' and mini-
peizometers in the unnamed stream. .
In 1987, a private contractor, ERT, on behalf of Vermont American
Corporation and under the oversight of the Vermont Agency of Environmental
Conservation, completed an investigation of IWS 2. .
In June 1987, Vermont American Corporation voluntarily installed wellhead
treatment systems on five residential wells where contaminant levels.
exceeded MCLs. These treatment systems were operated by Vermont American,
under the oversight of VDEC, until 1991, when six residences were connected
to the Lyndonville water supply. The Vermont Department of Health has
regularly monitored all of the residential wells downgradient of the
Landfill along Lily Pond and Red Village Roads.
VDEC completed a Preliminary Assessment/Site Evaluation in 1985, and EPA
proposed the Site for listing on the National Priorities List on June 21,
1988. On February 16, 1990, the Parker Landfill Site was added to the
National Priorities List.
A Remedial Investigation/Feasibility Study (RI/FS) was begun at the Site in
1990 and completed in 1994. The EPA completed a Baseline Risk Assessment
in 1993.
A more detailed description of the Site history can be found in Section 1
of the Remedial Investigation Report (May 2, 1994).
B.
Enforcement History
In February 1985, VT AEC informed four parties of their responsibility for
performing investigative work and remedial actions at the Site. The
parties initially declined and the Vermont Attorney General's office
prepared to file a lawsuit against t~em. Vermont American agreed to
proceed with investigative and remedial actions and their contractor began
a remedial investigation ~f IWS 2 in November of 1987. Investigative work
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
under State oversight was halted when the Site was proposed for the
National .priorities List.
On April 27, 1990, EPA notified twelve parties who either owned or operated
the facility, generated wastes that were shipped to the facility, arranged
for the disposal of wastes at the facility, or transported wastes to the
facility of their potential liability with respect to the Site.
Negotiations commenced with these potentially responsible parties (PRPs) at
that time regarding the settlement of the PRP's liability at the Site.
On Ju~y 30, 1990, EPA entered into an Administrative Order By Consent for
the Remedial Investigation/Feasibility Study with four of the PRPs. These
four PRPs also agreed to reimburse EPA and the State of Vermont for a
portion of their past costs through a Cost Recovery Administrative
Agreement. .'
Pursuant to the Administrative Order By Consent, the settling PRPs retained
a contractor and conducted the RI/FS under EPA oversight.
Several of the PRPs have been active in the remedy selection process for
this Site. Technical comments by several of the PRPs were submitted in
writing and presented at the public hearing during the public comment
period. The PRP comments are included in the Administrative Record and
summarized in the Responsiveness Summary.
III. COMMUNITY PARTICIPATION
Throughout the Site's history, community concern and involvement has been
fairly low. 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 March 6, 1991, EPA released a community relations plan which outlined a
program to address community concerns and keep citizens informed about and
involved in activities during the remedial process. On April 4, 1991, EPA
held an informational meeting in Lyndonville, Vermont to describe the plans
for the Remedial Investigation and Feasibility Study. On June 10, 1993,
EPA held an informational meeting in Lyndonville, Vermont to discuss the
results of the Remedial Investigation, the Risk Assessment, and the initial
. screening of remedial alternatives.
EPA published a notice and brief analysis of the Proposed Plan in the
Caledonian Record on July 7, 1994. On July 8, 1994, EPA made the
administrative record available for public review at EPA's offices in
Boston and at Cobleigh Public LibrarY in Lyndonville~ Vermont.
On July 13, 1994, EPA held an informational meeting to discuss the results
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
of the Remedial Investigation and the cleanup alternatives presented in the
Feasibility Study and to present the Agency's Proposed Plan. Also during
this meeting, the Agency answered questions from the public. From July 8,
1994 to September 6, 1994, the Agency held a sixty 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 August 3, 1994, the Agency held an
informal public hearing to discuss the Proposed 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 was developed by combining components of different
source control and management of migration alternatives to obtain a
comprehensive approach for Si.te remediation. In summary, the remedy
provides for the following actions which will address the principal threats
to human health and the environment posed by the Site:
3 .
4.
1.
Construction of multi-layer caps over the SWDA and three IWS
areas to minimize the potential for transfer of hazardous
substances from the soil and waste into the groundwater, surface
water, and sediments, and to prevent direct contact with
hazardous substances in the soil or solid waste;
2 .
Construction and
treatment system
groundwater, and
water standards;
operation of a groundwater extraction and
to prevent further migration of contaminated
to restore contaminated groundwater to drinking
Implementation of institutional controls to prevent ingestion of
contaminated groundwater and to protect the integrity of.the
Landfill caps; and
Long-term environmental monitoring and five-year reviews to
insure that the remedy remains protective of human health and the
environment. .
Remedial activities at the Site are comprehensive and intended to be a
final remedy.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
v.
SUMMARY OF SITE CHARACTERISTICS
Section E.3 of the Feasibility Study contains an overview of the Remedial
Inves~igation. The significant findings of the Remedial Investigation are
summarized below.
A.
Waste/Source Areas
Four source areas have been identified at the Parker Landfill Site (see
Figure 2). The SWDA contains approximately 1.4 million cubic yards of
waste covering approximately 14 acres and averaging 70 feet in thickness.
Individual source areas within the SWDA cannot be identified. Most, if not
all, of the waste is located above the water table.
IWS 1 contains an estimated 6800 cubic yards of waste/fill overlying 100
feet of unsaturated silty clay. The soil underlying the waste is
contaminated to a depth of at least 26 feet.
IWS 2 contains approximately 1200 cubic yards of waste/fill in two or three
disposal locations. The entire 18 feet of soil between the ground surface.
and the water table is contaminated, although levels decrease with depth.
This area exhibits the highest levels of contamination in the waste/soil.
IWS 3 contains approximately 2000 cubic yards of waste/fill in three
identified disposal locations. In this area, thirty feet of unsaturated
soil overlies a perched water table. The majority of VOC contamination is
in the upper fifteen feet of soil beneath the waste/fill. This area is
thought to be a principal source for groundwater contamination.
B.
Soil
Surface Soils
A total of seventeen surface soil samples were collected from locations
along the eastern perimeter of the SWDA in areas of leachate staining and
from within each IWS area. One background surface soil sample was
collected. No soil samples were taken from the surface of the SWDA because
it was presumed this area will be capped. No pesticides or PCBs were
detected in any of the surface soil samples taken from the Site.
Semivolatile organics and inorganics were most prevalent in SWDA perimeter
surface soils. Bis(2-ethylhexyl) phthalate was detected at a maximum
concentration of 0.15 mg/kg. Of the fourteen metals detected in the SWDA
perimeter, arsenic, barium, beryllium, lead, and nickel were detected above
background concentrations.
A .total of ten surface soil samples were collected from IWS areas. A wide
variety of contaminants were detected in the IWS surface soils area,
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ROD DECISION SUMMARy.
PARKER LANDFILL SUPERFUND SITE
including VOCs, semi-volatile organic compounds (SVOCs), and inorganics.
Organics were detected with the highest frequency and at the highest
concentrations at IWS 2: They included 1,2-dichloroethene (72 mg/kg), TCE
(1,000 mg/kg), tetrachloroethane (93 mg/kg), and various pOlynuclear
aromatic hYdrocarbons (PARs) with maximum concentrations ranging from 0.15
mg/kg to 8.5 mg/kg. Of the 17 inorganics detected, barium, chromium, iron,
and vanadium were detected above background concentrations in the IWS
areas.
Subsurface Soils
Subsurface" soil samples were also collected from soil test boring locations
at the perimeter of the SWDA and from within and around the IWS areas. The
subsurface soil sample (three to five feet below ground surface) from the
-soil boring B101B, located upgradient from IWS 3, was utilized as the
,'background sample. Only the subsurface soil sampies obtained from the 2 to
16 fe~t depth interval were addressed in the risk assessment based on
assumed accessibility to human receptor populations. No pesticides or PCBs
were detected in any of the subsurface soil samples taken from the Site.
The only contaminants detected in SWDA perimeter subsurface soil samples
were low concentrations of trichloroethene and xylenes at 0.002 mg/kg and
0.005 mg/kg, respectively. Inorganics were detected at concentrations
below background.
Subsurface soil samples were collected from soil borings and test pits in
each of the IWS areas, including fill material. VOCs were detected at the
highest concentrations and most frequently in IWS 2 subsurface soils, with
maximum concentrations of 2,500 mg/kg, 540 mg/kg, and 100 mg/kg for
trichloroethene, 1,2-dichloroethene, and tetrachloroethane, respectively.
SVOCs, primarily PARs and phthalates, also were detected in IWS area
subsurface soils. The highest concentrations of SVOCs were detected in
fill material collected from test pits in IWS 2 and IWS 3. Both bis(2-
ethylhexyl)phthalate and-di-n-butyl phthalate were detected in IWS 2 at
maximum concentrations of 11 mg/kg.
Of the twenty inorganic contaminants detected in IWS subsurface soils,
arsenic, barium,beryllium, cobalt, chromium, iron, manganese, vanadium,
and zinc were detected above background concentrations.
IWS 2 contains the greatest mass of VOCs in the soil, as compared to the
other IWS areas. However, it does not appear to be a major Source of
chlorinated VOCs to groundwater. Chlorinated VOC concentrations detected
in shallow groundwater in the IWS 2 area are an order of magnitude less
than chlorinated VOC concentrations in shallow groundwater at IWS land IWS
3, except for well ERTl, which is believed to be located in an area of
residual organic compounds.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
C.
Groundwater
Groundwater Contamination
. Three rounds of groundwater samples were collected during the Remedial.
Investigation from the 92 monitoring wells installed in and around the
Site. Groundwater samples collected from the Site were contaminated with
VOCs, SVOCs, and inorganics. Many of the contaminants detected iri the SWDA
and IWS area monitoring wells exceeded Federal Maximum Contaminant Levels
(MCLs) and/or the Vermont Enforcement Standards for groundwater (see Figure
3) .
One background/upgradient groundwater location, G101B, was sampled. No
contaminants were detected above either MCLs or the Vermont Enforcement
Standards, with the exception of biS{2-ethylhexyl) phthalate detected at
0.069 mg/L. . .
Twenty-four VOCs were detected in Site and Site vicinity groundwater. The
chemicals most frequently detected at the highest concentrations were 1,2-
dichloroethene (29 mg/L) and trichloroethene (TCE) (50 mg/L) i both of
these maximum concentrations were detected in well ERT1 near IWS 2.
Samples were also taken downgradient of the Landfill, including locations
along Brown Farm Road and Red Village Road. Contaminants detected above
MCLs or Vermont Enforcement Standards in downgradient locations include 2-
butanone, 1,2-dichloroethene, 1,2-dichloropropane, tetrachloroethane,'
trichloroethene, bis(2-ethylhexyl) phthalate, antimony, and lead.
Eleven SVOCs were detected in Site area groundwater. Bis(2-
ethylhexyl)phthalate (maximum concentration = 0.16 mg/L) was detected most
frequently, in approximately 60 percent of samples. Other SVOCs were
detected in less than 33 percent of samples analyzed. Twenty-four
inorganics were detected in groundwater, with arsenic, barium, chromium,
lead, manganese, nickel, and .zinc detected in greater than fifty percent of
the samples. .
Groundwater samples were also collected from residential wells downgradient
of the Landfill as part of a long-term monitoring program and a Vermont
Department of Health monitoring program. Total 1,2-dichloroethene and TCE
were the most frequently detected chemicals in these wells. No
contaminants have been detected in residential wells along Red Village Road
south of the Curren residence (see Figure 2) .
Contaminant Miqration
The SWDA serves as a source for shallow and deep groundwater contamination.
Leachate generated across the entire SWDA is interpreted to migrate within
the unsaturated zone in a southeasterly direction along waste layers, along
the interface between the Distal and the SWDA mass, and along suspected
bedding planes within the Distal. Portions of this flow discharge to the
upper Proximal along the eastern edge of the SWDA and at IWS.2. Flow in
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
the upper Proximal is south-southwesterly.
SWDA contaminants also reach the lower Proximal unit to the east and
possibly through windows in the Distal unit directly beneath the SWDA.
Once contaminants from the SWDA reach the lower Proximal, flow is west to
southwest.
Contaminants from IWS,l must pass through a minimum of 78 vertical feet of
Distal deposits prior to reaching the groundwater table in the lower
Proximal. Migration through the unsaturated zone is believed to be to the
southeast, toward the SWDA. When this flow reaches the lower Proximal,
migration is to the west and southwest.
IWS 2 is a collection point for southeasterly and southerly migrating SWDA
and IWS 3 contaminants, as well as contaminants from IWS 2. IWS 3
contaminants are transported southwest to the general vicinity of IWS 2 in
the upper Proximal unit, which is underlain by the lower permeability
Distal Unit. The Distal unit attenuates transport of contaminants but is
breached to the east of IWS 2 and the unnamed stream, allowing IWS 3
contaminants to migrate to the lower Proximal unit and the fractured
bedrock.
South and west of IWS 2, the upper and lower Proximal portions of the
aquifer merge and groundwater flows toward the west and southwest. There
is a significant decrease of contaminants in the overburden aquifer south
and southwest of the Landfill, probably a result of contaminant transport
into the fractured bedrock. .
Once contaminants enter the fractured bedrock east of IWS 2, flow is
predominantly to the south-southwest. There may be a fracture or fracture
zone 'which connects fractures in the IWS 2/SWDA area to fractures at the
Riverside School area. The precise extent of bedrock contamination is not
known; however, bedrock residential wells south of the Curren residence are
not contaminated.
D.
Surface Water/Sedtment
Unnamed Stream
Two rounds of surface water samples were collected during the Remedial
Investigation from eleven locations along the unnamed stream. Three
locations were designated as background sample locations. Primarily
inorganic contaminants were detected in the background and on-site surface
water samples. Of the thirteen inorganics detected, aluminum, antimony,
chromium, iron, and nickel concentrations exceeded background
concentrations.
No VOCs or SVOCs were detected in any of the background samples.
were detected in any of the stream surface water samples. Low
No SVOCs
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ROD DECISION SUMMARY
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concentrations of VOCs were detected in stream samples, with a maximum
concentration of 0.042 mg/L for l,2-dichloroethene. The maximum.
concentration of trichloroethene, 21 ug/l, exceeds the Vermont Water
Quality Criteria for the protection of human health (consumption of water
and organisms - 2.7 ug/l).
Two rounds of sediment samples were collected from the same locations as
the surface water samples. Primarily inorganics were detected in both
background and shallow stream sediment samples (0-6 inches). Elevated
concentrations of the following contaminants were detected compared to Site
background (maximum detected concentration in parentheses): arsenic (962
mg/kg); barium (809.5 mg/kg); cadmium (10.5 mg/kg); cyanide (22.6 mg/kg);
iron (383,000 mg/kg); and manganese (2,425 mg/kg). Based upon the
anomalous arsenic result at station 402 (initial sample was 16.5 mg/kg and
replicate was 1,908 mg/kg), duplicate sediment samples were collected from
this. location. Arsenic was detected in these duplicate samples at 1.3 and
1. 4 mg/kg.
VOCs were detected infrequently and at low concentrations in stream
sediments; highest detected concentration was 0.24 mg/kg for acetone. Bis-
(2-ethylhexyl) phthalate was the only SVOC detected in stream sediments; it
was detected once at 0.16 mg/kg.
The unnamed stream north of IWS 2 is periodically dry. Eleven piezometers
located in the unnamed stream were used to measure permeability of stream
sediments and vertical hydraulic gradients. Permeability measurements
indicate a complete hydraulic connection between the stream and the shallow
aquifer. Near the northern extent of the Landfill, the stream was a
"losing" stream (water flowing from the stream to the shallow aquifer).
Throughout the IWS 2 area, the stream is alternately losing and gaining,
depending on the location of the shallow groundwater table and the effects
of precipitation. South of the Landfill, the stream is predominately
losing to groundwater.
passumcsic River
River surface water samples were collected from three locations: upstream
of the potential Site influence, at the stream outfall, and downstream. No
VOCs or SVOCs were detected in upgradient or downgradient locations.
However, low concentrations of 1,2-dichloroethene (11 ug/L) and
trichloroethene (6 ug/L) were detected at the stream outfall location.
Inorganics detected at the stream outfall at concentrations above the
upgradient location include aluminum and manganese at maximum
concentrations of 215 ug/L and 197 ug/L, respectively.
Four river sediment samples were collected: one upgradient of the unnamed
stream outfall, two in the area of stream outfall, and onedowngradient.
No VOCs or SVOCs were detected in any of the sampled Passumpsic River
sediments. Inorganics in sediments at the stream outfall and downgradient
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
that were detected at higher concentrations than at the upgradient location
include arsenic, barium, cadmium, iron, manganese, and zinc.
No PCBs or pesticides were detected in any of the surface water or sediment
samples from either the unnamed stream or the Passumpsic River.
E.
Air
Two rounds of air quality monitoring for VOCs were conducted during the
Remedial Investigation. Benzene, methylene chloride, trichloroethene, and
1,1,1-trichloroethane were detected. The highest estimated concentration
was 3.4 ppbv for methylene chloride for a sample collected in the vicinity
of IWS 3. . ' .
F.
Leachate
Leachate was sampled at three locations along the eastern perimeter of the
SWDA. Thirteen VOCs, seven SVOCs, and 15 inorganics were detected. ,
Maximum concentrations of 11 of the 13 VOCs detected were less than 1 mg/L.
Acetone and 2-butanone were detected at 4.3 mg/L and 5.4 mg/L respectively.
G.
Ecological Resources/Wetlands
Ecological studies at the Site included a wildlife receptor inventory,
wetland delineation, a water quality survey, and a bioassessment of benthic
macroinvertebrates. Habitats at the Parker Landfill Site consist of
forested uplands, upland fields, forested wetlands, scrub/shrub wetlands,
and streams.
The unnamed stream to the east of the SWDA is ephemeral and consists of
shallow and poorly defined channels. Sedimentation from erosion of the
SWDA cap and an access road through the stream is limiting the
establishment of vegetation. Deposits of orange oxides accompanied by
Ferrobacillus colonies are evident where Landfill leachate enters the
stream.
Wetlands associated with the unnamed stream are prima+ily mixed
deciduous/conifer forest. Disturbed wetlands adjacent to the SWDA and IWS
2 represent a scrub/shrub wetland community. South of the merger of the
unnamed stream with another unnamed stream, wetland vegetation is limited
to the immediate vicinity of the stream channel, which has been altered by
channelization and entrenchment. '
Significant natural communities or threatened and endangered species are
not known to be present at the Parker Landfill Site or in the nearby
Passumpsic River.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
A complete discussion of Site characteristics can be found in the Remedial
Investigation Report in Sections 4, 5, and 6.
VI.
Summary of Site Risks
EPA performed a Risk Assessment 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 assessment for the Parker Site are discussed
below followed by the conclusions of the environmental risk assessment.
A.
Human Health Risk Assessment
1. Contaminant Identification
The Contaminants of Concern (COCs) constitute a representative subset of
all the contaminants identified at the Site during the Remedial
Investigation (RI). The COCs were selected to represent potential Site
related hazards based on toxicity, concentration, frequency of detection,
and mobility and persistence in the environment. The COCs identified at
the Parker Landfill and .listed in Tables 1-15 (Appendix A of this ROD) for
each media, were selected for evaluation in the human health risk
assessment. These include 33 surface soil, 38 subsurface soil, 38
groundwater, 15 sediment, 17 surface water, 33 leachate and 4 air COCs. A
summary of the health effects of each COC is located in Appendix D of the
Final Risk Assessment Report (May 26, 1993). .
2. Exposure Assessment .
Potential human health effects associated with exposure to the COCs were
estimated quantitatively or qualitatively through the development of
several hypothetical exposure pathways. These pathways were developed to
reflect the potential for exposure to hazardous substances based on the
present uses, and potential future uses, and location of the Site. .
Presently, the area surrounding the Landfill is a mixture of residential,
pasture, and wooded areas. Continued residential development is expected
around the Landfill in the future. A subdivision is proposed for the area
directly south of the Landfill. The following is a brief summary of the
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
exposure pathways evaluated. A more thorough description can be found on
pages 3-10 through 3-17 of the Risk Assessment.
c.
d.
e.
a.
Ingestion of Groundwater: Currently, groundwater in the
overburden and in bedrock is used as a potable water source. The
human heath risk assessment evaluated ingestion of groundwater by
current residents, using data from the current residential areas;
and also looked at the potential for ingestion of groundwater by
future residents, using data from the entire vicinity of the.
Site.
b.
Inhalation of Groundwater Contaminants: There is a potential for
certain groundwater contaminants to volatilize during shower
activities, however this exposure pathway was not evaluated
quantitatively. It is not expected that the risk estimate for
this pathway would exceed the risk calculated for the groundwater
ingestion pathway. Overall groundwater risks associated with
household used might be expected to be -approximately two times
the ingestion risk.
Surface/subsurface soils: Exposure to COCs in surface soils
through dermal contact and incidental ingestion by trespassers
traversing the Site was evaluated. Possible future exposur~ from
surface or subsurface soils was also evaluated based on an
assumption of excavation associated with new home construction.
Sediments/surface water: Stream/river sediments and stream
surface waters were evaluated in relation to exposure of youth
trespassers or future residents to COCs through dermal contact
and incidental ingestion.
Inhalation of airborne contaminants: The exposure of local
residents to airborne VOCs originating from the Landfill and the
unnamed stream was evaluated.
For each pathway evaluated, an average and a reasonable maximum exposure
estimate was generated corresponding to exposure to the average and the
maximum concentration detected in that particular medium. Residential
occupants for present and future ingestion and inhalation of contaminants
were assumed to weigh 70 Kg~ be exposed to air and water-born contaminants
for 30 years and ingest and inhale the contaminants on a daily basis. For
future residential scenarios involving surface soils, adults are assumed to
weigh 70kg and be exposed to surface soils for 30 years on a 150 day per
year exposure basis. Children are assumed to weigh 15kg and be exposed to
soil for 6 years on a 150 day per year exposure basis. People pursuing
recreational pursuits in close proximity to the Site are assumed to be
. between 9 and 18 years old and weigh 50 kg. Dermal contact scenarios
assumed exposure for 52 days a year for 10 years. Complete exposure
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
pathway assumptions can be found in Tables 3-3 through 3-12 of the Final
Risk Assessment Report.
3. Toxicitv Assessment
The human health risk assessment considered scientific evidence of toxicity
and information relating to chemical exposures (dose) to anticipated health
effects (response) for each COCo Toxicity information can be found in the
Final Risk Assessment.Report in Section 3.3 and Appendix D.
4. Risk Characterization
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 notation as a probability (e.g~ 1 x 10-6 for
1/1,000,000) and indicate that an average individual is not likely to have
greater than a one in a million chance of developing cancer over 70 years
as a result of site-related exposure 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 (HI) 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 course 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 example: The hazard quotient
for a compound known to produce liver damage should not be added to a
second whose toxic endpoint is kidney damage) .
Risk estimates developed in the Risk Assessment were evaluated using the
USEPA criteria and target risk range to identify the need for remedial
actions at. this Site. Chemicals present at the Site at concentrations in
excess of health-based criteria or the target risk range were identified
for each exposure pathway .and appropriate target cleanup levels were
developed. Tables 16-17 depict the carcinogenic and noncarcinogenic risk
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
summary for the contaminants of concern, the mediums evaluated, and the
present and potential future exposure pathways corresponding to the average
and the Reasonable Maximum Exposure (RME) scenarios. Appendix E of the.
Final Risk Assessment report presents the chemical-specific risk estimates
for each exposure pathway.
The greatest risks at the Site were associated with ingestion of
groundwater. Carcinogenic risk estimated for the ingestion of average and
maximum contaminant concentrations in groundwater both exceeded EPA's
target risk range of 10-4 to 10-6. The greatest carcinogenic risk value
(2x10-2) at the Parker Landfill Site is associated with the ingestion of
maximum concentrations of groundwater from w~lls at the Landfill. This
risk was driven primarily by trichloroethene, vinyl chloride, and arsenic.
The carcinogenic risks associated with average groundwater contaminant
concentrations in the vicinity of the Landfill was 3x10-4. Total
carcinogenic risks from existing residential wells, on the order of 10-5
fell within EPA's target risk range. However, six of the residential wells
which are no longer in use have contaminant levels exceeding MCLs.
The highest noncarcinogenic HI (500) was also associated with the ingestion
of maximum concentrations of groundwater in the immediate vicinity of the
landfill, driven primarily by trichloroethene, 1,2-dichloroethene, 4-
metbylphenol, arsenic and manganese. Noncarcinogenic risks from ingestion
of the average groundwater contaminant concentrations only slightly
exceeded unity (HI=6).
As stated previously, inhalation of groundwater contaminants would increase
the risk associated with residential groundwater use but this pathway was
not evaluated quantitatively. Also, iron, cobalt, and lead were not
assessed quantitatively in groundwater due to the lack of established
toxicity values. Exposure to these chemicals may cause additional risks.
. .
All carcinogenic and noncarcinogenic risk values estimated for exposure to
SWDA and IWS soil exposures were within or below EPA's acceptable risk
range except for the ingestion HI (20) for a child exposed to maximum
concentrations of subsurface/surface soil contaminants under a future
residential scenario. This risk is driven primarily by trichloroethene,
barium, chromium, and vanadium. .
All carcinogenic and noncarcinogenic risk values estimated for exposure to
stream sediments and surface water were within or below EPA's acceptable
risk range except for carcinogenic and noncarcinogenic risks to a potential
future resident who may be exposed to maximum concentrations of arsenic in
sediment in the unnamed stream immediately adjacent to the landfill. As
discussed previously, the single location with the high arsenic.
concentration was resampled., at which time detected concentrations were
almost three orders of magnitude lower.
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ROD DECISION SUMMARY
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Estimated total risks associated with air exposures to current/future
residents fell within EPA's target risk range.
B. Environmental Assessment
An ecological risk assessment was also
Landfill risk assessment, beginning on
Assessment Report.
produced as part of the Parker
page 4-1 of the Final Risk
The environmental assessment analyzed potential risks associated with
exposure of Site biota to contaminants in three mediums of concern: surface
waters of the Site streams and Passumpsic River, stream sediments, and
surface soils. Available criteria and guidelines were reviewed for use as
benchmark values for evaluating chemical toxicity to ecological receptors.
These guidelines include EPA Ambient Water Quality Criteria (AWQC) "and
sediment guidelines for comparison to Site surface waters and sediment
contaminant concentrations. In addition, sediment quality concentrations
were calculated for organic ecological COCs using the equilibrium
partitioning method. Surface water COCs for which no criteria exist were
evaluated by searching the Aqu~tic Information Retrieval (AQUIRE) database
for applicable toxicity information. Surface soils were evaluated by
estimating exposure doses received by indicator species (meadow vole,
short-tailed shrew, and red fox). These doses were then compared with
toxicity data obtained in the scientific literature.
Overall evaluation of potential risk to ecological receptors is estimated
in the ecological risk assessment through the calculation of risk indexes.
If the total risk index is greater than one, this indicates that exposure
to all COCs within that medium may pose a risk to organisms. The risk
indexes for the three mediums can be found in Tables 4-7 through 4-10 of
the Final Risk Assessment Report.
The conclusions of the ecological risk assessment were as follows. Surface
water quality in the unnamed stream may be impacted by elevated
concentrations of iron and silver. Sediment concentrations of barium,
cyanide, and manganese are slightly elevated but results of macrobenthic
sampling show that surface water and sediment contamination within the
stream are unlikely to result in adverse effects to resident aquatic biota.
Risks to terrestrial species exposed to contaminants in surface soil was
assessed by modeling exposure to three indicator species. Concentrations
of metals .in the IWS area surface soils may impact shrews (insectivores).
Herbivores (meadow vole as indicator species) and higher trophic levels
. (red fox as indicator species) are unlikely to be affected by soil
contaminants at the Site.
C~ Conclusions
In summary, the public health and environmental assessments indicate that
actual or threatened releases of hazardous substances from this Site, if
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
not addressed by implementing the response action selected in this ROD, may
present an imminent and substantial endangerment to the public health,
welfare, or the environment. Specifically, the human health risk
assessment identified groundwater ingestion as posing probable health risks
exceeding EPA risk management criteria. Secondarily, .risks associated with
future residential exposure to maximum contaminant concentrations of
surface soil and sediment slightly exceed EPA risk management criteria. In
addition, exposure to contaminants in IWS surface soils may impact some
wildlife species foraging in those areas. .
The response action selected in this ROD addresses the risks at the Site by
minimizing the potential for transfer of hazardous substances from the soil
and solid waste into the groundwater, surface water, and sediment;
preventing direct contact with hazardous substances in the soil or solid
waste; preventing further migration of contaminated groundwater; restoring
contaminated groundwater to drinking water standards; and preventing
ingestion of contaminated groundwater.
VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. Statutory Requirements/Response Objectives
Under its legal authorities, EPA's primary responsibility at Superfund
sites is to undertake remedial actions that are protective of human
health and the environment. In addition, Section 121 of CERCLA
establishes several other statutory requirements and preferences,
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 technologies 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
alternatives were developed to be consistent with. these Congressional
mandates..
Based on preliminary information relating to types of contaminants,
environmental media of concern, and potential exposure .
pathways, remedial action objectives were developed to aid in the
development and screening of alternatives. These remedial action
objectives were developed to mitigate existing and future potential
threats to public health and the environment. These response
objectives were:
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
SWDA and IWS Areas
.
Minimize, to the extent practicable, the potential for transfer
of hazardous substances from the soil and solid waste into the
groundwater, surface water, and sediment;
.
Prevent direct contact/ingestion of soil or solid waste posing a
potential total cancer risk greater than 10~4 to
10-6, or a potential hazard index greater than one; and
.
Comply with federal and state ARARs.
Groundwater
..
Prevent ingestion of groundwater containing Contaminant of .
Concern in excess of federal or state standards, or posing a
potential total cancer risk greater than 10-4 to 10-6, or a
potential hazard index greater than one;
.
Comply with federal and state ARARs.
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.
EPA has established the concept of presumptive remedy as a mechanism
to streamline Site studies and cleanup actions. The objective of the
presumptive remedies approach is to use cleanup techniques shown to be
effective in the past at similar sites. Presumptive remedies are
expected to be used at all appropriate sites except under unusual
circumstances. EPA's "Presumptive Remedy for CERCLA Municipal
Landfill Sites" establishes containment as the presumptive remedy for
CERCLA municipal landfills.
The Parker Landfill Feasibility Study presumed capping to be the.
remedy for the SWDA because this area accepted 'municipal waste with
some co-disposed industrial ,wastes. The IWS areas, which accepted
principally' industrial wastes, were evaluated as hot spots to
determine whether additional remedial responses should be considered
for these areas. This evaluation is contained in Section 1.6 of the
Feasibility Study Report. The Feasibility Study concluded that,
because IWS 1 and IWS 3 are not large enough that their removal or
treatment would significantly reduce the threat posed by the Site,
these areas are not appropriate for potential removal and treatment or
disposal. Only capping was considered for IWS 1 and IWS 3 in the
Feasibility Study.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
Because IWS 2 contains the greatest mass of contaminants in the. soil
and fill, the RI/FS evaluated a range of treatment technologies for
this hot spot. The purpose of these technologies is to reduce the
toxicity, mobility, or volume of the hazardous substances.
With respect to groundwater response action, the RI/FS developed a
limited number of remedial alternatives that attain site specific
remediation levels within different timeframes using different
technolog~es; and a no action alternative.
As discussed in Sections' 2 and 3 of the Feasibility Study, the RI/FS
,identified, assessed and screened technologies based on
,';'implementability, effectiveness, and cost~ These technologi~s were
" combined into remedial alternatives which included source control and
management of migration components. Section 3 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.
In summary, of the nine source control and management of migration
remedial alternatives screened in Section 3 of the Feasibility Study,
seven were retained for detailed analysis. Section 3..1 of the
Feasibility Study Report identifies the nine alternatives that were
retained through the screening process. Section 3.3 lists those that
were retained for detailed analysis.
VIII.
DESCRIPTION OF ALTERNATIVES
This Section provides a narrative summary of each alternative
evaluated. A detailed assessment of each alternative can be found in
Section 4 of the Feasibility Study ~eport.
The remedial alternatives that underwent detailed analysis for the
Parker Landfill Superfund Site are the following:
Alternative 1:
Alternative 2:
No Action
Containment (SWDA, IWS I, 2, and 3)/No Source
Control Groundwater
Containment (SWDA, IWS 1, 3, and 3)/Source Control
Groundwater
Containment (SWDA, IWS 1, 2, and 3)/In-situ Soil
Vapor "Extraction of IWS 2 Area/No Source Control
Groundwater
Alternative 3:
Alternative 4:
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
Alternative 5: Containment (SWDA, IWS 1, 2, and 3)/In-situ Soil
Vapor Extraction of IWS 2 Area/Source Control
Groundwater
Alternative 8: Containment (SWDA, IWS 1, 2, and 3)/ Downgradient
Groundwater Extraction/Treatment
Alternative 8A: Downgradient Groundwater Extraction
Combined with Alternatives 2 or 4 (No
Source Control Groundwater)
Downgradient Groundwater Extraction
Combined with Alternatives 3 or 5
(Source Control Groundwater)
Alternative 8B:
All of the alternatives include long-term environmental monitoring and
a five-year review. All of the alternatives, except for Alternative 1
(No Action), include institutional controls to prevent the use of
contaminated groundwater and protect the containment system.
Alternatives 6 and 7 included, excavation and off-site incineration of
IWS 2 contaminated soil. These alternatives were' eliminated in the'
initial screening process because they offered very limited additional
benefits and minimal risk reduction relative to the other
alternatives. In addition, these alternatives would be more costly to
implement and would pose significant potential worker and community
exposure and implementability concerns.
Alternative 1:
No Action
This alternative was evaluated in detail in the Feasibility Study, to
serve as a baseline for comparison with the other remedial
alternatives under consideration. Under this alternative, no
treatment or containment of the SWDA or IWS areas would occur and no
effort would be made tq treat or prevent the further migration 9f '
contaminated groundwater. Also, there would be no access restrictions
or institutional controls to prevent the use of contaminated
groundwater. Groundwater, surface water, and sediment would be
periodically monitored and the Site would undergo an evaluation of
data every five years.
Estimated
Estimated
Estimated
(net
Estimated
Time for Design and Construction:
Capital Cost: $0
Operation and Maintenance Costl:
pres en t worth)
Total Cost (net present worth)l:
Not Applicable
$ 43,000
$ 43,000
1 Estimated cost for each alternative is based on 30 years
of operation and a 7% interest rate.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
Alternative 2: Containment/Institutional Controls
Alternative 2 would consist of covering the SWDA and IWS areas
(approximately 20 acres) with multi-layer caps, consistent with the
RCRA Subtitle C requirements listed in 40 CFR (Part 264). The
typical multi-layer caps would consist of (from top to bottom) :
. six inches of topsoil to support a vegetative cover.
. 30 inches of soil fill to provide a root zone and
protection for the underlying components or 18 inches
of soil if using sand for drainage.
a nonwoven geotextile filter fabric to minimize fill
material from clogging the drainage layer.
a geonet/geotextile drainage layer or 12 inches of sand
to prevent ponding of water over the synthetic barrier.
a 40 mil very low density polyethylene (VLDPE) or
equivalent to act as the main barrier which prevents
water infiltration from entering the landfill.
a low hydraulic conductivity geosynthetic clay liner to
minimize potential leakage throughout the low hydraulic
conductivity geomembranne into the landfill. "
a base layer of six inches of silt or silty sand to
establish a base grade for the landfill.
.
.
.
.
.
The above cap will be utilized for all areas having slopes of less
than or equal to 5%. For all side slope areas, designed with a 3:1
slope, a minor variation of the base liner design would be
implemented. From top to bottom, the side slope cap would consist of:
.
.
six inches of topsoil to support a vegetative cover.
30 inches of soil fill to provide a root zone and
protection for the underlying components or 18 inches
of soil if using sand for drainage.
a nonwoven geotextile filter fabric to minimize fill
material from clogging" the drainage layer.
a geonet/geotextile drainage layer or 12 inches of sand
to prevent ponding of water over the synthetic barrier.
a textured geomembrane, 40 mil very low density"
polyethylene (VLDPE) or equivalent to act as the main
barrier which prevents water infiltration from entering
the landfill.
a base layer of six inches of silt or silty sand to
establish a base grade for the landfill and enhance
side slope stability.
.
.
.
.
In addition, an active gas collection system would be installed to
prevent Landfill gases from accumulating under the caps. Any wetlands
adversely impacted by the construction of the caps would be mitigated. "
"A storm water management system and perimeter fencing would also be
installed at the Landfill.
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ROD DECISION SUMMARY
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Finally, institutional controls would be put in place to prevent the
use of groundwater containing contaminant levels above state and
federal standards and to limit excavation or other disturbance of the
capped areas. Groundwater, surface water, and sediment would be
periodically monitored and the Site would undergo an evaluation of
data every five years.
Estimated Time for Design and Construction:
Estimated Capital Cost: $ 11,600,000
Estimated Operation and Maintenance Cost:
(net present worth)
Estimated Total Cost (net present worth):
24 months
$ 2,010,000
$ 13,600,000
Alternative 3: Containment (SWDA. rws Areas 1. 2. and 3)/ Source
Control Groundwater Extraction. Treatment. Discharqe/ Institutional
.Controls .
Alternative 3 would involve the installation of caps, a gas collection
system, fencing, stormwater management, and wetlands mitigation,
similar to that described for Alternative 2. In addition, Alternative
3 would involve the installation and. operation of a system to extract
an~ treat contaminated groundwater from the SWDA and IWS areas. This
will prevent further migration of contaminants and allow for the
restoration of the downgradient aquifers to federal and state drinking
water standards through natural attenuation. .
Approximately four overburden and one bedrock extraction wells would
be installed immediately downgradient of the Landfill. The exact
number and location of these wells would be determined during design
and would be sufficient to capture the overburden and bedrock
contaminant plumes. Extracted groundwater would be treated by air
stripping and GAC polishing (or an equivalent technology) to remove
organic contaminants. This treatment would require a pretreatment
step consisting of inorganics removal using carbonate/hydroxide
precipitation (or an equivalent technology). Treated groundwater
would be discharged to the Passumpsic River, after meeting water
quality requirements of the NPDES program. Treatment residuals would
undergo further treatment or destruction and/or off-site disposal,
depending upon their classification as hazardous or non-hazardous.
The air stream from the air stripper would pass through a carbon
filter to remove volatile organic compounds, and then be vented to the
atmosphere, in compliance with federal and state ARARs.
Like Alternative 2, this Alternative would also include institutional
controls, long-term monitoring, and five-year reviews.
Estimated Time for Design and "Construction:
Estimated Capital Cost: $ 15,450,000 .
Estimated Operation and Maintenance Cost:
30 months
$ 12,710,000
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
(net present worth)
Estimated Total Cost (net present worth):
$ 28,200,000
Alternative 4: Containment (SWDA. IWS Areas 1. 2. and 3)/ Soil Vapor
Extraction (SVE) at IWS 2/ Institutional Controls .
Alternative 4 includes the same containment measures (capping, gas
collection system, fencing, stormwater management, and wetlands.
mitigation) as Alternative 2. Also, like Alternative 2, this.
Alternative does not include any groundwater extraction and treatment.
Alternative 4 includes the installation of an SVE system in IWS 2 to
remove volatile organic compounds from the unsaturated soil. Soil
vapor would be removed from vapor extraction wells in IWS 2, and
treated with vapor-phase granular activated carbon before being
discharged to the atmosphere. This system would be ma1ntained and
monitored for fifteen years. .
Like the other alternatives (except for No Action), this Alternative
would also include institutional controls, long-term monitoring, and
five-year reviews.
Estimated Time for Design and Construction:
Estimated Capital Cost: $ 12,080,000
Estimated Operation and Maintenance Cost:
(net present worth)
Estimated Total Cost (net present worth):
25 months
$ 3,380,000
$ 15,500,000
Alternative 5: Containment (SWDA, IWS Areas 1. 2. and 3)/ Soil Vapor
Extraction (SVE) at IWS 2/ Source Control Groundwater Extraction,
Treatment, Discharae/ Institutional Controls
Alternative 5 combines the capping and source control groundwater
extraction and treatment of Alternative 3 with the SVE system
described above for Alternative 4. Like the other alternatives
(except for No Action), this Alternative would also include
institutional controls, long-term monitoring, and five-year reviews.
Estimated Time for Design and Construction:
Estimated Capital Cost: $ 15,890,000
Estimated qperation and Maintenance Cost:
(net present wortb.)
Estimated Total Cost (net present worth):
30 months
$ 14,080,000
$ 30,000,000
Alternative SA: Downaradient Groundwater Extraction Combined with'
Alternatives 2 or 4 (No Source Control Groundwater Extraction) .
Alternative SA would supplement Alternative 2 (containment/no source
control groundwater extraction) or Alternative 4 (containment/SVE of
IWS 2/no source control groundwater extraction). In this Alternative,
groundwater would not be extracted from source areas (SWDA and IWS
areas) but from downgradient areas at the southern edge of the
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
contaminated plume. Extracted water would be treated and discharged
as described for Alternative 3.
Like the other alternatives (except for No Action), this Alternative
would also include institutional controls, long-term monitoring, and
five-year reviews.
Estimated Time for Design and Construction:
Estimated Capital Cost: $ 16,110,000
Estimated Operation and Maintenance Cost:
(net present worth) .
Estimated Total Cost (net present worth):
30 months
$ 12,270,000
$ 28,400,000
Alternative 8B: Downaradient Groundwater Extraction Combined with
Alternatives 3 or 5 (Source Control Groundwater Extraction)
Alternative 8B would supplement. Alt.ernative 3 (containment/source
control groundwater extraction) or Alternative 5 (containment/SVE of
IWS 2/source control groundwater extraction). In this Alternative,
groundwater would be extracted. from source areas (SWDA and IWSareas)
and from downgradient areas at the southern edge of the contaminated
plume. Extracted water would be treated and discharged as described
for Alternative 3.
Like the other alternatives (except for No Action), this Alternative
would also include institutional controls, long-term monitoring, and
five-year reviews.
Estimated Time for Design and Construction:
Estimated Capital Cost: $ 17,130,000
Estimated Operation and Maintenance Cost: .
(net present worth)
Estimated Total Cost (net present worth):
30 months
$ 15,370,000
$ 32,500,000
IX.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
A.
Evaluation Criteria
Section 121(b) (1) of CERCLA presents several factors that at a minimum
EPA is required to consider in its assessment of alternatives.
Building upon these specific statutory mandates, the National
Contingency Plan articulates nine evaluation crite~ia 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
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
weakness with respect to the nine evaluation criteria.
are summarized as follows:
These criteria
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 each
pathway are eliminated, reduced or controlled through
treatment, engineering controls, or institutional
controls.
2.
Compliance with applicable or relevant and appropriate
requirements (ARARS) addresses whether or not a remedy
will meet all of the ARARs of other Federal and State
environmental laws and/or provide grounds for invoking
a waiver. .
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.
4.
5.
6.
3 .
Long-ter.m effectiveness and per.manence addresses the
criteria that are utilized to assess alternatives for
the long-term effectiveness and permanence they afford,
along with the degree of certainty that they will prove
successful.
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.
. Short ter.meffectiveness 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.
Implementabili ty addresses t.he technical and
administrative feasibility of a remedy, including the
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
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.
Modifvina 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 and key
concerns related to the preferred 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 and RI/FS report. .
A detailed tabular assessment of each alternative according to the
nine criteria can be found in Appendix A, Table 16 of this Record of
Decision.
Following the detailed analysis of each individual alternative, a
comparative analysis, focusing on the relative performance of each
alternative against the nine criteria, was conducted. This
comparative analysis can be found in Section 5 of the Feasibility
Study.
The section below presents the. nine criteria and a brief narrative
summary of the alternatives and the strengths and weaknesses according
to the detailed and comparative analysis.
B.
Summary of the Comparative Analysis of Alternatives
1.
Overall Protection of Human Health and the Environment
EPA's "Presumptive Remedy for CERCLA Municipal Landfill Sites"
establishes containment as the presumptive remedy for CERCLA .
municipal landfills. All of the alternatives, except for the No
Action Alternative, provide a similar level of protection of
human health and the environment concerning the potential for
direct contact with soil, sediments, and solid waste. Consistent
with the Presumptive Remedy, all of these alternatives include
the construction of caps and institutional controls to protect
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
the integrity of the caps. The caps would prevent ingestion and
dermal contact of soil or solid waste. Capping would also
prevent further transport of contaminants into stream sediments.
The No Action Alternative is not protective of human health or
the environment. This Alternative would allow a continued
release of contaminants and a possible spreading of contamination
to currently uncontaminated areas.
Capping would effectively reduce infiltration and thereby halt
the leaching of contaminants from the soil and solid waste into
groundwater. This would ultimately result in an improvement of
downgradient groundwater quality and a reduction of the risks to
human health associated with ingestion of contaminated
groundwater. Because of the uncertainty of the mass of
contaminants already in the saturated zone, the time frame for
reduction of groundwater levels to remediation goals with capping
only is unpredictable within the foreseeable future.
Installation and operation of a soil vapor extraction system
within IWS 2 (Alternatives 4," 5, 8) would not significantly
contribute to the protection of human health risks, since the cap
alone would prevent exposure to contaminants and migration of
contaminants from the unsaturated zone within IWS 2 to
groundwater.
With respect to exposure to contaminated groundwater, all
alternatives, except for the No Action Alternative, would
overall protection to human health and the environment as
institutional controls are in "place. In the long-term,
alternatives including source control groundwater extraction and
"treatment (3, 5, and 8B) would be protective of human health by
preventing further migration of contaminants beyond the boundary
of the Landfill and allowing for the restoration of the
downgradient aquifer. It is expected that, with any of the source
control groundwater extraction and treatment alternatives,
restoration of the downgradient aquifer would take 20 to 60
years. Therefore, during this time, protection of human health
would rely on institutional controls.
Alternatives 2 and 4 (no groundwater extraction and treatment)
rely solely on institutional controls" for protection of human
health from groundwater ingestion. It is anticipated that, .
absent groundwater extraction and treatment, the aquifer will not
be restored in the foreseeable future. Because it is
questionable whether institutional controls could effectively
prevent exposure to contaminated groundwater in the long-term,
these alternatives provide less protection of human health than
Alternatives 3, 5, and 8B. Alternative 8A (downgradient
of the
provide
long as
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
groundwater extraction and treatment) would not restore the
downgradient aquifer to remediation goals within the foreseeable
future, and therefore is similar to Alternatives 2 and 4 with
. respect to protection of human health.
In summary, all of the alternatives, except for the No Action
Alternative, would provide for overall protection of human health
and the environment. In the long-term, alternatives including
source control groundwater extraction and treatment (3, 5, 8B)
would provide greater protection of human health by eliminating
potential exposure to contaminated groundwater. .
2.
Compliance With ARARs
Tables 4-1 through 4-7 of the Feasibility Study Report and
.Appendix B of this Record of Decision provide a listing of all
chemical-specific, action-specific, and location-specific ARARs
for each alternative.
Alternative 1 (No Action) generally does not comply with ARARs,
including federal and state hazardous waste regulations, and
federal and state drinking water standards. It would only comply
. with state solid waste regulations, as it is required by the
state to be closed consistent with those regulations.
All of the alternatives, except for No Action, would meet the
federal and state hazardous waste regulations by complying with.
the closure and post-closure requirements for hazardous waste
facilities. These alternatives will also meet federal and state
wetlandsARARs by minimizing adverse effects to wetlands and
mitigating any unavoidable impacts. .
.Alternatives 2, 4, and SA (no source control groundwater.
extraction and treatment) would not meet Federal Safe Drinking
Water Maximum Contaminant Level Goals (MCLGs), Maximum
Contaminant Levels (MCLs), or Vermont Primary Groundwater Quality
Standards within the foreseeable future. These alternatives.
would also not meet the maximum permissible concentrations of
hazardous constituents in groundwater established in the Vermont
Hazardous Waste Regulations.
Alternatives 3, 5, and SB (source control groundwater extraction
and treatment) would meet the aforementioned drinking water
standards downgradient of the point of compliance within
approximately 20 to 60. years.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
3.
Long-Ter.m Effectiveness and Permanence
The No Action Alternative would not be effective or permanent in
reducing long-term risk; soil and solid waste will continue to be
available for exposure to human and ecological receptors and
contaminants will continue to leach into groundwater and migrate
beyond the boundary of the Landfill.
All of the remaining alternatives would be equally effective and
reliable in the long term in preventing exposure to contaminated
soil, solid waste, and sediment, since they all rely on capping.
All of the alternatives, except for No Action, would result in
some improvement in groundwater quality over the long-term,
however they vary in the degree of long-term effectiveness and
permanence. Al ternati ves 3, 5.t and 8B . (source control
groundwater) would be more effective and permanent in the long-
term by eventually eliminating the residual risk downgradient of
the Landfill boundary. A~ternatives 2, 4, and 8A (no source.
control groundwater) would rely on institutional controls to
prevent exposure to contaminated groundwater. Although
institutional controls can be reliable, elimination of an
exposure pathway is more reliable and permanent particularly in
the long-term.
The operation of an SVE system in IWS 2 (Alternatives 4, 5, 8)
would not be any more reliable than capping in the prevention of
leaching of contaminants into groundwater. However; it would be
more permanent because it would reduce contaminant levels~
In summary, none of the alternatives totally eliminate residual
risk associated with the Site. Except. for No Action, the
alternatives rely on preventing exposure to soil and solid waste
by containment (capping). The source control groundwater
alternatives (3, 5, 8B) are more effective and permanent in the
long-term because they focus on eliminating risk associated with
exposure to contaminated groundwater, rather than a reliance on
institutional controls to prevent exposure. Among those three
Alternatives (3, 5, 8B), there is no significant difference in
long-term effectiveness and permanence.
4.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Alternatives 1 and 2 would not provide a reduction in contaminant
toxicity, mobility, or volume through treatment because they do
not provide for treatment as a principle element. Some treatment
of landfill gas may be included in Alternative 2.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
Alternatives which provide for an SVEsystem in IWS 2 (4, 5, and
8) would reduce the mobility, toxicity, and volume of
contaminants in IWS 2 soil. Toxicity would be transferred to
residual materials from the treatment process, such as used
carbon filters. The degree to which the toxicity and volume
would be reduced is uncertain.
Alternatives which extract a~d treat groundwater (3, 5, and 8B)
would reduce the volume, toxicity, and mobility of contaminants
in groundwater. Again, toxicity would be transferred to
treatment residuals, such as carbon filters and sludge, which
would be disposed at an appropriate facility or recycled.
Among Altern'atives 3, 5, and 8B, Alternatives 5 and,8B, ,which
combine SVE with groundwater extraction and treatm~nt, would
provide for the greatest reduction of toxicity, mobility, or
volume through treatment. The next greatest reduction of
toxicity, mobility, or volume through treatment would be
Alternative 3, which provides for groundwater treatment but no
SVE.
5.
Short-Ter.m Effectiveness
Alternative 1 (No Action) would pose the lowest risk to the
community and Site workers during implementation since there is
no construction involved. Potential short-term risks associated
with installation of the caps (Alternatives 2 through 8) would be
relatively small. Site workers would be potentially exposed to
contaminants during regrading and construction of the caps.
These exposures can be controlled through routine monitoring and
the implementation of health and safety measures. '
Alternatives 3, 5, and 8 involve a slightly higher risk for,
contaminant exposure to workers involved in the construction of
the groundwater extraction wells, treatment system, and discharge
lines. Construction of the SVE systems for Alternatives 4 and 5
would also pose a slightly greater short-term risk of exposure to
contaminants to Site workers.' Again, it is expected that these'
exposures can be controlled through routine monitoring and the
implementation of health and safety measures.
Except for Alternative 1, wetlands would be impacted in the
north~rn portion of the Site, where a portion of the Unnamed
Stream would be routed through a culvert beneath the SWDA cap, or
relocated adjacent to the cap. It is expected that mitigation
for any wetlands affected by cap construction would take place on
the Site. Groundwater extraction (Alternatives 3, 5, 8) is not
expected to significantly affect wetlands.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
Short-term protection of human health and the environment would
not be achieved by Alternative 1, since exposure to contaminated
soil, solid waste, or groundwater would not be prevented.
Alternatives 2 through 8 would achieve short-term protection of
human health and the environment through capping and
institutional controls to prevent the use of contaminated
groundwater. There would be no short-term attainment of
groundwater remediation goals under any of the alternatives.
However Alternatives 3, 5, and 8B should provide greater short-
term reduction of contaminant levels over Alternatives 2, 4, and
8A due to including source control groundwater extraction in the
remedy.
There is no significant difference in short-term effectiveness
among the alternatives 3, 5, and 8B, although Alternatives 5 and
8B would have slightly higher risks of exposure during
construction of the SVE system. .
6.
Implementability
All of the Alternatives evaluated are implementable. Alternative
1 would be the easiest to implement because it involves no
construction. For the other Alternatives, construction and
maintenance of the caps included in Alternatives 2 through 8
would be relatively easy to implement and utilizes standard
materials and construction techniques. Long-term environmental
monitoring is also relatively easy to implement. Although
institutional controls are implementable, they require the
cooperation of landowners, the Town of Lyndon, and the State of
Vermont.
Installation of the groundwater extraction and treatment system
(Alternatives 3, 5, 8) ut-ilizes standard materials and
construction techniques. For discharge of treated water into the
Passumpsic River, some of the discharge limits for metals may be
difficult to attain, even with pretreatment of the extracted
w~ter to remove inorganics. Treatment of groundwater by air
stripping, followed by GAC, is a reliable treatment technology.
Residuals from the treatment system, spent carbon and waste
sludge, would require additional treatment and/or off-site
disposal. The availability of off-site disposal facilities for
treatment residuals is uncertain in the long-term making these
Alternatives slightly more difficult to implement.
Construction and operation of the SVE system (Alternatives 4, 5,
8) utilizes standard construction practices and materials but may
be more difficult to implement due to low permeability of soil'
and presence of buried debris. Treatment residuals from this
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
system would also require off-site disposal adding to the
implementability concerns.
Among "Alternatives 3, 5, and 8B, Alternative 5 would be more
difficult than 3 and 8B to implement due to possible site-
"specific limitations on the SVE system.
7.
Cost
A comparison of the estimated present worth costs2 for each
Alternative is as follows:
Alternative
1
2
3
4
5
8A
BB
Total
Capital
$ 0
11,600,000
15,450,000
12,080,000
15,890,000
16,110,000
17,130,000
Total
Operation &
Maintenance
$ 40,000
2,010,000
12,710,000
3,380,000
14,080,000
12,270,000
15,370,000
Total Costs
$ 40,000
13,600,000
28,200,000
15,500,000
30,000,000
28,400,000
32,500,000
The estimated total costs for the alternatives that meet the
threshold criteria for protection of human health and the
environment and compliance with ARARs are:
Alternative 3 $ 28,200,000
Alternative 5 $ 30,000,000
Alternative 8B $ 32,500,000
8.
State Acceptance
The Vermont Department of Environmental Conservation (VT DEC) has
been involved with the study and oversight of the Parker Landfill
Site since the mid-1980s. The VT DEC has reviewed the Remedial
Investigation, Feasibility Study, and Risk Assessment reports.
The state's comments on the Proposed Plan, as received during the
public comment period, and the EPA's responses to their comments
are summarized in the Responsiveness Summary in Appendix E to
this Record of Decision. "
In general, the state supported the preferred alternative set
2 Total present"worth costs for each alternative are based
on 30 years of operation and a 7% interest rate.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
forth in the Proposed Plan. However, the State requested that
SVE.be further investigated as a remedial option at this Site.
The State also felt the cost estimates, as presented in the
Feasibility Study Report, were high.
The State's declaration of concurrence with this Record of
Decision is attached as Appendix c.
9.
Community Acceptance
The comments received from the community on the RI/FS and the
Proposed Plan during the public comment period, and EPA's
responses to the comments, are summarized in the Responsiveness
Summary in Appendix E of this document. In addition, a summary
of the comments appears below. .
Some community residents, including those directly affected by
groundwater contamination from the Site, expressed support of the
proposed remedy. Other community residents, the Town of Lyndon~
and some of the PRPs expressed opposition to implementing the
source control groundwater extraction and treatment system and
also expressed concerns with some aspects of the conceptual cap
. design.
The primary objections to the proposal for groundwater cleanup
were the long-term costs associated with this portion of the
remedy and the potential effects these costs might have on the
local economy. Many of the parties objecting to groundwater
cleanup felt that institutional controls alone should be used to
prevent exposure to contaminated groundwater. Some PRPs
eXpressed concerns regarding the amount of treatment residuals
that would be generated and the length of time for groundwater
cleanup.
Some PRPs and community members questioned the need for a multi-
layer (Subtitle C) cap on the SWDA area and an active gas
collection system for the cap.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
x.
THE SELECTED REMEDY
The remedy selected to address contamination at the Parker Landfill
Superfund Site is Alternative 3, which includes placement of multi-
layer caps on the SWDA and IWS areas, source control extraction and
treatment of groundwater, institutional controls, long-term
monitoring, and five-year reviews. This remedy addresses all of the
contamination at the Site. A detailed description of the cleanup
levels and the selected remedy is presented below. .
A.
Interim Groundwater Cleanup Levels
Interim cleanup levels have been established in groundwater for all
contaminants of concern identified in the Baseline Risk Assessment
found to pose an unacceptable risk to either public health or the
environment. Interim cleanup level.s have been set based on the ARARs
(e.g., Federal Drinking Water Maximum Contaminant Level Goals (MCLGs)
and MCLs, and Vermont Groundwater Quality Standards) as available, or
other suitable criteria descr~bed 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 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 groundwater
contamination to determine whether the remedial action is protective.
This risk assessment of the residual groundwater contamination shall
follow EPA procedures and will assess the cumulative carcinogenic and
non-carcinogenic risks posed by ingestion of groundwater and
inhalation of VOCs from domestic water usage.
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.
Because the aquifer at and beyond the compliance boundary for the
Landfill is a current and potential source of drinking water, and the
aquifer immediately to the west of the Site has excellent potential
for use as a municipal or industrial water source, MCLs and non-zero
MCLGs established under the Safe Drinking Water Act are ARARs. The
State of Vermont has classified the aquifer under and beyond the -
compliance boundary for the Landfill as Class III, suitable as a
source of water for individual domestic drinking water supply,
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ROD DECISION SUMMARy
PARKER LANDFILL SUPERFUND SITE
irrigation, agricultural use, and general industrial and commercial
use. Vermont Primary Groundwater Quality Standards established under
the Groundwater Protection Rule and Strategy are also ARARs.
Interim cleanup levels for known, probable, and possible carcinogenic
compounds (Classes A, B, and C) have been established 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 than 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, and C compounds) based on
a 10-6 excess cancer risk level per compound considering the ingestion
of groundwater from domestic water usage. .
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 represent 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 groundwater from domestic water usage.
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 practical quantification
limit or background value was used as appropriate for the Interim
Groundwater Cleanup Level.
Table I below summarizes the Interim Cleanup Levels for carcinogenic
and non-carcinogenic contaminants of 'concern identified in
groundwater. . .
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ROD DECISION SUMMARY.
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TABLE I:' INTERIM GROUNDWATER CLEANUP LEVELS
Carcinogenic Interim
Contaminants of Cleanup
ConcernCclass) Level Cua/l)
1,1-Dichloroethene(C) 7
Benzene (A) 5
Methylene Chloride(B2) 5
Tetrachloroethane (B2) 0.7
Tri9hloroethene(B2) 5
Vinyl Chloride(A) 2
Bis(2-Ethyelhexyl)
'. . Phthalate (B2)
Arsenic (A) .
,Beryllium (B2)
Basis
Level of
Risk
5x10-s
1.7xI0-6
4.5xI0-7
4 xl 0 -7
6 xl 0-7
4.6xI0-S
MCLG
MCL
MCL
VPGQSa
MCL
MCL
6b,
50
4
MCL
MCL
MCL
1x10-6
1.lx10-4
2.1x10-4
SUM
4.2x10-4
. Recent 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 risk estimates may be overestimated) .
It is Agency policy to manage these risks downward by as much as a .
factor of ten. As a result, the carcinogenic risk for arsenic at this
Site has been managed as if it were one order or magnitude lower than
the calculated risk. Consequently, the risk level for arsenic in the
above table reflects a risk management factor.
Non-carcinogenic Interim
Contaminants Cleanup
Concern CClass) Level Cua/l)
1,'1,1-Trichoroethane(D) 200
1, 1-Dichoroethene (C) 7
1,2-Dichloroethene
(total) (D)
2-Butanone
Acetone
4-Methylphenol
Antimony
Chromium (Hexavalent)
Manganese (D)
Nickel (B2)
Vanadium (D)
,Target
Basis Endpoint Hazard
of Toxicitv Ouotient
MCLG liver' 0.06
MCLG liver 0.02
of
70
170
3700
~OO
6
50
180
100
0.2
MCLC
VPGQSa
RBd
RBd
MCL
VPGQSa
RBd
MCL
RBd
blood
fetotox
liver/kid.
CNS
blood
no obs. eff.
CNS
wgt. gain
no obs. eff.
0.2
0.008
1.0
1.0
0.4
0.03
1.0
0.2
1.0
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
S~S
HI liver
HI blood
HI fetotox
HI Central Nervous System
HI no observed effects
HI weight gain
1.1
0.6
0.0008
2.0
1.0
0.2
a
Vermont Primary Groundwater Quality Standard - Enforcment
Standard, Vermont Groundwater Protection Rule and Strategy
b
Due to. the presence. of Bis(2-Ethylhexyl) Phthalate in the
background groundwater at the Site (possible contamination from
monitoring well materials), the cleanup levels will be.6 ug/l
(MCL) or background, whichever is higher, as determined by the
EPA and VT DEC during predesign and design activities.
~v::.
.~
c
d
MCL is for cis-1,2-dichloroethylene.
Risk-based.
While these interim cleanup levels are consistent with ARARs or
suitable TBC criteria for groundwater, 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 groundwater. 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 groundwater contamination to determine whether the remedial
action is protective. This risk assessment of the residual
groundwater contamination shall follow EPA procedures and will assess
the cumulative carcinogenic and non-carcinogenic risks posed by
ingestion of groundwater and inhalation of VOCs from domestic water
usage. .
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.
All Interim Groundwater Cleanup Levels identified .in the ~OD and newly
promulgated ARARs and modified ARARs which call into question the
protectiveness of the remedy and the protective levels determined as a
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
consequence of the risk assessment of residual contamination, must be
met at the completion of the remedial action at the points of
compliance which, in accordance with the NCP, are established at and
beyond the edge of the existing SWDA and IWS areas. EPA has estimated
that these levels will be obtained within 20 to 60 years after
completion of the source control component.
B.
Description of Remedial Components
~he selected remedy for the Site includes placement of multi-layer
caps on the SWDA and IWS areas, source control extraction and
treatment of groundwater, institutional controls, long-term.
monitoring, and five-year reviews. Each of the components are
described below: .
1.
. Multi-Layer Caps
The top slope areas of the SWDA and IWS areas will be graded at
approximately five percent and the side slopes will be graded at three
horizontal to one vertical (3:1) or flatter. No side slope will be
graded more steeply than 3:1. Prior to any intrusive activity,
erosion and sedimentation controls will be implemented to protect the
unnamed stream which runs along the boundary of the SWDA. These
controls will be inspected on a routine basis and maintained until
soil stabilization is established.
Grading of the Landfill will take into account the wetlands areas
associated with the unnamed stream and minimize adverse effects to
these areas. If it is impossible to grade the Landfill to avoid
wetland areas and the unnamed stream, a limited portion of the unnamed
stream will be re-routed beneath or adjacent to the SWDA cap.
A continuous multi-layer (or "composite barrier") cap will be
constructed over the SWDA and IWS 1. Separate multi-layer caps may.be
constructed on IWS 2 and IWS 3. All of the caps will be designed,
constructed, operated, .and maintained to meet the performa,nce .
requirements of the Resource Conservation and Recovery Act ("RCRA")
Subtitle C regulations specified in 40 C.F.R. Sections 264.19, 264.310
and 264.111 (these standards are incorporated by reference into the
Vermont Hazardous Waste Management Act, 10 V.S.A. Chapter 159). The
caps shall also be designed to meet the requirements of the following
EPA technical guidance documents: "Final Covers on Hazardous Waste
Landfills and Surface Impoundments" (EPA/530-SW-89-047, July 1989).;
"Construction Quality Management for Remedial Action and Remedial
Design Waste Containment Sys~ems" (EPA!540/R-92/073, October 1992);
and "QA and QC for Waste Containment Facilities" (EPA/600/R-93/182,
September 1993). The multi-layer caps will achieve the following
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
minimum requirements:
5.
6 .
1.
The base laver will be comprised of unclassified fill
material. This material is used to establish the base grade
of the Landfill. Given the steep eastern slope of the
Landfill, the base grade of this slope is expected to be a
maximum of 3:1 (horizontal:vertical). The top of the SWDA
and the IWS areas will be graded at approximately five
percent. This layer will be a minimum of six inches on the
top slopes and 12 inches on the 3:1 side slopes.
The. bottom low hvdraulic conductivitv laver will be
. installed to minimize potential leakage thro~gh the low
hydraulic conductivity geomembrane, into the Landfill. This
layer acts as a safeguard to the geomembrane on the IWS
areas and the top of the SWDA, and will consist of clay or a
geo-synthetic clay liner '(GCL). This layer will have a
hydraulic conductivity no greater than 1 x 10-7 em/sec.
Because clay and GCLs cannot be placed on steep slopes, this
layer will only be utilized on areas having slopes less than
or equal to 5%. On slopes greater than 5%, a silty sand or
sandy silt layer will be placed beneath the geomembrane to
enhance side slope stability. This soil will have a
hydraulic conductivity no greater than 1 x 10-4 em/sec.
2.
3 .
The tOD low hvdraulic conductivitv laver will be a synthetic
barrier. This will be the main barrier which prevents water
infiltration from entering the Landfill. This synthetic
barrier will be a type of flexible geomembrane, 40 mil VLDPE
or equivalent, selected to prevent infiltration. The
geomembrane on the slopes greater than 5% must be t~xtured
to mini~ize the potential for sliding.
A drainaqe laver will be installed above the synthetic
barrier to prevent the ponding of water over the synthetic
barrier. This layer will be composed of either 12 inches of
sand with a minimum hydraulic conductivity of 1 x 10-2
cm/sec, or a synthetic material with a transmissivity of at
least 3 x 10-4 m2/sec or other equivalent material. The sand
should be no coarser than 3/8 incb.
4.
The filter laver will ,be composed of nonwoven geotextile
filter fabric to minimize fill material from clogging the
drainage layer.
The tOD laver will be the vegetative cover. This layer
will: (1) provide frost protection; (2) provide adequate
water-holding capacity to attenuate rainfall infiltration to
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
the drainage layer and to sustain vegetation through dry
periods; and (3) provide sufficient thickness to allow for
expected long-term erosion losses. The side slope will be
terraced to minimize erosion of the multi-layer caps so that
no more than 2 tons per acre per year of soil loss occurs.
The top layer will consist of a minimum of 24 inches of fill
material, with the top 12 inches consisting of a material
that will facilitate good vegetative growth. No deep-rooted
plants will be allowed to become established on the capped
.area.
Air: A landfill gas management system will be implemented to
insure that landfill gas does not build up beneath the caps or
migrate laterally. In addition, a collection system will insure
that gases containing VOCs in the IWS areas are properly treated
prior to venting. The appropriate gas management system for the
SWDA, IWS 1 and IWS 3 will be determined during pre-design and
will be based on the compliance criteria discussed below. An
active gas collection system, which maximizes the removal and
treatment of contaminants from the vadose zone, will be installed
in IWS 2. This system will be designed in such a way which
maximizes vapor contaminant removal in both the waste mass and
the underlying contaminated soil. This system will be operated
and maintained until no VOCs are detected in soil vapor
concentrations. The appropriate monitoring frequency and
duration will be developed during the design phase.
The point of compliance for air, consistent with the NCP, shall
be the point(s) of the maximum exposed individual, considering
reasonable expected used of the Site and surrounding area. The
maximum exposed individuals include: (1) adjacent residents; (2)
operation and maintenance personnel; and (3) individuals working
at the facility. The gas collection system shall not allow for
an unacceptable risk of exposure to the maximum exposed
individuals by controlling the release of landfill gas and
treating collected landfill gas. The gas collection and
treatment system shall also Gomply with federal and state air
regulations, including but not limited to Vermont air pollution
control regulations (10 VSA Chapter 5), the federal Clean Air
Act, and the proposed rule for landfill gas management (Federal
Register 244:88, May 30, 1991). .
Surface Water/Wetlands: Surface water drainage controls will be
constructed to minimize erosion of the caps. As determined by
the final design, drainage channels will be installed in certain
areas on the top and perimeter of the Landfill caps to channel
runoff away from the Landfill to a stormwater retention pond.
The capped areas will also be revegetated and the vegetation
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
maintained to prevent erosion. Stormwater runoff from the
Landfill will be managed in accordance with Vermont Water Quality
Standards. The drainage system of the caps must be capable of
handling a 25 year, 24 hour storm event.
Mitigation for wetlands, including the unnamed stream and
associated wetlands, which are unavoidably impacted by the
capping of the Landfill, will be accomplished consistent with
State and Federal laws and guidance. Potential successful
mitigation sites will be identified on the basis of topographic
location, water source and transport, hydrodynamics, and site
morphometry and soils. On-site and in-kind mitigation is
preferable where achievable. Mitigation must provide, at a
minimum, one for one functional replacement, with an adequate
margin of safety to reflect the expected degree of success.
associated with the mitigation plan. It is anticipated that
minimum mitigation ratios for this site will be 1.5/1.0 for
restoration and 2.0/1.0 for creation. Creation of any wetlands
will need to take into account buffer zones and upland transition
zones. A reference wetland will be identified and used to
monitor and evaluate the impact of natural fluctuations on the
mitigation success.
Pre-Design Studies: Prior to the design of the caps, the gas
collection system, surface water controls, and wetlands
replication, the following p~e-design studies will be completed:
a. A geotechnical investigation to define the properties
of the SWDA foundation soils, with a focus on slope
stability and potential settlement. This investigation
will also assess the feasibility of waste relocation
for minimization of wetlands impacts.
A hydrological study to evaluate impacts of the caps
and provide design criteria for culvert sizing and
wetlands mitigation.
A soil gas survey to evaluate the quality and quantity
of gas production and to evaluate the potential extent
of gas migration beyond the Landfill boundaries. This
information will be used to design the gas collection
and treatment system and to determine if there is a
need for remediation systems outside of the Landfill
boundaries. .
A storm water/erosion control management system study
to provide design criteria for erosion and.
sedimentation control and storm water management during
and after cap construction.
An evaluation to insure the appropriate thickness of
the top layer to: (I) provide frost protection; {2} .
provide adequate water-holding capacity to attenuate
b.
c.
d.
e.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
rainfall infiltration to the drainage layer and to
sustain vegetation through dry periods; and (3) provide
sufficient thickness to allow for expected long-term
erosion losses.
Lonq-term monitorinq/maintenance: The integrity of the caps, the
gas collection system, surface water controls, and wetlands
replication will. be monitored regularly and maintained to meet
the objectives set forth in this ROD. Access to the capped areas
.will'be controlled by the installation and maintenance of an
industrial fence. .
.2.
Sour~e Control Groundwater Extraction and Treatment
The goal of this remedial action is to restore groundwater at and
beyond the edge of the waste management ~nits to its beneficial use,
which is, at this Site, an actual and potential source of drinking
water. Currently, both the overburden and bedrock aquifers
downgradient of the Landfill are being used as a residential drinking
water source. In addition, the Site is in one of the few areas in the
region that has a high potential for development of public .and
industrial water supplies.
Based on information obtained during the remedial investigation and on
a careful analysis of all remedial alternatives, EPA believes that the
selected remedy will achieve this goal by containing contamination at
the source and allowing for the natural restoration of the'
downgradient aquifers. ~ased on current data, EPA believes that
groundwater downgradient of the Landfill will be restored to its
beneficial use in 20 - 60 years after implementation of the
groundwater component of this ROD.
A groundwater extraction and treatment system will be installed for
the purpose of the containment of contaminants which exceed interim
groundwater cleanup levels (see Section X.A. above) at the point of
compliance. The.point of compliance is defined as the vertical
surface located at the hydraulically downgradient limit of the waste
management area (including the SWDA and IWS areas) that extends down
into the uppermost aquifer underlying the waste management unit.
Contaminants in the overburden and bedrock aquifers downgradient of
. the point of compliance will be restored through natural attenuation
processes once the source of contamination is controlled at the point
of compliance. .
The conceptual extraction design presented in the Feasibility Study
was based on the use of four extraction wells'in the' overburden and
one extraction well in the bedrock. The exact number and location of
wells necessary to contain the contaminant plume at the point of
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
compliance will be determined during the design phase. EPA retains
the flexibility to modify or enhance the extraction system to increase
effectiveness and/or decrease costs and time of operation.
Modifications/enhancements may include (but are not limited to) :
phasing the design/installation of the extraction systemj installing
horizontal extraction wells, collection trenches, or subsurface
barriers; reinjection of treated water; pulsed pumping; and air
sparging.
The conceptual design and cost estimation for treatment of extracted
groundwater presented in the Feasibility Study included air stripping
and GAC polishing. It also included a pretreatment step consisting of
inorganics removal using carbonate/hydroxide precipitation. The actual
technologies and sequence of technologies used for the treatment train
will be determined during remedial design.
Contaminated groundwater must be treated to meet interim groundwater
cleanup levels (see Section X..A. above) and requirements for discharge
of treated water. It is anticipated that treated groundwater will be
discharged to the Passumpsic River. The discharge will have to meet
the substantive requirements of the Vermont Water Quality Standards.
Other discharge options include: 1) discharge to a POTWj or 2)
rei~jection of treated groundwater on the Site. . These alternative
discharge options will undergo further evaluation during the remedial
design to determine which is the most .effective and least costly
alternative. Should one of these discharge options be selected, the
discharge must meet all ARARs for that option. .
The groundwater extraction and treatment system will operate until
interim groundwater cleanup levels (See Section X.A.) are met at the
point of compliance and the remedy is determined to be protective. .
During this time, the system's performance will be carefully monitored
on a regular basis and. adjusted as warranted by the performance. data
collected during operation. Modifications/enhancements may include
(but are not limited to) : .
a.
discontinuation of pumping at individual wells ~here cleanup
goals have been attained and maintained;
alternating pumping at wells to eliminate stagnation points;
b.
c.
installation of additional extraction wells, horizontal
extraction wells, collection trenches, or subsurface
barriers to facilitate or accelerate cleanup of the
contaminant plume;
d.
reinjection of treated groundwater;
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
e.
pulsed pumping to allow aquifer equilibration and encourage
adsorbed contaminants to partition into groundwater; and
f.
air sparging to facilitate or accelerate cleanup of the
contaminant plume.
If, as a result of performance monitoring over time, it is determined
that a groundwater extraction system is not able to contain .
contaminants at the point of compliance, or that the system has
reached a steady-state in which contaminant levels have ceased to
decline over time and have remained constant for a specified period of
time at some statistically significant levels over groundwater cleanup
levels, EPA will reevaluate the remediation goals and consider
modification or discontinuation of the groundwater extraction and
treatment system. Any change in remediation goals or discontinuation
of the groundwater extraction and treatment system will be
accomplished through an Explanation. of Significant Differences (ESD)
or an amendment to the Record of Decision.
Pre-Desiqn Studies: Prior to the design of the groundwater extraction
and treatment system, the following pre-design studies will be .
completed:
a.
an evaluation of alternatives for discharge of treated water
and disposal of residuals;
b.
treatability studies to determine the most appropriate and
cost effective technologies to be included in the treatment
train;
c.
bioassay toxicity testing to determine site specific
discharge limitations, if treated. groundwater is to' be
discharged to surface water;
d.
a pipeline survey to determine construction techniques of
the discharge pipe; and
e.
a geotechnical study to determine the best location for the
treatment facility.
3. Institutional Controls
Institutional controls will be established to protect the capped
areas, to prevent the use of groundwater potentially impacted by the
Site, and to inform future purchasers of property of the groundwater
restrictions associated with the property. These institutional
controls will consist of deed restrictions and local or state
regulations which are enforceable and reliable for long-term
protection. Restrictions to protect the Landfill caps will include
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
controlling access to the capped areas (e.g. a fence) and prohibiting
excavation or other disturbances which may adversely affect the
integrity of the caps.
The restrictions on use of groundwater will extend from the upgradient
perimeter of the Landfill to all downgradient boundaries of the
contaminant plume in both overburden and bedrock. The restrictions
will also include a buffer zone around the contaminated area adequate
to insure that new private or public water supply wells in the. .
vicinity would not induce movement of the contaminants into
uncontaminated areas or interfere with any remedial action at tne
Site. Groundwater use restrictions will remain in effect until
contaminant levels reach groundwater cleanup levels (see Section X.A.)
in the bedrock and overburden aquifers downgradient of the point of
compliance. .
4.
Long-Ter.m Monitoring
An environmental monitoring program will be implemented to evaluate
the performance of the groundwater treatment system and the overall
effectiveness of the remedy. The monitoring program will include
selected groundwater monitoring wells, and surface water and sediment
in the unnamed stream and the Passumpsic River. In addition,
groundwater in overburden and bedrock monitoring and/or residential
wells immediately downgradient of the contaminated area will be
monitored on a regular basis to insure that the contaminant plume is
not spreading into previously uncontaminated areas.
Performance monitoring will be conducted to insure the proper
operation of the remedy. Performance monitoring will include periodic
monitoring, and necessary maintenance, of the capped areas, landfill
gas collection/treatment system, and any wetland replication areas
associated with the remedy. In addition, the groundwater treatment
system influent and discharge will be monitored regularly.
5.
Five-Year Review
To the extent required by law, EPA will review the Site at least once
every five years after initiation of the remedial. action at the Site
if any hazardous substances, pollutants or contaminants remain at the
Site to assure that the remedial action continues to protect human
health and the environment. EPA will also review the Site before the
Site is proPQsed for deletion from the National Priorities List (NPL).
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
XI.
STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Parker Landfill
Superfund Site is consistent with CERCLA and, to the extent.
practicable, the NCP. The selected remedy is protective of human
health and the environment, attains ARARs and is cost effective. The
selected remedy also satisfies the statutory preference for treatment
which permanently and significantly reduces the mobility, toxicity or
volume of hazardous substances as a principal element. 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
specifically installation of Landfill caps will prevent ingestion and
dermal contact of soil or solid waste. Capping will also prevent
further transport of contaminants into stream sediments. Capping will
effectively eliminate infiltration and thereby halt the leaching of
contaminants from the soil and solid waste into groundwater. This
will ultimately result in an improvement of downgradient groundwater
quality and a reduction of the risks to human health associated with
ingestion of contaminated groundwater. Institutional controls will be
implemented to prevent the use of contaminated groundwater until
cleanup goals have been met. Long-term monitoring will insure that
the remedy remains protective of human health and the environment.
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
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 groundwater contamination to determine
whether the remedial action is protective. This risk assessment of
the residual groundwater contamination shall follow EPA procedures and
will assess the cumulative carcinogenic and non-carcinogenic risks
posed by ingestion of groundwater and inhalation of VOCs from domestic
water usage. If, after 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 not been
exceeded for a period of three consecutive years, or until the remedy
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
is otherwise deemed protective. These protective residual levels
shall constitute the final cleanup levels for this Record of Decision
and shall be considered performance standard~ for any remedial action.
B.
The Selected Remedy Attains ARARs
This remedy will meet or attain all applicable or relevant and
appropriate federal and state requirements. that apply to the Site. A
detailed listing of environmental laws from which ARARs for the
selected remedial action are derived, and the specific ARARs can be
found in Appendix B of this ROD. These tables give a brief synopsis
of the ARARs and an explanation of the actions necessary to meet the
ARARs. These tables also indicate whether the ARARs are applicable or
relevant and appropriate to actions at the Site. In addition to
ARARs, the tables describe standards that are To-Be-Considered (TBC)
. with respect to remedial actions. Environmental laws from which the
ARARs for the selected remedial action are derived, and the specific
ARARs include:
Chemical-Scecific
Vermont Air Pollution Control Regulations
Federal NESHAP for Vinyl Chloride
Federal NESHAP for Benzene Waste Operations
Vermont Hazardous Waste Regulations
Vermont Groundwater Protection Regulations
Resource Conservation and Recovery Act (RCRA) -- Groundwater
Protection Standards Subpart F
Federal Safe Drinking Water Maximum Contaminant Levels (MCLs)
Federal Safe Drinking Water Maximum Contaminant Level Goals
. . (MCLGs).
Federal Safe Drinking Water National Secondary Maximum
Contaminant Levels (SMCLs) (TBC)
Federal Safe Drinking Water Proposed MCSs for Synthetic Organic
Chemicals and Inorganic Chemicals (TBC)
Federal Drinking Water Health Advisories (TBC)
Federal Groundwater Protection Strategy (TBC)
Federal Interim Sediment Quality Criteria (TBC)
Action-Scecific
Vermont Hazardous Waste Regulations
Vermont Solid Waste Regulations.
RCRA Air Emissions Standards for Process Vents Subpart AA
RCRA Air Emissions Standards for Equipment Leaks Subpart BB\
Clean Air Act, National Emissions Standards for Hazardous Air
Pollutants (NESHAP)
Federal Noise Control Regulations
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
Vermont Land Use and Development Law
Vermont Water Quality Standards
Vermont NPDES Permit Program Regulations
Federal Quality Criteria for Water
Proposed Rule for Landfill Gas Management
Federal Solid Waste Regulations (TBC)
EPA Technical Guidance Document: Final Covers on Hazardous
Landfills and Surface Impoundments (TBC)
Federal Proposed Regulation for Control ofVOCs (TBC)
Waste
Location~Specific
, Vermont Hazardous Waste Regulations
Vermont Solid Waste Regulations
Vermont Wetland Rules
. Federal Guidelines for Specification of Disposal Sites for
Dredged or Fill Material
Federal Fish and wildlife Coordination Regulations
Federal Army Corps of Engineers Nationwide Permit Program
Regulations
Federal Executive Order 11990 - Protection of Wetlands (TBC)
Federal Executive Order 11988 - Floodplain Management (TBC)
Principal Hazardous Waste ARARS
RCRA regulations and the current State of Vermont Hazardous Waste
Regulations are applicable to this remedy. In those'limited instances
where these regulations may conflict, the more stringent regulation
will be followed. Since RCRA-type wastes were disposed of in both the
SWDA andIWS areas during their operation, which included disposal
after 1980, the cap design and construction for both units will meet
both RCRA and Vermont Hazardous Waste standards. There is evidence
that at least one potentially responsible party at this Site, and.
perhaps more, disposed of RCRA-type wastes in the SWDA after 1980. .
Sludge generated by the groundwater treatment unit, if determined to
be RCRA waste, must also be removed from the Site, transported, and
disposed of in accordance with RCRA and state requirements.
Vermont Land Use and Development Law Act 250 specifies ten criteria
that must be addressed by an improvement to property. The Act is
relevant and appropriate to this Site and the selected remedy will
comply with the requirements, including no undue air or water
pollution and compliance with wetlands rules, through proper design
and implementation of the remedial action.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
PrinciDal ARARs for Groundwater Protection
It has been determined by EPA that the groundwater in the overburden
and bedrock aquifers beyond the points of compliance is a current
drinking water source and a potential future drinking water source.
While Maximum Contaminant Levels (MCLs) and Maximum Contaminant Level
Goals (MCLGs) promulgated under the federal Safe Drinking Water Act
are not applicable to groundwater, they are relevant and appropriate
to groundwater cleanup because the groundwater is being used and may
be used in the future as a drinking water source. Also, a portion of
the aquifer near the Passumpsic River has excellent potential for
future development of municipal and commercial/industrial water
supplies. In addition, the NCP requires that usable groundwaters be
restored to their beneficial uses whenever practicable. See 40 CFR
300.430 (a) (iii) (F) . .
Primary Groundwater Standards, contained in the State of Vermont
Groundwater Protection Act and Groundwater Quality Standards (10
V.S.A. Chapter 47 and 48) are _applicable. The aquifer is classified
by the State of Vermont as a Class III aquifer, suitable as a source
of water for individual domestic drinking water supply, irrigation,
agricultural use, and general industrial and commercial use. A
management objective for Class III ground waters is compliance with
the Vermont Groundwater Standards. There is currently a
reclassification petition before the Secretary of the Vermont Agency
of Natural Resources to reclassify groundwater in the vicinity of the
landfill to Class IV, suitable for some agricultural, industrial and
commercial use but not as a source of potable water. A management
objective for Class IV groundwater is to achieve the Vermont
Groundwater Standards to the extent feasible. The selected remedy
will comply with these ARARs by achieving the standards at and beyond
the point of compliance for the Site.
PrinciDal ARARs/TBCs for Wetland Protection
The federal Clean Water Act and the Vermont Wetland Rules are ARARs
for the portion of the remedy constructed in or affecting the wetlands
at the Site. Executive Order 11990 (Protection of Wetlands) is a To
Be Considered requirement. These rules prohibit activity adversely
affecting a wetland if there exists a practicable alternative which is
less detrimental. Because of the Landfill's proximity to the wetlands
surrounding the unnamed stream, it may be necessary for the cap to
extend into portions of the wetland area. In.the short term, .
construction will be conducted to avoid or minimize the damage to
flora and fauna within the wetland. Additionally, after construction
is completed, those wetlands which are lost will be replaced,
preferably on-site.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
Vermont Land Use and Development Law Act 250 specifies ten criteria
that must be addressed by an improvement to property. The Act is
relevant and appropriate to this Site and the selected remedy will
comply with the requirements, including no undue air or water.
pollution and compliance with wetlands rules, through proper design
and implementation of the remedial action.
princiual ARARs for Air Oualitv Protection
Air quality protection requirements are action specific. Federal
National Ambient Air Quality Standards (NAAQS) are not ARARs but are
guidelines for specific criteria pollutants for air emission sources.
NAAQS define levels of air quality which the EPA judges are necessary
to protect public health. The State Air Pollution Control Regulations
must contain, at a minimum, the federal air quality requirements:
Whereas the National Emission Standards for Hazardous Air Pollutants
(NESHAPs) address VOC emissions from specific sources. Proposed
federal air regulations also require the collection, control and
monitoring of Non-Methane Organic Compounds (NMOCs) such as benzene
and ethane. RCRA requirements for air emissions from thermal units,
process vents and equipment leaks are also included as potential
ARARs .
State Air Pollution Control Regulations establish air quality
standards and allowable discharges and list hazardous contaminants and
set Hazard Limiting Values and Action Limits. The federal and state
regulations which set standards for VOC emissions from certain
industries will be relevant and appropriate to set limits on the
emissions from any treatment system used at the Site. The remedy will
attain these ARARs as well as those identified in the tables in
Appendix B through the design and operation of the landfill gas
collection and treatment system.
Princiual ARARs for Surface Water Protection
Several different ARARs address the protection of surface water bodies
(including wetlands which are addressed separately in this section) .
If treated groundwater is discharged to surface water, ARARs include
the Vermont Water Quality Standards and the substantive state and
federal requirements of the NPDES provisions of the Clean Water Act.
In those instances where state and federal standards differ, the more
stringent will be followed. If treated groundwater is discharged to a
POTW, the ARARs will be met for that alternative.
C.
The Selected Remedial Action is Cost-Effective
In the Agency's judgment, the selected remedy is cost effective, i.e.,
the remedy affords overall effectiveness proportional to its costs.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
In selecting this remedy, once EPA identified alternatives that are
protective of human health and the environment and that attain, or, as
appropriate, waive ARARs, EPA evaluated the overall effectiveness of
each alternative by assessing the relevant three criteria--Iong term
effectiveness and permanence; reduction in toxicity, mobility, and
volume through treatment; and short term effectiveness, in
combination. The relationship of the overall effectiveness of this
remedial alternative was determined to be proportional to its costs.
The present worth costs of this remedial alternative, as presented in
th~ Proposed Plan, are:
Estimated Capital Cost:
Estimated Operations and Maintenance Cost:
Estimated Total Cost:
$15,450,000.
$12,710,000..
$28,200,000.
For comparison, the estimated total costs for the alternatives. that
meet the threshold criteria for protection of human health and the
. environment and compliance with ARARs are:
Alternative 3 $ 28,200,000
Alternative 5 $ 30,000,000
Alternative 8B $ 32,500,000
The selected remedy (Alternative 3) is the least expensive of those
alternatives that meet the threshold criteria. Alternative 5 includes
an SVE system in IWS 2. EPA feels that the additional costs for this
alternative are not warranted, since capping of IWS 2 will be
effective in reducing exposure and eliminating infiltration of
contaminants to groundwater. In addition, an active gas collection
system in this area would serve to remove some VOC contaminants and
have a similar benefit to an~VE system., The additional costs for
Alternative 8B are related to extraction and treatment of groundwater
downgradient of the Landfill. Extraction and treatment in the
downgradient plume would not appreciably reduce the time for
restoration of this area to drinking water standards. Therefore, EPA
believes that these additional costs are not justified.
D.
The Selected Remedy Utilizes Per.manent Solutions and Alternative
Treatment or Resource Recovery TechnOlogies to the Maximum Extent
Practicable
Once the Agency identified those alternatives that attain or, as
appropriate, waive ARARs and that are protective of human health and
the environment, EPA identified which alternative utilizes permanent
solutions and alternative treatment technologies or resQurce recovery
technologies to the maximum extent practicable. This determination
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
was made by deciding which one of the identified alternatives provides
the best balance of trade-offs among alternatives in terms of: 1)
long-term effectiveness and permanence; 2) reduction. of toxicity,
mobility or volume through treatment; 3) short-term effectiveness;
4)implementability; and 5) cost. The balancing test emDhasized long-
term effectiveness and permanence and the reduction of toxicity,
mobility and volume 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 (Alternative 3) provides long-term effectiveness
through capping of the SWDA and IWS areas to prevent exposure to
contaminated soil and solid waste. Capping will also prevent
continued migration of contaminants to groundwater, surface water, and
sediments in the long-term. The selected alternative also provides
long-term effectiveness through the eventual elimination of residual
risk in groundwater downgradient of the Landfill. In that regard, it
provides greater long-term effectiveness and permanence than
alternatives which relied solely on.institutional controls in
preventing exposure to contaminated groundwater for an indefinite
period of time. Although the SVE system proposed for IWS 2 in
Alternatives 4, 5, and 8 would provide more permanence by reducing
VOCs in the soils, these alternatives did not appreciably increase the
long-term effectiveness over capping and active gas collection. All
of the alternatives (except for the No Action Alternative) were
similar in their short-term effectiveness and implementability.
The selection of the remedy also considered the preference for
treatment as a principal element. Alternatives 2 and 6 did not
utilize treatment at all, and alternative 5 utilized treatment through
an SVE system but did not include treatment of contaminated
groundwater.
In selecting the remedy, EPA considered both state and community
acceptance. The State of Vermont is supportive of Alternative 3 as .
the selected remedy but had expressed a desire to further evaluate SVE
for IWS 2, similar to Alternative 5. On the other hand, some
Potentially Responsible Parties and community members questioned the
need for even an active gas collection system in the SWDA and the IWS
areas. In response to these comments, EPA has chosen to retain and
maximize active gas collection for IWS 2, containing the highest. soil
contaminant levels, and allowing for pre-design studies to determine
if active gas collection is necessary in the SWDA, IWS 1, and IWS 3.
This approach will allow for removal.of VOCs from the soil in IWS 2,
in response to the State's. concern, but allow for the potential for a
passive gas collection system in the other areas.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
Community acceptance of the remedy is divided. Those directly
affected by the groundwater contamination from the Site, and some
other community residents, have expressed support for the remedy.
Others in the community, the Selectmen of the Town of Lyndon, and some
of the PRPs opposed groundwater cleanup on the basis of the long-term
costs associated with this remedy. EPA has chosen to select a remedy
that combines containment of contaminants at the source with natural
restoration of the downgradient aquifer. This remedy is protective of
human health and the environment, meets ARARs, and is supported by the
State and a portion of the community. In response to the portion of
the community that has expressed concerns about the cost, EPA re-
evaluated the costs for the selected remedy, -which resulted in a
'significant change from the Proposed Plan. An explanation of these
significant changes can be found in Section XII of this ROD. In
addition, EPA has provided the maximum flexibility in the design of
the remedy, so that technologies and discharge options can be chosen
which minimize costs. For example, EPA is allowing for a pre-design
evaluation of options for discharge of treated groundwater and for
landfill gas management.
E.
The Selected Remedy Satisfies the Preference for Treatment Which
Permanently and Significantly reduces the Toxicity, Mobility or
Volume of the Hazardous Substances as a Principal Element
CERCLA and the NCP set forth the process by which remedial actions are
evaluated and selected. Because many CERCLA municipal landfill sites
share similar characteristics, they lend themselves to remediation by
similar technologies. EPA has established a number of expectations as
to the types of technologies that should be considered and
alternatives that should be developed; they are listed in the National
Contingency Plan (40 CFR 300.430 (a) (1)) and EPA Guidance Document
"Conducting Remedial Investigation/Feasibility Studies for CERCLA
Municipal Landfill Sites" EPA/540/P-91/001. For CERCLA municipal.
landfill sites, it is expected that:
1.
2 .
3 .
The principal threats posed by a site will be treated wherever
practical, such as in the case of remediation of a hot spot.
Engineering controls such as containment will be used for waste
that poses a relatively low long-term threat or where treatment
is impractical.
A combination of methods will be used as appropriate to achieve
protection of human health and the environment. An example of
combined methods for municipal landfill sites would be treatment
of hot spots in conjunction with containment of the landfill
contents.
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ROD.DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
4.
Institutional controls such as deed restrictions will be used to
supplement engineering controls, as appropriate, to prevent
exposure to hazardous wastes.
5.
Innovative technologies will be considered when such technologies
offer the potential for superior treatment performance or lower
costs for performance similar to that of demonstrated
technologies.
6.
Groundwater will be returned to beneficial uses whenever
practical, within a reasonable time, given the particular
circumstances of the site.
The remedy selected in this ROD satisfies the expectations set forth
in CERCLA and the NCP for treatment of CERCLA municipal landfill
sites. Potential exposure to and ingestion of contaminated
groundwater is the principal threat posed by the Site. The selected
remedy is a containment remedy which uses engineering controls .
supplemented by institutional .controls. EPA has determined that it is
not practical to treat the hot spots (IWS areas). EPA has also
determined that a source control groundwater containment remedy will
be effective in the restoration of groundwater and that a more
aggressive groundwater restoration strategy would not provide
additional benefits at this Site.
The selected remedy satisfies the statutory preference for treatment
as a principal element by treating the extracted groundwater in
treatment processes which result in the removal of contaminants. This
action will reduce the toxicity, mobility, and volume of contaminants
in groundwater.
XII. DOCUMENTATION OF SIGNIFICANT CHANGES
EPA presented a proposed plan (preferred alternative) for
remediation of the Site on July 6, 1994. The preferred alternative
included: .
..
Construction of multi-layer caps over the SWDA and three IWS
areas;
.
Construction and operation of a source control {containment}
groundwater extraction and treatment system and natural
restoration of the downgradient aquifer;
Implementation of institutional controls:
.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
.
Long-term environmental monitoring: and
.
Five-year reviews.
The selected remedy in this ROD is generally consistent with the
proposed plan. As a result of public comments regarding the cost of
the remedy, however, EPAhas performed a detailed evaluation of the
remedial costs presented in the Feasibility Study and has developed a
revised estimated cost for the selected remedy. Significant revisions
to the estimated cost of the remedy are summarized here and the basis
of all cost revisions are detailed in Appendix F to this ROD and in
the Administrative Record. .
Duplicative costs included in the Feasibility Study for operations and.
maintenance of the cap and groundwater extraction and treatment system
were eliminated in the revised cost estimate. In addition, EPA also
reduced its anticipated long-term monitoring requirements which
lowered the estimated cost. .
Further, it was assumed that the groundwater treatment plant would be
automated and not require a full-time operator after the initial
start-up. Consequently, labor costs for the groundwater treatment
plant were reduced over time. Costs were also reduced for recycling
and replacement of spent carbon, based on the fact that contaminant
levels in the treatment plant influent will decrease over time.
Likewise, costs were reduced for disposal of gas condensate based on a
decrease over time. The Feasibility Study estimated that 50% of the
treatment plant residuals would require disposal as hazardous waste.
Based on EPA's experience, 10% or less of these residuals would be
classified as hazardous waste, decreasing disposal costs over the life
of the treatment plant. Health and safety and engineering costs were
also reduced, consistent with other Superfund Site cost estimates.
Costs for the following items which were not included in the
Feasibility Study were added to the revised cost estimate: mobile home
relocation, condensate traps, condensate tanks, stormwater management,
wetlands impact study, wetlands mitigation, and cap installation.
The revised cost estimate for the selected remedy"is:
Total
Total Operation &
Caoital Maintenance
Groundwater $1,554,925 $4,688,798
Capping $6,983,064 $ 865,967
TOTAL COST: $14,092,753
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
It should be noted that the cost estimates in both the Feasibility
Study and the EPA cost revision are estimates and not actual costs
related to design and construction. These estimates are used to
compare alternatives and it is expected that actual costs will vary
anywhere from +50% to -30%. Actual costs are dependant, among other
factors, upon the materials used and the outcome of pre-design
studies.
In response to a question raised during the public comment period, EPA
has also evaluated the potential for using local materials and labor
for the selected remedy. It is estimated that approximately 40% of
the costs for the selected remedy could be spent locally (see Appendix
F of this ROD). The use of local materials and labor will be
encouraged to the extent practicable.
Although not as significant, some additional changes have been made
and are summarized here. The proposed plan specified that extracted
groundwater would be treated with a treatment train including chemical
precipitation, air stripping, and GAC polishing. In order to insure
that the most effective and least costly treatment train is used, the
selected remedy does not identify specific technologies which must be
used. .
The proposed plan specified that treated water would be discharged to
the Passumpsic River. Although this is retained in the selected
remedy as the most likely discharge option, flexibility is included to
further evaluate and chose other discharge options, such as on-site
reinjection or discharge to a POTW. This is to insure that the most
cost-effective discharge method is used.
The proposed plan specified that an active gas. collection system would
be installed in the SWDA and IWS areas. To insure that the most cost-
effective system that is able to meet the legal and technical
requirements of landfill gas management is used, the selected remedy
specifies that pre-design studies will determine the type of gas
collection system to be used in the SWDA, IWS 1, and IWS 3. Active
gas management has been retained for IWS 2, since VOC levels in soil
are highest at this location. In addition, ,the selected remedy
specifies that active gas collection system will be maximized in this
area, in response to the State of Vermont's preference for extraction
and treatment of soil vapors from this waste area.
With regard to the Landfill caps, the layers in the proposed plan are
consistent with the layers in the selected remedy, however the
selected remedy includes some flexibility to use alternative materials
that may be less costly and/or promote recycling/reuse.
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ROD DECISION SUMMARY
PARKER LANDFILL SUPERFUND SITE
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, Risk
Assessment and Feasibility Study to determine if the selected remedy
is in compliance with applicable or relevant and appropriate' State
environmental laws anq regulations. The State of Vermont concurs with
the selected remedy for the Parker Landfill Superfund Site. A copy of
the declaration of concurrence is attached as Appendix C.
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APPENDIX A
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Appendix A - Tables and Figures
Table 1 - Site and Site Vicinity Ground Water
Table 2 - SWDA Surface Soils (0-2 feet)
Table 3 - Surface Soils For IWS-1 Area
Table 4 - Surface Sqils For IWS-2 Area
Table 5 - Surface Soils For IWS-3 Area
Table 6 -.Subsurface Soils For SWDA (2-16 feet)
Table 7 - Deep Subsurface Soils For SWDA (>16 feet)
Table 8
Subsurface Soils For IWS Areas. (2-16 feet)
Table 9 - Deep Subsurface Soils For IWS Areas
(>16 feet)-
Table 10 - Sediment & Downgradient Sediment For Passumpsic
River.
Table 11 - Sediment For Unnamed Stream
Table 12 - Surface Water - Passumpsic River
Table 13 - Surface Water - Unnamed Stream
Table 14 - Air Data
Table 15 - Leachate Data
Table 16 - Summary of Carcinogenic Risks Estimated for the
Parker Landfill Site
Table 17 - Summary of Noncarcinogenic Hazard Indices (HI)
Estimated for the Parker Landfill Site
Table 18 - Comparative Analysis Summary
Figure 1 - Site Location
Figure 2 - Site and Vicinity
Figure 3 - Contaminants in Groundwater Above MCS or VES Outside
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TABL::: 1 - CONTAM!NANTS OF CONC:::;;':; - SITE AND SITE '1::::!NI'!'Y GROUNIJ ;;ATER
NOTE: 1. All soil/sedime~: =esults in ug/kg except inorganic results
which are in mg/~=; all water resul:s in ug/l.
2. Average C:~centra~ion = Geo~etric Mean Cor.=~~tratic~
Contaminant of Averaae Maximum Fre~~!!!:.c..,
~ Concentration Concentration of De-:.ect.ion
(ua/1J lua/l)
l,l,l-Trichloroethane 4.11 850.00 23/190
l,l-Dichloroethane 4.31 600.00 46/190
l,l-Dichloroethene 3.23 12.00 3/183
l,2-Dichloroethene(total) 10.06 29,000.00 92/193
1,2-Dichloropropane 3.01 5.00 7/183
2-3utanone 14.86 12,000.00 58/1S9
4-Methvl-2-Pentanone 7.95 430.00 38/189
Acetone 11.00 8,400 50/190
Benzene 3.17 23.00 24/133
Chlo=omethane 3.91 32.00 11/176
Ethyl Benzene 3.58 68.00 35/198
Methylene Chloride 2.00 520.00 17/194
Tetrachloroethene 3.80 350.0 17/194
Toluene 6.25 1,500.00 83/189
Trich10roethene 9.15 50,000.00 92/191
Vinyl Acetate 5.90 17.00 1/179
Vinyl Chloride 6.15 450.00 22/194
Xylenes, Total 4.21 .190.00 35/183
4-Meo:hvlDhenol 24.49 6,500.00 21/63
Bis (2-EthylhexvlJ Phthalate 10.49 160.00 35/5.
Diethyl Phthalate 7.38 93.00 17/62
Napthalene 6.02 39.00 5/60
Aluminum 1,793.00 176,000.00 69/79
Antimony 17.79 88.20 4/79
Arsenic 4.21 169.00 43/79
Ba=ium 146.00 1,600.00 76/79
Be:::vllium 1.05 8.50 16/79
Cadmium 1.91 11.00 8/69
Calcium 107,114.00 770,500.00 59/7.
Chromium 16.20 1.950.00 49/74
Cobalt 19.64 184.00 37/79
Cocce= 31.42 511.00 57/79
Cyanide 5.43 30.50 2/35
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Lead 8.40 98.10 72/79
!'.agnesium 11,006.00 88.900.00 65/79
!'.a:1ganese 730.64 25.500.00 78/79
~e:-cury 0 .08 0.41 5/79
~ickel 44.97 1,440.00 56/79
?ot:assium 8.236.23 303,000.00 52/79
Sodium 14,036.00 2,410,000.00 66/79
Vanadium 15.11 335.00 35/79
Zinc 74.05 3,710.00 69/78
Table 1
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TABLE 2 - CONTA!C:,A.""TS OF CONCERN - SWDA SURFACE SC:LS (0-2 feet
::::E: 1. A:l soil/sediment results in ug/kg except inorga~:: results
w~ic~ are in mg/kg; all water resul:s in ug/l. .
2. Average Concentration E Geo~e:ric Mean Cc~:entration
COl'.:a::-.inant of Averaae Maximum Freaue~cv
~ Concentration Concentratic~ of Detec:ion
(ua/l) Cua/l)
Met::ylene Chloride 2.00 2.00 1/6
Bis '2-Ethvlhexvl) Phthalate 264.40 150.00 2/6
Alu!:"~::~m 6251. 45 12.800.00 6/6
Arse~ic 3.32 43.00 6/6
Bari',;~ 33.06 50.40 6/6
Ber-...:lium 0.36 0.65 3/6
Chrc~~m 9.90 24.40 4/6
Cobal: 5.57 10.40 5/6
Coccer 9.57 15.90 6/6
Iron n. 867.27 17.300.00 6/6
Lea:: 4.49 16.20 4/5
Mag::es:.um 1,731.11 5.820.00 2/6
Mans;a.-:ese 234 .71 415.00 6/6
Nicitel 15.68 48.20 6/6
Var:.a::.:.~m 12.52 30.40 4/6
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TnE:':::
3 - C::;-:;_'!!NANTS OF CC:;CERN - :;;S -1 AREA SURFACE SO I LS
NOTE; 1.. All soil/sediment res-.;:'ts in ug/kg except ir.:::=;anic res1.:1ts
~hich are in mg/kg; a:1 water results in ug/:.
2. Average Concer.tration.= Geometric Mear. Concent=ation
Contaminar.t -- A'/eraae Maximum F=e=ency of
~ Concentration concenc=a:ion De:ection
2-Butanone 7.04 9.00 1/2
Xylenes. To:al :.73 1.00 1/2
Fluoranthene :;0.00 150.00 1/1
Phenanthrene .66.95 8500.00 2/2
PYrene 130.00 130.00 1/1
Aluminum 6215.00 6220.00 2/2
A."1timony :;.08 54.BO 1/2
A:senic 3.34 3.60 2/2
Barium :5.89 74.20 2/2
Beryllium ~.43 0.58 1/2
Cadmium 9.40 9.40 1/1
Chromium 54.00 54.00 1/1
Cobalt 33.96 146.00 2/2
Cooper 39.80 63.10 2/2
Iron 45509.34 139000.00 2/2
Lead 26.21 45.20 2/2
Magnesium 1S53.29 3210.00 1/2
Manganese 219.25 253.00 2/2
Nickel 37.76 82.40 2/2
Vanadium 235.92 2200.00 2/2
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TAB:'E 4 - CONT;';~:~AN'I'S OF CCNCER:; - IWS-2 AREA S'U",FACE SOIL
NOTE: 1. A:l soil/sediment :-esults in ug/kg excepe inorganic results
~hich are in mg/k9; all ~ater res~::s in ug/l.
2. Average Ccncene:-a:ion = Geomeeric Mean Concentration
Ccr.eaminant 0= Ave!'aae Maximum FreO"'..:encv
~ Cor.cene:-ation Concentration of r:~=ec~ion
1.2-Dichloroe:~ene (toeal) 40.54 72000.00 2/4
Acetone 35.07 25000.00 1/4
Methylene Chlc:-ide 9.87 19000.00 1/4
Tet:-achloroet~ene 38.03 93000.00 2/4
Trichloroethene 68.87 1000000.00 1/4
2-Methvlnapht:-.alene 339.01 270.00 1/3
Bis (2~EehYlhexvl) Phthalate 308.69 300.00 1/3
Fluoranehene 278.69 150,,00 1/3
Na'Othalene 251.32 llO.OO 1/3
Phenanthrene 366.08 340.00 1/3
Fvrene 284.75 160.00 1/3
Aluminum 65ll.17 12100. {)O 4/4
Arsenic 1.25 2.50 4/4
Ba:-ium 64.53 215.00 4/4
Be:-vllium 0.40 0.68 2/4
Ch:-omium 41. 64 425.00 4/4
Cobalt 8.45 6.20 3/4
Ccpper 9.73 26.20 3/4
CYanide .60 1.70 2/4
I:-on 12230.45 25400.00 4/4
Lead 3.10 3.30 3/3
Maanesium 2423 .84 4450.00 3/4
Manaanese 193.34 259.00 4/4
Nickel 17.70 44.80 4/4
Vanadium 30.29 148.00 4/4
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TABLE: - CONTAM:~A!'ITS OF CONC!RN - IWS-3 .>.=Z:; SURFAC! SOIL
~:7E: 1. All soil/sedimen~ results ~~ ~g/kg exce~~ inorganic results
which are in mg/kg; all wa~e= results i~ ug/l.
2. Average Concentra~~~~ = Geome~ric Mean Co~centration
Cont:a~..:..:':ant of Averac5! Maximum Frequencv
~ Conce::.==a:.ion Cc~centration of Detectio:1
1,1-Dichlorethane 22.20 27~0.00 1/4
1,2-~ichloroe~hene (total) 26.62 820 . 00 2/4
2-Bu~anone ,13.76 53.00 1/4
Acetc::e 14.99 35:.00 1/4
Benze::.e 5.18 16.00 2/4
Ethyl Benzene 7.90 27.00 2/4
Tetrachloroethe::e 21.76 340.00 3/4
Tolue::e 12.52 210.00 2/4
Tric::.:oroethene 21. 35 350.00 2/4
Xy1e::es. Total 16.92 130.00 2/4
Pyre::e 1369.3: 5000.00 1/2
Aluminum 6073.0: 8560.01 3/3
Arse::ic 4.55 7.50 3/3
Bariu:n 733.92 ,3000.00 3/3
Chrc:nium 1738.95 2560.00 3/3
Coba:~ 154.6: 194.00 3/3
Copper 72.26 101.00 3/3
Cyani::e 1.15 ' 3.50 2/3
Iron 75027.32 93000.00 3/3
Lead 84.81 124.00 2/2
Macmesium 3068.63 3560.00 3/3
Manaa::ese 432.97 560.00 3/3
Nickel 212.21 289.00 3/3
Vanadium 545.00 785.00 3/3
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TABLE 6 - CONTAM::~~S OF CO~CERN - SWDA ~~=~JRFACE SOILS (2-16 :~~c)
NG~: 1. A:~ soil/sedi~e~c results i~ ug/kg excepc inorga~~= resulcs
which are in mg/kg; all Water resulcs in ug/l.
2. Average Concentrati~n = Geometric Mean Cc~=entration
Contami~ant of Averace Maximum Frequencv
~ Conce~tration Concentratio~ of Decec:ion
(ua/l' lua/l)
Trichlc::,oethene 2.00 2.00 1/1
Xvlenes. Total 5.00 5.00 1/1
Alumi~-';::I 3270.CO 3270.00 1/1
Arsenic 0.75 0.75 1/1
Barium 19.00 19.00 '1/1
Iron 5200.00 5200.00 1/1
Lead 1.50 1.50 1/1
Manaanese 71.9C 71.90 1/1
Nickel 9.10 9.10 1/1
Vanadiu~ 8.20 8.20 1/1
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TABLE 7 - CC~~;.~INANTS OF CONCE~~ - DEE? SWDA Sv=SURFACE SOILS (>16 fee:)
NOTE: :.
All soil/sediment ~esults in ug;~g except inorganic res~lts
which are in mg/kg; all water results in ug/l.
2. Average Ccn:entration = Geometric Mean Concent~ation
Contaminar..: :Jf Averaae Maximum F:-e~..1encv
Concern Concentratic:1 Concentration of uetection
(ua/1) (ua 1)
1.1.1-Tric~loroethene 2.45 2.00 1/2
1.2-Dichlor:ethene 10.39 36.00 1/2
Toluene 2.45 2.00 1/2
.Trichloroet~ene 13.75 63.00 1/2
Aluminum 6542.17 10000.00 2/2
Arsenic 1.83 2.40 2/2
Barium 37.59 57.90 2/2
Calcium 19972.61 22100.00 1/2
Chromium 17.10 21.20 2/2
Cobalt 6.23 6.80 1/2
Copper 9.79 15.70 1/2
Iron 11706.92 16200.00 2/2
Lead 3.25 4.40 2/2
Magnesium 2784.89 5620.00 1/2
Manganese 266.53 320.00 2/2
Nickel 26.84 33.50 2/2
Vanadium 12.60 25.80 1/2
-------
TABLE 8 - C~NTAMINAN7S OF CONCE~; - IWS S~=S~~:ACE Sv:LS (2-16 f==:,
NOTE: 1. All soil/sedimen: ~=sults in ~g/%g exc=pt inorganic ~=sults
which a~e in mg/kg; all wa:e~ ~=sul:s in ug/I.
2. Average C=~centration ~ Geometric Mean Conc=ntration
Contaminant of Averaae Maximum Frequencv
~ Conce:::~ation Concentration of Detec:ion
(ua/li (ua/l)
l.l.l-Trichloroethane 17.75 6300.00 5/17
1.1-Dichloroethane 28.63 7200.00 7/17
1.2-Dichloroethene(:otal) 152.83 540000.00 14/20
. 2-Butanone 21. 61 350.00 5/16
Acetone 16.72 720.00 4/16
Benzene 9.18 150.00 5/15
Ethyl Benzene 16.18 590.00 8/17
Methylene Chloride 14.22 9300.00 3/18
Tetrachloroethene 167.98 100000.00 16/22
Toluene 18.28 1500.00 9/17
Trichloroethene 364.96 2500000.00 20/23
Xylenes. Total 35.89 5300.00 9/18
2-Methylnaphthalene 1007.17 15000.00 9/17
4-Methyl1)henol 395.72 1100.00 2/9
Bis (2-E:hylhexyl) Phthalate 601.10 11000.00. 2/10
Dibenzo£uran 506.67 1700.00 2/11
Fluoranthene 546.08 3100.00 2/11
Fluorene 634.95 2400.00 5/14
Napthalene 677.03 6900.00 8/15
Phenanthrene 782.11 7800.00 6/14
Pyrene 578.21 3400.00 6/13
di-n-Butyl Phthalate 473.77 11000.00 2/10
Aluminum 5504.64 10100.00 20/20
Arsenic 2.34 31.80 19/20
Barium 353.82 12300.00 20/20
Beryllium 0.17 0.26 2/20
Cadmium 0.45 9.80 2/20
Chromium 108.47 9090.00 19/20
Cobalt 20.32 481.00 15/18
Copper 15.55 595.00 14/20
Cyanide 1.71 241.00 12/20
Iron 20611. C~ 432000.00 20/20
Lead 7.18 506.00 20/20
-------
Manqa:1ese 226.-: 1570.00 20/20
Nickel 39. ~: 1140.00 20/20
Se1e::ium 0.23 0.83 4/20
Sodium 68.:: 235.00 7/20
Vanadium 54.3- 2580.00 14/20
Zinc 33. B: 270.00 16/20
.Table 8
-------
TAE:~ , - CO~";'~:~ANTS OF CONCERN - IWS DEEP SU2~.FACE SOILS (>16 feet)
~OTE: 1. ~:l soil/sediment results in ug/k; ~xcept inorganic results
which are in mg/kg; all water res~:ts in ug/l.
2. Average Concentration = Get~etric Mean Concentratic~
C~:':.~aminar.t 0: Averaae Maximum Freauency
~ Concentratio::. Concentration of Detection
:.l.l-Trichloroethane 8.28 380.00 1/10
:.l-Pichloroethane 8.64 580.00 2/10
1. 2-Dichloroethene (total) 19.47 23000.00 4/10
2-Butanone 36.39 540.00 2/10
Acetone. 27.30 950.00 2/10
C~lorobenzene 8.40 440.00 1/10
Cloroform 9.33 5.00 1/10
Ethyl Benzer.e 9.34 1900.00 2/10
~et:.ylene Ch:cride 9.14 470.00 1/10
7etrachloroethene 12.85 36000.00 3/10
':'c:uene 10.50 680.00 2/10
7richloroethe~e 27.29 63000.00 8/10
Xy:enes, Tot".a: 12.35 8900.00 2/10
1.2-Dichlorobenzene 536.92 5600.00 1/8
2-~ethv1naphtha1ene 610.87 23000.00 2/8
Ace:-:aphthene 519.49 4300.00 1/8
-;:",,;,oranchene 519.49 4300.00 1/8
F:'uorene 584.20 ' 11000.00 1/8
Ya'Othalene 473.34 8900.00 3/8
:::~:lanthrene 531.00 22000.00 2/8
Pv':"ene 525.29 4700.00 1/8
di-n-But".yl Phthalate 474.29 82.00 1/8
Aluminum 4954.51 14000.00 8/8
A:senic 1.61 18.00 8/8
Earium 30.37 735.00 7/8
Beryllium 0.18 0.65 1/8
Cadmium 0.38 0.86 1/8
Ca:cium 5539.63 46800.00 1/8
Clrcmium 15.09 568.00 8/8
C':::alt 3.41 6.90 6/8
C=;cer 7.56 18.. 90 6/8
:::=:::'1 8191.64 184000.00 8/8
:'ead 2.50 4.60 8/8
-------
Manganese 172.17 374.00 8/8
Nic:kel 14.03 27.00 8/8
Potassiu::I 655.42 3310.00 ::'/8
Vanadium 9.85 41.20 5/8
Zinc: 21.73 136.00 6/8
Table 9
-------
~AELE 10 - CC~AMIN~~S OF CONCERN - SEDIMENT &
DC~GRADIE~7 SEDIMENT FOR ?ASSUMPSIC RI'lER
NOTE: 1. All soil/sediment res~lts in ug/kg except inorganic res~"ts
which are in mg/kg; a:: water results in ug/l.
2. Average Conce~:ration = Geometric Mean Concentra:ion
Contaminant of Averaae Maximum F:eouencv of
~ CO:"1centration cc:mcentration De:ection
Aluminum 6Q02.93 72S0.00 3/3
Arsenic 1. 04 1.20 1/3
Barium 34.49 62.10 2/3
Cadmium 0.68 1.20 1/3
Calcium 3781.16 7220.00 2/3
Chromium 12.06 15.50 3/3
Co!)!)er 4.68 9.30 2/3
Iron 8432.77 '10600.00 3/3
Lead 5.17 9.50 3/3
Magnesium 3al4. 67 3830.00 3/3
Manganese 415.99 1180.00 3/3
Nickel 7.93 13.20 2/3
Potassium 584.62 1030.00 1/3
Vanadium 13.32 15.50 3/3
-------
:-;.=:'::: 11 - C:::::'AI-1INANTS OF CONCERN - S:::::~NT. t;:;:.IlIMED STREAM
NOTE: 1. ~:l soil/sediment resul:s :~ ug/kg except inorganic results
~hich are in mg/kg; all ~a:e~ resu:':s in ug/l.
2. Average Concent~a:::n = Geo~etric Mean Concentration
Cc~:aminant c: Ave=a=~ Maximum .Freaue~cv
~ Co:":::~:".~=ation Concentration of Detection
2-3utanone 12.1:: 81.50 1/8
Ace:one 10.27 240.00 1/8
C:::'oroethane 9.3:: 10.00 1/8
C:::oroform 5.3~ 2.00 1/8
T~ichlorethene 5.3: 2.00 1/8,
Bis (2-EthvU:exyl) Phthalate 327.:0; 160.00 1/4
A:-..:",inum 4045.::7 12500.00 8/8
A:senic 5.35 962.25 4/8
Barium 71.::2 809.50 7/8
Cadmium 0.77 10.50 1/8
Calcium 2779.:: 11925.00 5/8
C.".omium 7.5:: 27.40 5/8
Co:alt 5.99 12.60 1/8
Cc::cer 6.09 20.70 5/8
Cyanide 0.82 22.60. 1/5
!:::::'1 206::::.::4 383000.00 8/8
lead 3.9:: 17.00 8/8
Magnesium 156i.:: 5470.00 4/8
Manganese 605.';: 2425.00 8/8
Nickel 9.10 24.80 4/8
Potassium 629.::5 2230.00 3/8
Var.adium 12. C:: 46.90 5/8
-------
TABLE 12 - ::~AMINANTS OF CONCE~~ - Surface Water, Passumpsic River
NOTE: 1.
All soil/sediment results in ug/kg except inorganic results
which are in mg/kg; all water results in ug/l.
2. Average Concentration m Geometric Mean Concentration
~-.= :
Contaminar.t of Averac:re Maximum Freauency
~ Concencracion Concentration of Detection
1.2-Dichloroethene(tocal) 3.32 11.00 2/2
Trichloroethene 3.87 6.00 1/2
Aluminum 196.72 215.00 2/2
Barium 43..01 18.50 1/2
Calcium 25190.28 34300.00 1/2
Iron 563.67 611.00 2/2
-------
TAE:E 13 - ::~~~~:NANTS OF CONCERN - Surface Water, UNNAMED STR~_~
NOTE: 1. A::.l soil/sediment res~lts i~ ug/kg except inorganic results
which are in mg/kg; a:l wate~ results in ug/l.
2. Average Conce~tratior. = Geometric Mean Concentration
C::ntami~a~t 0: Averaae Maximum FreO'Uencv
~ Concentration Concentratior. 0: Detection
l,2-Dichlorcethene (total) 7.32 42.00 4/8
Acetone 4.53 15.00 1/8
Trichloroethane 4.78 21. 00 4/8
Vinyl ~:oride 4.09 1. 00 1/8
Aluminu::l 87.53 116.00 1/8
~timonv 31.54 56.50 1/8
Sarium 87.73 291.50 4/8
Calcium 39279.35 79400.00 5/8
Chromil::n 5.47 11.20 1/8
!=on 2538.63 33750.00 8/8
I".agnesiu::l 3936.70 9375.00 5/8
Manganese 780.91 3350.00 8/8
Nickel 21.04 38.80 1/8
Fotassil:m 3982.57 10040.00 ' 4/8
Silver 5.23 14.10 1/8
Sodium 5367.22 23550.00 3/8
-------
TABLE 14 - CONTAMIN~~S OF CONCE?~; - Air Da~a
Contami:'lant of Averace Maximum Freauencv
~ Conce:'ltration Concentration of Detection
l,l,l-Trichloroethane 0.30 0.61 5/23
Benzene 0.34 1.30 7/24
Methvlene Chloride 0.40 3.40 7/23
-------
7n3LE 15 - :ONTAMINANTS OF CONCE~~; - Leacha::
N07E: 1. All soil/sediment ~esults in ~g/~g exce~: inorganic results
which are in mg/kg; all wate~ ~esu:ts in ug/1.
2. Average Ccncentration = Geometric Mean Concen:ration
Contaminant of Averaae Maximum Freauencv
~ Concentra:ion Cor.centration of Detect.ion
2-Butancne 68.20 5400.00 1/3
4-Methyl-2-Pentanone 15.87 200.00 2/3
Acetone 263.77 430.00 3/3
Benzene 1.41 2.00 2/2
Chlorobenzene 2.24 2.00 1/2
Chloroet::ane 3.00 3.00 2/2
Ethvl Benzene 81.96 480.00 3/3
Methylene Chloride 3.04 .56.00 2/3
Toluene 70.33 940.00 3/3
Vinyl e:.:oride 2.74 1. 50 1/2
Xvlenes, Total 88.99 120.00 2/2
4-Methv1~"enol 167.33 5600.00 1/2
Benzoic Acid 165.51 9300.00. 2/3
Benzvl B~:yl Phthalate 5.00 5.00 1/2
Diethvl ;::"thalate 4.74 5.00 2/2
Naothalene 13.23 35.00 1/2
Phenol 45.83 420.00 1/2
di -n-B\;:'."1. Phthalate 3.46 4.00 2/2
Aluminu".. 3082.63 4900.00 3/3
Arsenic 4.45 4.10 2/3
Barium 222.01 280:00 3/3
Calciu," 153496.21 610000.00 1/3
. Copper 13.70 30.00 2/3
Iron 127480.80 173850.00 3/3
Lead 8.41 11.40 3/3
Maqnesiu::I 13154.54 85500.00 1/3
Manganese 5025.96 6765.00 3/3
Mercurv 0.05 0.09 1/3
Nickel 47.76 60.40 3/3
Potassiu:-:: 24595.57 324000.00 1/3
Sodium 47066.16 353000.00 2/3
vanadiu:-:: 6.25 10.80 1/3
Zinc 108.3 263.00 3/3
Table
15
-------
PARKER ROD TABLE 16
TABLE 3-1 X. SU\1\1AR Y OF CARCI:\OGE~IC RISKS ESTIMATED FOR THE
PARKER LANDFILL SITE .
Average Maximum
Scenario Receptor Present/Future Total Risk Total Risk
Ground Water - Site and Site Vicinit~.
Ingestion Resident F 3 x 104** 2 X 10-2**
Ground Water - Residential Wells
Ingestion Resident P/F 8 x 10.6 3 x 10-5
Surface Soils - IWS Areas
Ingestion Trespasser P 2 x 10.7 I X 10.6
Dennal Contact Trespasser P 2 x 10-10 2 X 10-6
Surface Soils - SWDA
Ingestion Trespasser P 3 x 10-7 3 X 10-6
Dennal Contact Trespasser P 4 x 10-11 2 X 10-11
Surface/Subsurface Soil - IWS Area
Ingestion Resident F 4 x 10-6 7 x 10-5
(child and adult)
Dennal Contact Resident F 8 x 10-9 4 x 10-5
(child and adult)
Stream Sediment
Ingestion Trespasser P 4 x 10-7 7 x 10-5
Dennal Contact Trespasser P
A92-!7ii.3
3-54
RECYCLED PAPER
-------
P..:..RKER ROD TABLE 16 (<:ont.)
TABLE 3-18. (CONTINuED)
Average Maximum
Scenario Receptor PresentlFuture Total Risk Total Risk
Stream Sediment (continued)
Ingestion Resident F 2 x 10-6 4 X 10-4**
(child and adult)
Dermal Contact Resident F
(child and adult)
Air
Inhalation Resident P/F 5 x 10-6 . 2 x 10.5
(child and adult)
"Exceeds Hj'risk
-- Only inorganics detected in sediments: negligible dermal absorption of inorganics expected (see text)
A92-1777.3
. 3-55
RECYCLED PAPER
-------
PARKER ROD TABLE 17
TABLE 3-19. SL\1\'1ARY OF ;\O:\CARCINOGE;\IC HAZARD I:-':DICES (HI)
ESTIMATED FOR THE PARKER LANDFILL SITE
Average :\-Iaximum
Scenario Receptor Present/Future Chronic HI Chronic HI
Ground 'Water - Site and Site Vicinity
Ingestion Resident F 6 x 1O\!:ic* 5 x 10:**
Ground Water - Residential \Vells
In £!estion Resident P/F 9 x 10-3 3 X 10'1
. Surface Soils - IWS Areas
Ingestion Trespasser P 3 x 10-: 4 x 10-1
Dermal Contact Trespasser P 1 x lO,s 1 X 10-1
Surface Soils - SWDA
Ingestion Trespasser P 4 x 10-3 4 x 10':
Dermal Contact Trespasser P 9 x 10-7 5 x 10,7
Surface/Subsurface Soils - IWS Areas
Ingestion Resident F
Adult 3 x 10-: 2 x 100**
Child 6 x 10-1 2 x: 101**
Dermal Contact Resident F
Adult 1 x 10-4 7 X 10-1
Child 5 x 10-4 3 x 10°**
Stream Sediment
Ingestion . Trespasser P 7 x 10,3 9 X 10'1
Dermal Contact Trespasser P
A9::!-li77.3
3-56
r;ECYCLED PAPER
-------
PARKER ROD TABLE 17 (cant.)
TABLE 3-1 Y. (CONTL'\;UED)
Average Maximum
Scenariu Receptur Present/Future Chronic HI Chronic HI
Stream Sediment (continued)
Ingestion Resident F
Adult 5 x 10"' 7 X 10-1
Child 5 x IO"~ 6 x 10°*
Dennal Contact Resident F
Adult
Child
Air
Inhalation Resident . P/F 2 x 1003 7 X 10.3
*HI exceeds one (1)
-- Only inorganics detected in sedimems: negligible dennal absorption of inorganic expected (see text)
A92-l77i.3
3-57
RECYCLED PAPER
-------
ROD Table 18
PARKER LANDFILL SUPERFUND SITE
COMPARATIVE ANALYSIS SUMMARY
Alternative
1.
No Action
2. Containment/
Institutional Controls
3. Containment/
Institutional Controls/Source
Control Groundwater
Extraction
4 . Containment/
Institutional Controls SVE at
IWS 2
Overall
Protectiveness
Human Health: No reduction
of unacceptable risks
associated with direct
contact with soil/sedime~t
and ingestion of groundwater.
Ecological: No reduction of
risks associated with IWS
soils. No reduction of
stream siltation.
Human Health: Reduces risks
associated with direct
contact with soil/sediment.
Institutional Controls reduce
'risks associated with
ingestion o~ groundwater.
Ecological: Reduces risks of
contact with IWS soils.
Eliminates further siltation
of stream.
Human Health: Reduces risks
associated with direct
contact with soil/sediment.
Institutional Controls reduce
risks associated with
ingestion of groundwater.
Ecological:' Reduces risks of
contact with IWS soils.
Eliminates further siltation
of stream
Human Health: Reduces
risks associated with direct
contact with soil/sedime~t.
Institutional Controls reduce
risks associated with
ingestion of groundwater.
Ecological: Reduces risks of
contact with IWS soils. '
Eliminates further siltation
of stream.
Compliance
with ARARs
Will not achieve Federal or
State groundwater ARARs.
Will not achieve State
hazardous waste management
ARARs.
Will not achieve Federal or
State wetlands ARARs.
Will not achieve Federal or
State groundwater ARARs.
Will achieve State hazardous
waste management ARARs.
Will meet action-specific
ARARs .
Will comply with Federal and
State wetland ARARs.
Will achieve 'Federal and
State groundwater ARARs in
long-term.
Will achieve State hazardous
waste management ARARs.
Will meet action-specific
ARARs.
Will comply with Federal and
State wetland ARARs.
Will not achieve Federal or
State groundwater ARARs.
Will achieve State hazardous
waste management ARARs.
Will meet action-specific
ARARs.
Will comply with Federal and
-------
Alternative
5. Containment/
Institutional Controls/ SVE
at IWS2/Source Control
Groundwater Extraction
8a. Downgradient Groundwater
Extraction Combined with
Alternatives 2 or 4 (No
Source" Control Groundwater)
8b. Downgradient Groundwater
Extraction Combined with
Alternatives 3 or 5 (Source
Control Groundwater)
Overall
Protectiveness
Human Health: Reduces risks
associated with direct
contact with soil/sediments.
Institutional Controls reduce
risks associated with
ingestion of groundwater.
Ecological: Reduces risks of
contact with IWS soils.
Eliminates further siltation
of stream.
Human Health: Reduces risks
associated with direct
contact with soil/sediment.
Institutional Controls reduce
risks associated with
ingestion of groundwater.
Ecological: Reduces risks of
contact with IWS soils.
Eliminates further siltation
of stream.
Human Health: Reduces risks
associated with direct
contact with soil/sediments.
Institutional Controls reduce
risks associated with
ingestion of groundwater.
Ecological: Reduces risks of
contact with IWS soils.
Eliminates further siltation
of stream.
Compliance
wi th A.~s
Will achieve Federal and
State groundwater ARARs in
long-term.
Will achieve State hazardous
waste management ARARs.
Will meet action-specific
ARARs.
Will comply with Federal and
State wetland ARARs.
Will not achieve Federal or
State groundwater ARARs.
Will achieve State hazardous
waste management ARARs.
Will meet action-specific
ARARs.
will comply with Federal and
State wetland ARARs.
Will achieve Federal and
State groundwater ARARs in
long-term.
Will achieve State hazardous
waste management ARARs.
Will meet action-specific
ARARs.
Will comply with Federal and
-------
Alternative
Long-Term
Effectiveness &
Permanence
Reduction of Toxicity
Mobility, and Volume
Through Treatment
1. No Action Residual risks unchanged No reduction of toxicity,
mobility, and volume (TMV)
No long-term effectiveness through treatment.
2. Containment/ Residual risks reduced. No reduction of toxicity,
Institutional Controls Capping is reliable and mobility, and volume (TMV)
effective for long-term through treatment, "except
control. for treatment of landfill
gas".
Limited long-term improvement
of groundwater quality.
3. Containment/ Residual risks reduced. Reduction of TMV of
Institutional Controls/Source Capping and groundwater groundwater through
Control Groundwater extraction reliable and extraction and treatment.
Extraction effective for long-term
control.
Long-term improvement of
groundwater quality.
4. Containment/ Residual risks reduced. Reduction of toxicity of IWS2
Institutional Controls/SVE at Capping is reliable and soils through treatment.
IWS2 effective for long-term
control.
Limited long-term improvement
of groundwater quality.
-------
Alternative
Long-Term
Effectiveness &
Peymanence
Reduction of Toxicity,
Mobility, and Volume
Through Treatment
5. Con:ainment/ Residual risks reduced. Reduction of TMV of
Institutional Controls/SVE at Capping and groundwater groundwater through
IWS2/Source Control extraction reliable and extraction and treatment.
Ground~ater Extraction effective for long-term
control. Reduction of toxicity of IWS2
soils through treatment.
Long-te~ improvement of
ground~ater quality.
SVE system more permanent.
8a. Downgradient Groundwater Residual risks reduced. Reduction of TMV of
Extraction Combined with Capping is reliable and groundwater through
Alternatives 2 or 4 (No effective for long-term extraction and treatment.
Source. Control Groundwater) control.
Limited long-term improvement
of grou.~d~ater quality.
8b. Downgradient Groundwater Residual-risks reduced. Reduction of TMV of
Extraction Combined with Capping and groundwater groundwater through
Alternatives 3 or 5 (Source extraction reliable and extraction and treatment.
Control Groundwater) effective for long-term
control.
Long-te~ improvement of
-------
Alternative
1.
No Action
2. Containment!
Institutional Controls
3. Containment!
Institutional Controls!Source
Control Ground~ater
Extraction
4. ,Containment!
Institutional Controls!SVE at
IWS2
Short-Term
Effectiveness
Lowest potential risk to
community & workers.
No impact to wetlands.
No short-term exposure
protection.
Minimal implementation
ti~e.
Minimal short-term risks to
workers and community duri~g
cap construction.
Some wetlands impacts - wi~l
require mitigation.
Short-term exposure
protection through capping
and institutional controls.
24 month implementation ti~e.
Minimal short-term risks to
workers and community duri~g
construction of cap and
groundwater extraction
system.
Some wetlands impacts - will
require mitigation.
Short-term exposure
protection through capping
and institutional controls.
34 month implementation ti~e.
Somewhat greater short-te~
risks to workers and
community during construction
of cap and SVE system.
Some wetlands impacts - will
require mitigation.
Short-term exposure
protection through capping
and institutional controls.
27 month implementation time.
Implementability
Easiest to i~plement~
Capping easy to implement.
Institutional controls
require cooperation of
landowners, tc~, and state.
Capping & groundwater
extraction easy to implement.
Institutional controls
require cooperation of
landowners. tc'~. and state.'
May be some implementation
problems with discharge of
treated gro~~d~ater.
Long-term availability of
residuals disposal facilities
uncertain.
Capping easy to implement.
Institutional controls
require cooperation of
landowners, tc~. and state.
SVE may be difficult to
-------
Alternative
5. Containment/
Institutional Controls/SVE at
IWS2/Source Control
Groundwater Extraction
Sa. Downgradient' Groundwater
Extraction Combined with
Alternatives 2 or 4 (No
Source Control Groundwater)
8D. Downgradient Groundwater
Extraction Combined with
Alternatives 3 or 5 (Source
Control Groundwater)
Short~Term
Effectiveness
Somewhat greater short-term
r~sks to workers and
community during construction
of cap, SVE system, and
groundwater extraction
system.
Some wetlands impacts - will
require mitigation.
Short-term exposure
protection through capping
and institutional controls.
34 month implementation time.
Somewhat greater short-term
risks to workers and
community during construction
of cap, SVE system, and
groundwater extraction
system.
Some wetlands impacts - will
require mitigation.
Short-term exposure
protection through capping
a~d institutional controls.
34 month implementation time.
Somewhat greater short-term
risks to workers and
community during construction
of cap, SVE system, ,and
groundwater extraction
system.
Some wetlands impacts - will
require mitigation.
Short-term exposure
protection through capp~ng
and institutional controls.
34 month implementation time.
Implementability
Capping & groundwater
extraction easy to implement.
Institutional controls
require cooperation of
landowners, town, and state.
May be some implementation
problems with discharge of
treated groundwater.
Long-term availability of
residuals disposal facilities
uncertain.
SVE may be difficult to
implement successfully.
Capping & groundwater
extraction easy'to implement.
Institutional controls
require cooperation of
landowners, tonw, nad state.
May be some implementation
problems with discharge of
treated groundwater.
Long-term availability of
residuals disposal facilities
uncertain.
SVE may be difficult to
implement successfully.
.
Capping & groundwater
extraction easy to implement.
Institutional controls
require cooperation of
landowners, town, and state.
May be some implementation
problems with discharge of
treated groundwater.
Long-term availabiiity of
residuals disposal facilities
uncertain.
SVE may be difficult to
-------
Feasibilitv Study Cost Estimates
Alternative
Low
Medium
High
Estimated
1. No Ac~ion $40,000 $50,000 $54,000 $43,000
2. Containmen~/ $10,400,000 $13,600,000 $19,300,000 $13,000,000
Institutional
Controls
3. Containment/ $19,000,000 $28,200,000 $38,000,000 $28,100,000
Institutional
Controls/Source
Control
Groundwater
Extraction
4. Containment/ $11,800,000 $15,500,000 $22,100,000 $15,300,000
Institutional
Controls/SVE at
IWS2 '.
5. Containment/ $20,400,000 $30,000,000 $40,700,000 $29,700,000
Institutional c
Controls/SVE at
IWS2/Source
Control
Groundwater
Extraction
8a. Downgradient $18,800,000 $28,400,000 $39,100,000 $28,700,000
Groundwater
Extraction
Combined with
Alternatives 2
or 4 (No Source
Control
Groundwater)
8D. Downgradient $21,500,000 $32,500,000 $43,400,000 $32,000,000
Groundwater
Extraction
Combined with
Alternatives 3
or 5 (Source
Control
-------
_0" .-..-
. . ,
'._:.:.;~' ~ .~~~
. ..---,.v
-.-----
PARKER ROD FIGL~E 1
- _._-
I
SOURC:::
U.S.G.S. TOPOGRAPHIC IMP. BURKE MOUNTAIN QUADRANGLE. V:::;IAONT, 7.5 ~INUTE SERIES. =~OVlS;O~L EDITION, 1988.
~
,
I ~~;4 En~ironmenlal
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. --' Engineering, Inc.
1: 24000
,/z
i
SCALE IN
?ARKER LAN::::-~:.. PR:)~::CT
LVNDONVILL::. V::RIJ:;\i7
R::V.:::ML INVEST ~:"710N ~::;:):;~T
o
I
?~OJ EC7 ~OC L, S
MILES.
FIGUrE 1 - ~
J~"~I~::; '-4"'£:: ~A~I('..~C
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"9; 5:)2£
:.:;. " 1'2/~2
:..! ":';1I3o~:
-------
PAmmn non
FIGtmE 2
8
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UURRINCION Q
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NOTES:
~. Envlronmenlal
..) Science k
.-- En.lnoerl".. Inc.
PARKER lANDFill PROJECT
L YNDONVlllE. VERMONT
REMEDIAL INVESTIGATION REPORT
I.
DAn t.W" FROM .'Of'OGfW'IllC ItORKSIIEU
Of IUl PAUaI:(N INdI'.l8. 0..110 Sl:Pf(WUUI
,. 1117, PftD.t8QfO 8f' fAS1'(RN fOPOGltAPttICS.
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- ma: <- IWS AAOS)
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......
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,~=
PlAN OF PARKER L
-------
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PARKER ROD
FIGURE ~
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-------
APPENDIX B
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
-------
. .
TAbL.E 4-1
ARARs SPECIFIC TO REMEDIAL ALTERNATIVE I:
Parker landfill.Feasibility Study
Lyndonville, Vermont
I'S
NO-ACTION'
I(cvir.hH.. U
1).le: Ii I HN.J
.--.
Type Medium Requirements Status Synopsis of kequin:mcnt Action to be taken to attain ARAI{
Chemical- Groundw~ter Vermont Hazudous Waste Relevant and This regulation establishes the maximum . Maximum permissible concentrations for
Specific RegulttiOQ (BPR 7-502) Appropriate permissible concentrations of hazardous' Contaminants of Concern that are
I constituents in groundwater in the uppennost currently exceeded will continue to lit:
.t'.!
aquifer underlying the waste management exceeded until or unless the source is
area beyond the point of compliance. An depleted and/or natural degradation
alternate concentration limit (ACL). biased on processes reduce their respective
protection of human health and the concentrations in groundwater below
environment, may be established by the permissible levels.
Regional Administrator.
8 Periodic groundwater monitoring would
be required.
Vermont Groundwater Protection Applicable Water quality standards apply to regulatory 8 Remediation goals for COlltumilllUits or
Regulations (EPR 12) programs that may affect groundwater Concern that are currently exceeded will
resources. Primary Ground Water Quality. continue to be exceeded until or unless
Standards cover a broad range of chemicaJs the source is depleted and/or natural
that, if present, may detract from the degradation processes reduce their
intended use of the groimd water. These respective concentrations in groundwater
standards include an .remediation goals. and below these standards.
a .preventive action limit, . which is either
IO~ or 50~ of the remediation goal. Both
. trigger a specified response. Secondary
Ground Water Quality Standards covering
paramctcrs that affect aesthetic qualities. also
include a preventivo action limit, which is
SO~ of the remediation goal. U
Federal Safe Drinking Water Relevant and MCt... have been promulgated for a number 8 MCLs for Contaminants of COllecm thai
Maximum ContAminant Levels Appropriate of common organic and inorganic are currently exceed cd will conlilluc 10
(MCLs) for organic and contaminants; and action levels have been be exceeded until or unless the source is
inorganic chemicals (40 CPR promulgated for lead and copper. These depleted and/or natural degradation
141 Subparts B, G, and I). levels regulate the concentration of processes reduce their respective
cont.amioants in public drinking water concentrations in groundwater helow thc
I suppliCl, but may abo be considered MCI..s.
appropriate ror groundwater aquifers
potentially used for drinking water.
file :".rhr1.r.nJlhI4. A. WI'
""*"
-------
TAnL.E 4-1
ARARs SPECIFIC TO REMEDIAL ALTERNATIVE I:
Parker Landfill Feasibility Study
Lyndonville, Vennont
I'S
NO-ACTION
R~viMiul1: U
081": 1118194
Type Medium Requirements Status Synopsis of Requirement Action 10 be taken to attain ARAR
Chemical- Groundwater Federal Safo Drinking Water Relevant and MCLGs arc health-based goals (non- 8 MCLGs tbat arc currently exceedoo will
Specific (cont'd) Maximum Contaminant Level Appropriate enforceable) for public water supplies. continue to be exceeded until or unh:ss
(cont'd) Goals (MCLGa) for organic and MCLGs arc levels considered 10 have no the source is depleted and/or naluml
inorganic chemical. (40 CPR , known or anticipated negative health effects degradation processes reduce the
141 Subpart F). which includes a margin of safety. These concentrations of contaminants below the '
,
goals arc available for a number of organic MCLGs. "
I
i
and inorganic contaminants. I
Federal Safe Drinking Water To Be These regulations control contaminants that 8 To be considered in selecting remooial I
National SccondaJy Maximum Considered affect the aesthetic qualities of drinking water alternative. I
Contaminant Levels (SMCu) such as appearance, odor and taste. SMCLs
(40 CFR 143.3). arc not federally enforceable but are intended
to be used by states as guidelines.
Federal Safe Drinking Water To Be These regulations woul~ establish MCLs for 8 To be considered in selecting remooial
proposed MCLs for synthetic Considered certain chemical species. alternative.
organic chemicals and inorganic
chemicals (40 CPR 141).
Federal Drinking Water Health, To Be EPA publishes contaminant-specific health 8 To be considered in selecting r~m~dilll
Advisories. Considered advisories that indicate the non-carcinogenic alternative.
risks associated with consuming contaminated
drinking water.
Federal Groundwater Protection To Be EPA's GPS includes a component which 8 To be considered in sc:lecting remediul
Strategy (EPA, August 1984). Considered states that groundwater is ecologically vital, alternative.
if the aquifer provides the base now for a
particularly sensitive ecosystem which, if 8 The aquifer below the Study Area does "
polluted, would destroy a unique habitat. not provide the hase now for" sl'lIsitiw
habitat.
f
'.
I','e ,puler/onn/lhl4. A. wp
dllwp
-------
TAuLE 4-1
ARARs SPECIFIC TO REMEDIAL ALTERNATIVE I:
Parker Landfill Feasibility Study
Lyndonville, Vennont
I'~
NO-ACTION
Revi.ion: ()
Dale: 1118/'14
Type Medium Requirements Status Synopsis of Requirement Action to be taken to aUain ARAR
Chemical- Sediment Federal Interim Sedirricnt Quality To Be Sediment quality criteria were compiled from 8 To be considered in selecting remediul
Specific Criteria Considered studies of effects of toxic compounds in alternative.
(cont'd) sediments on benthic biota. Sediment quality
criteria have been published for metals, 8 Sediment quality criteria for II
PAUs, and other persistent organic Contaminants of Concern that are
compounds. cWTCntly exceeded will continue to be "
II
exceeded until or unless the source is h
depleted and/or natural degradation II
;,
processes reduce their respective \1
concentrations in sediment below the ;1
!
recommended criteria. 'i
H
Action- N/A Vermont Hazardous Waste Applicable These reguJatioDs establish requirements for 8 The No Action Alternative does not fully!;
Specific Regulations (EPR Chapter 7 bazardous waste facilities, including facility satisfy security requirements, nor docs it '
~ !
Subchapter S) standards, emergency preparedness and accomplish thc specified objectives of ,:
prevention, and contingency planning. closure and post-closurc care for IWS ':
Closure of land disposal units shall be Areas. '
..
implemented to accomplish the objectives !
,.
detailed in 40 CPR 264 Subpart F (ReleaseS !:
from waste management units), Subpart G !:
(Closure and post-closure). and Subpart N i
(Landfills).
,
Vermont SOlid Waste Applicable Final cover on solid wastc landfills are 8 The No Action Altemative mL:Cts these i
Regulations (EPR Section 6-702) required to have a minimum slope of S requirements for the SWDA. !
percent and a maximum slope of 33'n r
percent. Grass or ground cover. must be
established within four months of final cover,
or as soon as weather permits.
h'e ..,..rhr/ar.../I"'''' A. 101/(1
""wp
-------
TAbLE 4-1
ARARs SPECIFIC TO REMEDIAL ALTERNATIVE I:
Parker Landfill Peasibility Study
LyndOnville, Vermont
NO-ACTION
I'~
R~viliulI: II
nll~: IIIII/')~
Type Medium Requirements Status Synopsis of RequircQJCDt Action to be taken to attain ARAR 1]
.'i
0:
Action- N/A Federal Solid Waste Regulations To Be The final cover system installed on a solid 8 Vermont solid waste cover requiremenls '!
,
Specific (40 CPR 258.60) Considered waste landfill must be designed to minimize are more stringent. i
I
(conl'd) infiltration and erosion, and consist of an I
!
infiltration layer underlying an erosion layer. I
The infiltration layer must have at least 18.
of earthen material that has a low
permeability. The erosion layer must consist
of .t lC8!it 6- of earthen material thai is
capable of sustaining native plant growth. I
Vermont . Land Use and Relevant and Construction of improvements on tracts of 8 The No Action Alternative does nol I
Development Law (Act 250'- 10 Appropriate land larger than 10 acres are required to . facilitate compliance with the
VSA Chapter ISI) comply with criteria specified in the Act, groundwater protection aspect of the I
including DO undue air or water pollution, no Act. I
disposal of harmfu1 or toxic substances to
groundwater, no unreasonable soil erosion, i
compliance with wetlands rules, and no
adverso affects on aesthetic values.'
Surface Vermont Water Quality Applicable Stormwater runoff shall Dot have an undue 8 The No Action Alternative does lIot
Waters Standards (EPR Section 2'{)5» adverso effect on the receiving waters. facilitate compliance wilh the prohibition
on undue adverse effects of stormwater
on receiving waters.
Location- Floodplains Vermont Hazardous Waste Relevant and Hazardous waste disposal facilities are not to 8 IWS Areas are not located in a
Specific and Seismic Regulations (EPR 7-502) Appropriate be located in seismically active areas Dor iD seismically active area or in a IOO-year ~;
ZoDes lOO-year floodplains (unless washout can be floodplain. .~
,.,
;
prevented or DO adverso effects of washout .
can be substantiated).
Groundwater, Vermont Solid Waste Relevant and Solid waste disposal facilities are not to be 8 The SWDA is not located in the
Wetlands, and Regulations (EPR 6-502, 503) Appropriate located in Class I or Class II groundwater sensitive areas outlined.
Floodplains areas, significant wetlands, or a IOO-year
floodplain/Dood stage elevation. Solid waste
facilities are to be located so as not to
adversely affect drinking water supplies.
""~ :porhr/orln/.hI4. A. wI'
dtlwp
-------
TAbLE 4-2
ARARs SPECIFIC TO REMEDIAL ALTERNATIVE 2:
CONTAINMENT (SWDA, IWS 1,2, and 3)/NO SOURCE CONTROL GROUNDWATER
. Parker Landfill Feasibility Study
Lyndonville, Vermont
I;S
Rcvi..iuli. U .
Dale: III 8/'/4
Type Medium RoqulremeDta Sc.tus Synopsis of Requirement Action to be taken to attain ARAR
ChemicaJ~ Air Vermont Air Pollution Control Relevant and The following provisions of Vermont air 8 Gas collection system for the IWS Areas
S~i fic ReguJat10aa (BPR Chapter 5) Appropriate emissions regulations address relevant and will be evaluated to determine if
appropriate air pollution issues: controlling pollution thresholds are exceedc:d for
emissions of conventional pollutants and control technology application.
hazardous air pollutants to prevent ambient I
concentrations from exceeding NAAQS and
Hazard Limiting Values, respectively;
minimizing fugitive particulate emissions I
from material handling and construction; and
controlling nuisances and odors. I
Federal NESHAP for Vinyl Relevant and Specifies that the concentration of vinyl 8 Gas collection system f ' ,he IWS Areas I
I
Chloride (40 CFR 61 Subpart F) Appropriate chloride in exhaust gas from control will be evaluated to determine if vinyl !
equipment must not exceed 10 ppm. chloride thresholds are excee
-------
TAbLE 4-2
ARARs SPECIFIC TO REMEDIAL ALTERNATIVE 2:
CONTAINMENT (SWDA. IWS I. 2. and 3)/NO SOURCE CONTROL GROUNDW ATER
Parker Landfill feasibility Study'
Lyndonville. Vennont
,.<;
Rcvi~hU" ()
Dale: "181'1..
Type Medium RequlreaiMte StU.uI Syo.opsi3 of Requlroment Action to bo taken to attain ARAR
Chemical- Groundwater Vennont Groundwater Protection Applicable Water quality standards apply to regulatory 8 Groundwater quality would improve due
Specific (cont'd) RegulaliOlll (BPR 12) programs that may affect groundwater to presence of caps on SWDA and IWS
(cont'd) resources. Primary Ground Water Quality Areas; however. remediation goals for
Standards cover a broad range of chemicals Contaminants of Concern that are
that. if present. may detract from the currently exceeded will continue to be
intended use of the ground water. These exceeded until or unless the source is
standards include an . remediation goal", depleted and/or natural degradalion
based on federal MCLs, USEPA Office of processes reduce their respective
Drinking Water. Ufetime Health Advisory, concentrations in groundwater below
or a Vermont Health Advisory. and a these standards. I
i
"preventive action limit". which is either j
IO~ or SO~ of the remediation goal. Both
trigger a specified response. Secondary
Ground Water Quality Standards covering'
parameters that affect aesthetic qualities, also \
include a preventive action limit. which is
SO~ of the remediation goal. i
.
i
Federal Safe Drinking Water Relevant and MCLs have been promulgated for a number i
8 Groundwater quality would improve due !
Maximum Contaminant Levels Appropriate of common organic and inorganic' to presence of caps on SWDA and IWS Ii
(MCLs) for organic and contaminants; and action levels have been Areas; however, MCL'! for
inorganic chemicals (40 CPR promulgated for lead and copper. These Contaminants of Concern that are
141 Subparts O. 0. and I) levels regulate the concentration of currently exceeded will continue to be I'
conlaminants in public drinking water exceeded until or unless the source is ,I
supplies. but may also be considered depleted and/or natural degradation I
appropriate for groundwater aquifers processes reduce their respective
potentially used for drinking water. concentrations in groundwater below the
MCLs.
File: l'arker/araro/lhI4. B. wI'
tll/wl'
-------
. TAu....E 4-2
ARARs SPECIFIC TO REMEDIAL ALTERNATIVE 2:
CONTAINMENT (SWDA, IWS 1,2, and 3)/NO SOURCE CONTROL GROUNDWATER
Parker Landfill Feasibility Study
Lyndonville, Vermont
I'S
R~vili,u,- ()
I)alc: 11111/'1-1
-- ...
Type Medium Roqulrommta Status Synopsis of Requirement Action to be taken 10 altain ARAR
Chemical- Groundwater Federal Safo Drinking Water Relevant and MCLGs arc health-based goals (non- 8 Groundwater quality would improv~ dll~
Specific (cont'd) Maximum Contaminant Level Appropriate enforceable) for public water supplies. 10 presence of caps on SWDA and IWS
(cont'd) Goals (MCLG.) (or organic and MCLGs arc levels considered to have no Areas; however, MCLGs thai are
inorganic chemical. (40 CFR .known or anticipated neg~tive health effects currently exceeded will continue to be
141 Subpart F) which includes a margin of safety. These exceeded until or unless the sOllrc~ is
goals are available for a number of organic depleted and/or natural d~gradali()n
and inorganic contaminants, processes reduce the concentrations of
contaminants below the MCLGs.
Federal Safe Drinking Water To Be These regulations control contaminants that 8 To be considered in selecting remooial
National Secondary Maximum Considered affect the aesthetic qualities of drinking water alternative.
Contaminant Levels (SMCLs) such as appearance, odor, and taste. SMCLs
(40 CFR 143.3) arc not federally enforceable but arc intended
to be used by states as .guidelines.
Federal Safe Drinking Water To Be These regulations would establish MCI..3 for 8 To be considered in selecting remooial
proposed MCLs for synthetic' Considered certain chemical' species. alternative.
organic chemicals and inorganic
chemicals (40 CFR 141)
Federal Drinking Water Health To Be EPA publishes contaminant-specific health 8 To be considered in selecting remooial
Advisories Considered advisories that indicate the non-carcinogenic alteniative.
risks associated with consuming contaminated
drinking water.
Federal Groundwater Protection To Be EPA's GPS includes a component which 8 To be considered in selecting r~mooial
Strategy (EPA, August 1984) Considered stales that groundwater is ecologically vital, alternative. ~';
if the aquifer provides the base now for a
particularly sensitive ecosystem which, ,if 8 The aquifer below the Study Area docs
polluted, would destroy a unique habitat. not provide the base flow for a sellsitiv~
I habitat.
file .I,arlcr/ara.."hI4. B. "'I'
1111"'1'
-------
TA...LE 4-2
ARARs SPBCIFIC TO RBMBDIAL ALTERNATIVE 2:
CONTAINMBNT (SWDA, IWS J, 2, and 3)/NO SOURCB CONTROL GROUNDWATER
Parker Landfill Peasibility Study
Lyndonville, Yermont
I'S
R~villiun: n
note: 1/181'1.1
1)pe Medium RoqullOlDiCnta Status Synopsis of Requirement Action to bfJ taken 10 altain ARAR
Chemical- Sediment Federallntcrim Sediment Quality To Be Sediment quality criteria were compiled from 8 To be considered in selecting remedial
Speci fic Criteria Considered studies of effects of toxic compounds in alternative.
(cont'd) sediments on benthic biota. Sediment quality
criteria have been published for metals, 8 Sediment quality would improve due to
PAUs, and other persistent organic presence of cap on SWDA and IWS
compounds. Areas; however, sedimenl (11111 lily
criteria for Contaminants of Concem
that arc currently exceeded will continue
to be exceeded until or unless the source
is depleted and/or natural degradation
processes reduce their respective
concentrations in sediment below the
recommended criteria.
Action- N/A Yermont Hazardous Waste Applicable These regulations establish requirements for 8 Alternative 2 will satisfy security
Specific Regulations (BPR Chapter 7 hazardous waste facilities, including facility requirements and accomplish Ihe
Subchapter S) standards, emergency preparedness and specified objectives of closure and pOSI-
prevention, and contingency planning. closure care that are applicable to IWS
Closure of land disposal units shall be Areas.
implemented to accomplish the objectives
detailed in 40 CPR 264 Subpart P (Releases
from wute management units), Subpart G
(Closure and post-closure), and Subpart N
(Landfills).
Yermont Solid Waste Applicable Final cover on solid waste landfills are 8 Alternative 2 will satisfy Ihe final cover
Regulations (EPR Section 6-702) required to have a minimum slope of S requirements applicable 10 the SWDA.
percent and a maximum slope of 33%
percent. Grass or ground cover must be
established within four month!! of final cover,
or as soon u weather permits.
f
hie: l'arkerlarar.111014. D. "'I'
.111",1' .
-------
TAbLE 4-2 -
- ARARs SPECIfiC TO REMEDIAL ALTERNA'J1VE 2:
CONTAINMENT (SWDA, IWS 1,2, and 3)/NO SOURCE CONI'ROL GROUNDWATER
Parker Landfill Feasibility Study
Lyndonville, Vermont
I ~.
Rcvisi'HI. U
Dale: IIIHI'j-1
Type Medium - Roqul~nl8 StWs Synopsis of Requirement Action to be taken to attain ARAR ..- I
I
Action- N/A Federal Solid Waste Regulations To Be The final cover system installed on a solid . Vermont solid waste cover requirements
Spcci fic (40 CPR 2.58.60) Considered waste landfill must be designed to minimize arc more stringent. I
(cont'd) infiltration and erosion, and consist of an
infiltration layer underlying an erosion layer.
The infiltration layer must have at least 18.
of earthen material that has a low
permeability. The erosion layer II1l1st consist
of at least 6. of earthen material that is
capable of sustaining native plant growth.
EP A Tcchnical Guidance To Be Presents EP A recommendations on design . To be considered in designing a cap for
Document: Final Covers on Considered specifications for multilayer landfill caps. IWS Areas.
Hazardous Waste Landfills and
Surface Impoundments
Federal Noise Control Applicable Establish noise emission standards applicable - . Construction equipment will ~ requir~
Regulations (40 CPR 204,205) to portable air compressors and medium and to comply with applicable noi~ emission
heavy duty trucks. standards.
Vermont Land Use and Relevant and Construction of improvements on tracts of . Alternative 2 facilitates compliance with
Development Law (Act 150 - 10 Appropriate land larger than 10 acres arc required to the Act by reducing leachate generation
VSA Chapter 151) comply with criteria specified in the Act, arid controlling erosion from SWDA and i'
including no undue air or water pollution, no IWS Areas. Ii
disposal of harmful or toxic substances to i ~
groundwater, no unreasonable soil erosion, 1
compliance with wetlands roles, and no
adverse affects on aesthetic values. i;
1
Air Federal Proposed Regulation for To Be Proposes emission standards for VOCs from 8 To be considered in predesign studies. i
Control of VOCs Considered groundwater treatment units such as air I
strippers.
Surface Vermont Water Quality Applicable Stormwatcr runoff shall oot have an undue - 8 Alternative 2 will facilitate compliance I
~
Waters Standards (EPR Section 2'{)5» adverse effect on the receiving waters. with this requirement by controlling ;
erosion and nmoff fmm SWDA 111111 I
I
IWS Areas.
':ile: l.arlLcr/aran/(b/4 - B - wp
dllwp
-------
TAl>....E 4-2
ARARs SPECIFIC TO REMEDIAL ALTERNATIVE 2: .
CONTAINMENT (SWDA, IWS I, 2, and 3)/NO SOURCE CONTROL GROUNDWATER
. Parker Landfill feasibility Study
Lyndonville, Verotont
I.,',
Revisiun. (,
n.le: 1/18/'1.
!
Type Medium RoquJrommtt Sa.tua Synopsis of Requhement Action to be taken to attain ARAR i
I
Location- Floodplains Vermont Huudous Waste Relevant and Hazardous waste disposal facilities are not to 8 IWS Areas are not located in a
Specific and Seismic Reguladoaa (BPR 7-502) Appropriate be located in seismically active areas nor in seismically active area or in a tOO-year
Zones lOO-year floodplains (unless washout can be floodplain.
prevented or no adverse effects of washout
can be substantiated).
(j roulldwater. Vermont Solid Waste Relevant and Solid waste disposal facilities arc not to be 8 The SWPA is not located in the
Well~lIds, and Regulations (EPR 6-S02, S03) Appropriate located in Class I or Class II groundwater sensitive areas outlined.
Floodplains areas, significant wetlands, or a tOO-year
floodplain/flood stage elevation. Solid waste
facilities arc to be located so as not to
adversely affect drinking water supplies.
Wetlands Vermont Wetland Rules Applicable These regulations include procedures for the 8 Alternative 2 improves protection of
idontification, classification, and protection significant wetlands.
of wetlands.
Federal Guidelines for Relevant and A proposed disposal site for the discharge of 8 Alternative 2 minimizes adverse effects
Specification of Disposal Sites Appropriate dredged or fill material is determined to be to wetlands in the Study Area.
for Dredged or Fill Material (40 either in. compliance or non-compliance with
CFR 230) the guidelines given here. These guidelines
cover potential impacts on human Use
characteristics and potential impacts on
aquatic ecosystems including: physical and
chemical characteristics, biological ;!
characteristics, and special aquatic sites. The
regulations also specify evaluation and testing
to make determinations, and actions to
minimize adverse effects.
Federal Fish and Wildlife Applicable Establishes requirements for a consultation 8 Alternative 2 meets this requiremcnt.
, Coordination Regulations (SO with U.S. Fish and Wildlife Service and slate
CFR 297) wildlife ag~ncies to mitigate losses of fish
. and wildlife that result from modification of
waters.
I;; Ie 'porker/oron/lbl4. B, wp
dLlwp
-------
TABLE 4-2
ARARs SPECIFIC TO REMEDIAL ALTERNATIVE 2:
CONTAINMENT (SWDA, IWS I, 2, and 3)/NO SOURCE CONTROL GROUNDW A TER
Parker LaJidfili Peasibility Study
Lyndonville, Vermont
I'~
Rcvitiiun 0
Dale: 1118/'14
,
Type Medium Rcqulromenta Status Synopsis of Requirement Action to be taken to attain ARAR i
L.ocalion- Wetlands Federal Army Corps of Relevant and Usts conditions that must be met for the . Substantive conditions for a general I
!
Specific (cont'd) Engineen Nationwide Permit Appropriate nationwide general permit to discharge permit will be met under this alternalive, I
I
(cont'd) Program bgulations (33 CPR dredged or fill material. These conditions j
330, Appendix A) include consideration of maintenance, erosion
and siltation controls, aquatic life
movements, equipment usage, endangered
species, suitable material, and mitigation,
Federal Executive Order 11990. Applicable Directs federal agencies to avoid, where . To be considered in pre
-------
TA..,....E 4-3
ARARs SPECIFIC TO REMEDIAL ALTERNATIVES 3,5, and 881
Parker Landfill Feasibility Study .
Lyndonville, Vermont
I'~
R~vilii\Jn I:
DI''': 1/111/''''
.,
Type Medium ltequiremcnt8 Status Synopsis of Roqu.irerncnt Action to be taken to .attain ARAR
:
Chemical- Air Vermont Air Pollution Control Rclevant and Thc following provisions of Vcrmont air 8 Gas collection system for the IWS Areas '
Specific RcgulatioD8 (BPR Chapter 5) Appropriate cmissions reguJations address relevanl and will be evaluated to determine if I
appropriate air pollution issues: controlling pollution thresholds are exceeded for I
emissions of convcntional pollutants and control technology applicalion. i
!
hazardous air pollutants 10 prevenl ambient i
concentrations from cxceeding NAAQS and
Hazard Umiting Values, respectivcly;
minimizing fugitivc particulate cmissions
from material handling and consllUction; and
controlling nuisances and odors.
Federal NESHAP for Vinyl Relevant and Specifies that ,thc concentration of vinyl 8 Gas collection syslem for Ihe IWS ArCllii
Chloride (40 CPR 61 Subpart F) Appropriate chloride in exhaust gas from control will be evaluated to determine if vinyl
cqu.ipment must not exceed 10 ppm. chloride thresholds are exceeded for
control technology applicalion.
Federal NESHAP for Benzene Relevant and Specifies that benzenc waste treatment 8 Gas colleclion syslem for Ihe IWS Areas
Waste Operations (40 CPR 61. Appropriate processes either: (I) removes benzene from will be evalualed 10 delermine if benzene
Subpart FF) the waste stream 10 a level less than 10 ppm, thresholds are exceeded for conlrol
or (2) removes benzene from the wasle lechnology appliculion.
.stream by 99 percent or more on a mass
basis, or (3) incinerates the benzene in a
combustion unit that achieves a 99 percent
destruction efficiency.
IIi
.0
"
Altern..It".. J <.....llmnICnI (5WDA, IWS I, 2, Ind 3)/5nu,.;. Conlrol OruundwII.,;
Alternl'l\c ~ Cun'"lIInlCnI (5WDA, IWS I, 2. Ind ])/ln,SlIu Silli Vlpor EII"~h..n..r tws2 ISnuree Curdr,,1 Oruundwller;
Altern,,""e 1111 U""'''I/,"d'llIl Onound"'a", t>II,acltunfTrealnlOnI1Dia<:ha'lleiColllbinedwilh AheOialive J 0' S.
!'ile ,,,arker/lrln/lhH-C -10'''
tll1wp
-------
. TAuLE 4-3
ARARs SPECIFIC TO REMEDIAL ALTERNATIVES 3, S, and 88:
Parker Landfill Feasibilily Study
Lyndonville, Vennont
I..
Rc:villiinll. t.
Dale: 1I1HN.
-
Type Medium Requirements Status Synopsis of Requirement Action to be taken to atlain ARAR
Chemical- Groundwater Vermont Hazardous Waste Relevant and This regulation establishes the maximum 8 Groundwater qualily would improve due i
Specific Regulations (EPR 7-S02) Appropriate permissible concentrations of hazardous to presence of caps on SWDAand IWS
(cont'd) constituents in groundwater in the uppermost Areas; however, maximum pern~issible '
aquifer underlying the waste OWlagement concentrations for Contaminants of
area beyond the point of compliance. An Concern that are currently excU4:led will
allernale concentration limit (ACL), based on continue to be exceeded until or IInl,'ss
protection of human health and the the source is deplded and/or nulllfill .
environment, may be established by the degradation processes reduce their 'I
Regional Administrator. respective concentrations in groundwater I
below permissible levels. i
Vermont Groundwater Protection Applicable Water qualily standards apply to regulatory 8 Groundwater quality would improve due :i
..
~ !
Regulations (EPR 12) programs that may affect groundwater to presence of caps on SWDA and IWS ;,
II
resources. Prinwy Ground Water Qualily Areas. II
Standards cover a broad range of chemicaJs
that, if present, may detract from the 8 Groundwater quality within the capture I
intended use of the ground water. These zone of the source control extraction
standards include an . remediation goal", system is not expected to achieve
based on federaJ MCLs, USEPA Office of compliance with remediation gnu Is until
Drinking Water, lifetime Health Advisory, the source is depleted and/or natural
or a Vermont Health Advisory, and a degradation processes reduce their
.preventive action limit., which is either respective concentrations in groundwater
IO~ or SO~ of the remediation goat. Both below these standards.
trigger a specified response. Secondary
Ground Water Quality Standards covering 8 Groundwater quality downgradient of the i
panmders that affect aesthetic qualities, also capture zone of the source control
include a preventive action limit, which is extraction system would meet
SO~ of the remediation goal. remediation goals aftcr some pcriml of
treatment system operation.
hie :p.rk~ri.r."ilhl4 -c . wp
"IIWI'
-------
. TA~...E 4-3 .
ARARs SPECIFIC TO REMEDIAL ALTERNATIVES 3, S, and 88:
Parker Landfill Peasibility Study .
LyndOnville, Vermont
1.\
Revi.iulI: II
Dale: 1/1819.'
"1
Type Medium RcquireJocots Status Synopsis of Rcquirement Action to be taken to attain ARAR !
j
!
Chemical- Groundwater Federal Safe Drinking Water Relevant and MCLs have been promulgated for a number . Groundwater quality would improve due ,
Specific (cont'd) Maximum Contamin.nt Levels Appropriate of common organic and inorganic to presence of caps on SWDA and IWS i
i
(cOlit'd) (MCLa) for orpoic and contaminants; and action levels have been Areas. !
inorganic chemical. (40 CFR promulgated for lead and copper. These '
;
141 Subparts B, 0, and I) levels regulate the concentration of . Groundwater quality within the capture
contaminants in public drinking water zone of the source control cllln.Il"lillll
supplies, but may also be considered system is not expected to achieve
appropriate for groundwater aquifers compliance with remediation goals until
potentially used for drinking water. the source is depleted and/or natural I
degradation processes reduce their
respective concentrations in groundwater j'
below these standards.
. Groundwater quality downgradient of the
capture zone of the source control ;
extraction system would meet MCLs !
after some period of treatment system
operation.
i
)
..
..-;.
File :l'uker/ara.n/lbI4-C. wI'
dl/wl'
-------
TAIu..E 4-3
ARARs SPECIFIC TO REMEDIAL ALTERNATIVES 3, S, and 88:
Parker Landfill Feasibility Study .
Lyndonville, Vennont
I. ,
Revitii"11 :,
Da'", 111111'...:
Type Medium RoquiwclDtlDts Status Synopsis of Requirement Action to be taken to attain ARAR .:1
Chemical- Groundwater Federal Safe Drinking Water Relevant and MCWs are health-~ goals (non- 8 Groundwater quality would improve due :1
Speci fie (cont'd) Maximum Contaminant Level Appropriate enforceable) for public water supplies. to presence of caps on SWDA IIOd IWS 11
(c~nt'd) Goals (MCWs) for organic and MCWs are levels considered to have no Areas. \
inorganic chemicals (40 CPR known or anticipated negative health effects i
141 Subpart F) which includes a margin of safety. These 8 Groundwater quality within the capture ,
goals arc available for a number of organic wne of the source control extraction i
i
and inorganic contaminants. system is not expected to achieve I
compliance with remediation goals until I
I
the source is depleted and/or natural I
degradation processes reduce their I
I
respective concentrations in gruulIllwllter I
below these standards. i
8 Groundwater quality downgradient of the i
capture wne of the source control I
extraction system would meet MCLGs I
I
after some period of treatment system i
operation. :
;
Federal Safe Drinking Watet To Be These regulations control contaminants that 8 To be considered in selecting remedial I
:
Nalional SocondaJy Maximum Considered affoct the aesthetic qualilies of drinking water alternative. '
,
Contaminant Levels (SMCLs) such as appearance, odor, and taste. SMCLs
(40 CPR 143.3) arc not federally enforceable but arc intended 1/
to be used by slates as guidelines. "
Federal Safe Drinking Water To Be Tbese regulations' would establish MCLs for 8 To be cOnsidered in selecting rCllIedial
proposed MCLs for synthetic' Considered certain chemical spocies. alternative.
organic chemicals and inorganic
chemicals (40 CPR 141)
Federal Drinking Water Health To Be EPA publishes contaminant-specific health 8 To be considered in selecting remedial
Advisories Considered advisories that indicate the non-carciriogenic alternative.
risks associated with consuming contaminated
drinking water.
Fil..:par~crlaranllbl" ,C ,IIII'
dllwl'
-------
TAba...B 4-3
ARARs SPECIFIC TO REMEDIAL ALTERNATIVES 3, 5, and 88:
Parker Landfill- Feasibility Study .
Lyndonville, Vermont
I;S
Revisi"..: II
Dale: 1118194
~
Type Medium Requi~t8 Status Synopsis of Requirement Action to be taken to 8Uain ARAR i
Chemical- Groundwater Federal Groundwater Protection To Be EPA's GPS includes a component which 8 To be considered in selecting remedial '
Specific (cont'd) Strategy (EPA, AuSUSt 1984) Considered states that groundwater is ecologically vital, alternative.
(cont'd) if the aquifer provides the base now for a I
particularly sensitive ecosystem which, if 8 The aquifer below the Study Area does ;
polluted, would destroy a unique habitat. not provide the base now for a sensitive
habitat. ,
Federal Interim Sediment Quality To Be Sediment quality criteria were compiled from 8 To be considered in selecting remedial ;
&diment
Criteria Considered studies of effects of toxic compounds in alternative. :
sediments on benthic biota. Sediment quality ,
I
criteria have ~ published for metals, 8 Sediment quality would improve due to I
PAHs, and other persistent organic presence of cap on SWDA and IWS '
compounds. Areas.
Action- N/A Vermont Hazardous Waste Applicable Hazardous waste that is generated from 8 Hazardous wastes generated during :
I
Spcc i lie Regulations (EPR Chapter 7 renvxlial activities and I"C(luires off-site remedial activities will he nUlllngcd in I
!
Subchapter 3) disposal will need to be managed in accordance with generator requirements.
accordance with generator requirements,
including identification of waste, I
accumulation in containers or tanks, marking
and labelling, and manifesting the waste to
its final destination.
Vermont Hazardous Waste Applicable Hazardous waste that is !11Bllifested off-site 8 Hazardous wastes shipped off-site will
Regulations (EPR Chapter 7 will require notification to the TSDF that the be accompanied by LDR lIotifieationto
Section 7-106) waste is a restricted waste and either meets the TSDF. i
or does not meet WR treatment standards.
r
File :l'uler/aran/lbI4.C .wl'
<.II/WI'
-------
TAbLE 4-3
ARARs SPECifiC TO REMEDIAL ALTERNATIVES 3, S, and 88:
Parker Landfill feasibility Study
Lyndonville, Ve~ont
I.S
ReVlliiuli U
Dal,,: 11111/'1.,
Type Medium aequirements S~ Synopsis of Requirement Action to be taken to attain ARAR
Action- N/A Vermont Hazardous Waste Applicable These regulations establish requirements for 8 Alternative 3, S or 88 will satisfy
Spcci fie RegulaUoDl (EPR Chapter 7 hazardous waste facilities, including facility security requirements and accomplish the:
Subcblpter S) standards, emergency preparedness and specified objectives of closure and posl- !
prevention, and contingency planning. closure care that are applicable to IWS !
Closure of land disposal units shall be Areas. I
implemented to accomplish the ohjoctives I
I
~ detailed in 40 CfR 264 Subpart f (Releases I
from waste management units), Subpart G
(Closure and post-closurc), and Subpart N i
!
(Landfills). i
Final cover on solid waste landfills arc 8 Alternative 3, S or 88 will satisfy the 1
Vermont Solid Waste Applicable
Regulations (EPR Section 6-702) required to have a minimum slope of 5 final cover requirements applicable to ;1
percent and a maximum slope of 33~ the SWDA. .,
percenl. Grass or ground cover must be 'i
established within four months of final cover, ii
or as soon as weather permits. I
fedenl Solid Waste Regulations To Be The final cover system installed on a solid 8 Vennont solid waste cover requin:mcnls
(40 CFR 258.60) Considered waste landfill must be designed to minimize arc more stringent.
infiltration and erosion, and consist of an
infiltration layer underlying an erosion layer.
The infiltration layer must have at least 18.
of earthen material that has . low
penneabiHty. The erosion layer must consist .~
of at least 6. of earthen material that is
capable of sustaining native plant growth.
r
EPA Tcchnical Guidance To Be Presents EPA recommendations on design 8 To be considered in designing a cap for II
Document: Final Covers on Considered specifications for multilayer landfill caps. IWS Areas.
Hazardous Waste Landfills and. I
Surface Impoundments
Federal Noise Control Applicable Establish noise emission slandards 8pplicahle 8 Construction equipmcnl will bc rC4luired
Rcgulations (40 CFR 204, 20S) to portable air compressors and medium and to comply with applicable noise emission
heavy duty trucks. standards.
Fllc:l'.r~cr/.r.r./lhI4-C .wp
dl/wl'
-------
. TAuLE 4-3
ARARs SPECIFIC TO REMEDIAL ALTERNATIVES 3, 5, and 80:
. Parleer Landfill Peasibility Study
Lyndonville, Vennont
I.S
Revi.uuu U
01"" \JIll/')4
Typt: Medium llequirernent8 Slalus Synopsis of Requirement Action to be taken to attain ARAR
Action- N/A Vermont Land Use and Relevant and Construction of improvements on tracts of 8 Alternative 3, 5 or 88 facilitates
Specific DevelopDlt.Gt Law (Act 250 - 10 Appropriate land larger than 10 acres arc requ.ircd to compliance with the Act by reducing
(cont'd) VSA Chapter 151) comply with criteria specified in the Act, leachate generation and controlling
including no undue air or water pollution, no erosion from SWDA and IWS Areas.
disposal of barmfuJ or toxic substances to
groundwater, no unreasonable soil erosion, I
compliance with wetlands rules, and no I
advel'llC affects on aesthetic values. I
I
,
Air Federal Proposed Regulation for To Be Proposes emission standards for VOCs from 8 To be considered in predesign studies. I
,
Control of VOC. Considered groundwater treatment units such as air I
strippers. I
Surface Vermont Water Quality Applicable Outlines criteria for discharging into waters 8 Alternative 3, 5 or 88 meets these
Waters Standards (EPIt Section 1-(4) of the state and discusses the assimilative criteria.
capacity of such waters.
Vermont Water Quality Applicable Water quality criteria arc to be calcuJated on 8 Alternative 3, 5 or 88 satisfies this ,
Standards (EPR Section 2-02) the basis of 7QI0 flow values. requ.irement. I
I
Vermont Water Quality Applicable A specific portion of the receiving waters 8 Alternative 3, 5 or 88 satisfies these I
Standards (EPRSection 2;03) that docs not exceed 200 feet from the point rcqu.irement. I
i
of discharge sball be the designated mixing ,
zone for properly treated waste. The mixing 1
zone sball not have adverse effects on hUm8n
health, aquatic life, or existing uses of the
receiving waters. . ;
Vermont Water Quality Applicable Stormwater runoff shall not have an undue 8 Alternative 3, 5 or 811 will fllt'ililille
Standards (EPR Section 2-05» adverse effect on the receiving waters. compliance with this requiremcnl by
controlling erosion and mnorr from
SWDA and IWS Areas.
Vermont Water Quality Applicable Outlines the established criteria for dissolved 8 Alternative 3, 5 or 8n meets these
Standards (EPR Section 3-01) oxygen, temperature, phosphoms, nitrates, criteria.
aquatic habitats, sJudge deposits or solid
refuse, solids aJid oil, alkalinity; pH, and
toxic substances, excel)t in mixing zones.
Fil":parl""lrln/lbI4-C .wp
dl/wp
-------
. TAuLE 4-3 .
ARARs SPECIFIC TO REMEDIAL ALTERNATIVES 3, 5, and 88:
Parker Landfill Feasibility Study .
L.yndonville, Vermont
I.S
Reviaiun (8
111.<: 111111".1
Type Medium Requirements Status Synopsis of Requirement Action to be taken 10 attain ARAR
Action- Surface Verinont Water Quality Applicable Outlines the criteria for turbidity, E. coli, 8 Alternative 3, 5 or 88 m~ts Ihese
Specific Waters Standarda (BfR Section 3-(4) color, taste, and odor, except in mixing criteria.
(cont'd) (cont'd) zones.
Vermont Water Quality . Applicable Toxic wastes concentrations shall not have an 8 Allemative 3, 5 or 8n meels Ihese
Standards (£fR Section 3-(6) adverse impact on hUDWt health, or aquatic criteria.
lifc.
Vennont Water Quality Applicable Outlines current water quality criteria for the 8 Alternative 3, 5 or 88 m~ls these
Standards (EPR Appendix D) protection of aquatic biota. criteria.
Vennont NPDES Pcrmit Relevant and Specify thc procedures required to obtain a 8 Alternative 3, 5 or 88 satisfies these '
Program Regulations (BPR appropriate NPDES pcnnit to discharge any waste into requirements. F
Chapter 13) tho waters of Vennont, . and the terms and ..
conditions of permits. Requirements for I:
monitoring, recording, and repOrting arc also i
included. f
! ~
:\
Federal Quality Criteria for Applicable Pursuant to Section 304(a)(I) of the Clean 8 Alternative 3, 5 or 88 m~ts (hese ,1
Water Water Act, the EPA establishes ambient criteria. j;
water quality criteria. These criteria present I:
scientific data and guidance on the
environmental effects of pollutants. The h
criteria can contribute to establishing. '
regulatory requirements that govern impacts ;
to water quality. i
I
lOcation- FI~plains Vennont Hazardous Waste Relevant and Haardous waste dispOsal facilities arc not to 8 IWS Areas are not located in a
Specific and Seismic Regulations (EPR 1-502) Appropriate be located in seismically active areas nor in seismically active area or in a IOU-year ,
ZOnes loo-year floodplains (unless washout can be floodplain.
prevented or no adverse effects of washout
can be substantiated).
Fil":l'erkerferlraflhI4.C. WI'
,II/WI'
-------
TA..--B 4-3
ARARs SPECIFIC TO REMEDIAL ALTERNATIVES 3,5, and 88:
Parker Landfill Feasibility Study .
Lyndonville, Vermont
I.~
Rt:villiiun. ()
Dale: 11111/9-1
Type Medium 1lequjJemeQts Stanis Synopsi. of Requirement Action to be taken to attain ARAR
I..ocation- Groundwater, Vermont Solid Waste Relevant and Solid waste disposal facilities are not to be 8 The SWDA is not located in the
Specific Wetlands, and RegulatiOILl (HPR 6-502,503) Appropriate located in Class I or Class II groundwater sensitive areas outlined.
Floodplains areas, significant wetlands, or a tOO-year
floodplain/flood stage elevation. Solid waste
facilities are to be located so as not to
adversely affect drinking water supplies.
Wellands Vermont Wetland Rules Applicable These regulations include procedures for the 8 Alternative 3, 5 or 88 improves
identification, classification, and proteCtion protection of significant wetlands.
of wetlands.
Federal Guidelines for Relevant and A proposed disposal site for the discharge of 8 Alternative 3, 5 or 88 minimizes
Specification of Disposal Sites Appropriate dredged or fill material is determined to be adverse effects to wetlands in the Study
for Dredged or Fill Material (40 either in compliance or non-compliance with Area.
CPR 230) the guidelineS given here. These guidelines
cover potential impacts on human use
characteristics and potential impacts on
aquatic ecosystems including: physical and
chemical characteristics, biological
characteristics, and special aquatic sites. The
regulations also specify evaluation and testing
to make determinations, and actions to
minimize adverse effects.
Federal Fish and Wildlife Applicable Establishes requirements for a consultation 8 Alternative 3, 5 or 88 meets Ihis
Coordination Regulations (SO with U.S. Fish -..d Wildlife Service and state requirement.
CPR 297) wildlife agencies to mitigate losses of fish
and wildlife that result from modification of
waters.
Federal Army Corps of Relevant and Usia conditions that must be met for the . Substantive conditions for a general
Engineers Nationwide Permit Appropriate nationwide general permit to discharge permit will he met.
Program Regulations (33 CFR dredged or, fill material. These conditions I
330, Appendix A) include consideration of maintenance, erosion
and siltation controls, aquatic life
movemca18, equipment usage, endangered
species, suitahle material, and mitigation.
fil~:p.rk~r/8f.r./11~14-C .wp
.h/wp
-------
T ALo~ 4-3
ARARs SPECIFIC TO REMEDIAL ALTERNATIVES 3, S, and 88:
Parker LvtdfiU Feasibility Study .
Lyndonville, Vermont
I.~
Rcvi,iun. ti
Dale: III KN-I
Type Medium JequireQW1ts Status Synopsis of Requirement Action to be taken to attain ARAR
Location- Wetlands Federal Executive Order 11990 Applicable Directs federal agencies to avoid, where . To be considered in predesign studies.
Specific (cont'd) Protection of Wetlands (40 CPR possible, adversely effecting or destroying
(cont'd) 6, AppIIIdix A) wetJands. Requirements for wetJands
detennination, assessment, and preservation
or restoration are set forth.
. Floodplains Federal Eltecutive Order 11938 Applicable Requires federal agencies to avoid, where. . To be considered in prooesign studies.
Floodplain Management (40 possible, adversely effecting floodplains.
CFR 6, Appendilt A) Requirements for floodplains determination,
assessment, and preservation or restoration
are set forth.
I'ile:pMrkcr/.r8n/lbl4-C _WI'
dl1wp
-------
TAbLB 4-4
ARARs SPBCIFIC TO RBMBDIAL ALTERNATIVES 4 and 8AI
Parker Landfill Peasibility Study
Lyndonville, Vennont
..s
Revisiun. (J
1>0''': 11111"1,1
Type Medium Requi"mcnts Status Synopsi. of Requirement Action to be taken to attain ARAR
Chcmical- Air Vermont Air Pollution Control Relevant and The following pmvisions of Vermont air 8 Gas collection syslcm fur Ihc IWS A"clI~
Specific Regulations (BPR Chapter S) Appropriate emissions regulations address relevant and will be evaluated to determinc if
appropriate air pollution issues: controlling pollution thresholds are exceeded for
emissions of conventional pollutants and control technology application.
hazardous air pollutants to prevent ambient
concentrations from exceeding NAAQS and
Hazard Umiting Values, respectively;
minimizing fugilive particulate emissions
from material handling and construction; and
controlling nuisances and odors.
Federal NESHAP for Vinyl Relevant and Specifics that ,the concenlration of vinyl 8 Gas collection system for thc IWS Arcus
Chloride (40 CPR 61 Subpart P) Appropriate chloride in exhaust gas from control will be evaluated to delermine if vinyl
equipment must not exceed 10 ppm. chloride thresholds are exceeded lor
control technology application.
Federal NESHAP for Benzene Relevant and Specifics that benune waste treatment 8 Gas collection system for the IWS Areas
Waste Operations (40 CPR 61, Appropriate processes either: (I) removes benzene from will be evaluated to detennine if benzene
Subpart FF) the waste stream to a level less than 10 ppm. thresholds are exceeded for conlrul
or (2) "moves benune from the waste technology application.
stream by 99 percent or more on a mass
basis, or (3) incinerates the benzene in a
combustion unit that achieves a 99 percent
destruction efficiency.
Alle".....e ~ C"nlo...men. (SWDA. IWS I, 2. and JI'ln.SiIU SUI I Vapur EJUra~tiun of IWS2 INo Sou~o Cunlrul Orou'ndwater;
Alle",,"ve IIA, D.,wllllroJ."nt UnMlndwater E.If8~tlonfTreatrnentJDi8CharBelCombinedwitb Allernative 2 or 4.
hi" 1,.,k"".....'II,I" 1>."'1'
.hl",p
1.II~c I ,I' .'
-------
TAbLE 4-4
ARARs SfECIFIC TO REMEDIAL ALTERNATIVES 4 and SA';
Parker Landfill Peasibility Study
Lyndonville, Vennont
I.:.
Rcvi,iun: I~
D.loo: II III}').:
. _.- h ]
Type Medium Rcquirements Status Synopsis of Rcquirement Action to be taken to auain ARAR
ChemicaJ- Groundwater Vermont Haz.anIous Waste Relevant and This regulation establishes the maximum 8 Groundwater quality would improve due I
Specific ReguJationa (EPR 7-502) Appropriate permissible concentrations of hazardous to presence of caps on SWDA and IWS
(conI' d) constituents in groundwater in the uppermost Areas; however, maximum permissible
aquifer underlying the waste management concentrations for Contaminants of
area beyond the point of compliance. An Concern that arc currenlly exceeded will
aJtemate concentration limit (ACL), based on continue to be exceeded until or unless
protection of human health and the the source is depleted aud/or IIII.urlll
environment, may be established by the degradation processes reduce .heir
RegionaJ Administralor. respective concentrations in groundwater
below permissible levels.
Vermont Groundwater Protection Applicable Water quality standards apply to regulatory 8 Groundwater quality would improve due
Regulations (EPR 12) programs that may affect groundwater to presence of caps on SWDA and IWS
resources. Prinwy Ground Water Quality Areas; however, remediation goals for
Standards cover a broad range of chemicaJs Contaminants of Concern that are
that, if present, may detract from the currenlly exceeded will continuc to hc
intended use of the ground water. These exceeded until or unless the source is
standards include an .remediation goaJ" , depleted and/or natural degradation
based on federal MCLs, USEPA Office of processes reduce their respective
Drinking Water, Ufetimc HcaJth Advisory, concentrations in. groundwlI.cr helow
or a Vermont HcaJth Advisory, and a these standards.
.preventive action limit., which is either
10~ or SO~ of the remcdiation goaJ. 80th
trigger a specified response. Secondary
Ground Water Quality Standards covering
parameters that affect aesthetic qualities, aJso
include a preventive action limit, which is
So~ of the remediation goal.
File :parker/arar./lbI4- D. wp
dllwp
-------
, TAbL£ 4-4 ,
ARAKs SPECIFIC TO REMEDIAL ALTERNATIVES 4 and 8..\1:
Parker Landfill Feasibility Study
LyndoDville, Vermont
I.'"
Revisiun: n
Dale: 11181').\
.
Medium RequiroDWIts Status Synopsis of Requirement. Action to be taken to auain ARAR. .
Type !
-,
Chemical- Groundwater Federal Safe Drinking Water Relevant and MCLB have been promulgated for a number 8 Groundwaler quulily would improvc duc I
Specific (cont'd) Maximum Contaminant Levcls Appropriate of common organic and inorganic' ' to presencc of caps on SWDA and IWS I
(coni'd) (MCLa) for orpnic and contaminants; and action levcls have been Areas; however, MCUi for i
I
inorganic chemicals (40 CPR promuJgated for lead and copper. These Contaminants of Concern thaI are I
141 Subputl B, G, and I) levels regulate the concentration of currently exceeded will continue 10 be I
I
contaminants in public drinking water exceeded until or unless the source is
supplies, but may also be considered depicted and/or natural degradalion
appropriate for groundwater aquifers processes reduce their respective
potentially used for drinking water. concentrations in groundwaler below Ihe
MCLs.
Federal Safe Drinking Water Relevant and MCLGs are health-based goals (non- 8 Groundwater quality would improve due
Maximum Contaminant L.cvel Appropriate enforceable) for public water supplies; to presence of caps on SWDA and IWS
Goals (MCLGs) for organic and MCLGs are levels considered to have no Areas; however, MCLGs Ihat are
inorganic chemicals (40 CPR known or anticipated negative health effects currently exceeded will conlinue 10 be
141 Subpart F) which includes a margin of safety. These exceeded until or unless the source is '
goals are available for a number of organic depicted and/or natural degradalion
and inorganic contaminants. processes reduce Ihe concenlralions of
contaminants below the MCLGs.
Federal Safe Drinking Water To Be These regulations control contaminants that 8 To be considcred in selecting remooial
National Secondary'Maximum Considered affect the aesthctic quaJities of drinking watcr alternative.
Contaminant Levels (SMCLs) such as appearance, odor, and taste. SMCLs
(40 CPR 143.3) are not federally enforceable but arc intended
to be used by states as ,guidelines.
Federal Safe Drinking Water To Be These regulations would establish MCLs for 8 To be considcred in seleCling rClllCtlill1
proposed MCUi for synthetic Considcred certain chemical species. altemativc.
organic chemicals and inorganic
chemicals (40 CPR 141)
Federal Drinking Water Health To Be EPA publi¥tcs contaminant-specific heal(b, 8 To be considered in selecting rc:mcdial
Advisories Considered advisories that indicate (be non-carcinogenic aJtemative.
risks associated wi(b consuming conlaminaled
drinking water. '
File :l'arker/arar'/lbI4' D. wI'
III/wI'
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TAb....E 4-4
ARARs SPECIFIC TO REMEDIAL ALTERNATIVES 4 and SAI:
Parker Landfill Feasibility Study .
Lyndonville, Vermont
I'S
Revi.iun: II
Dlle: 11\8N-I
Synopsis of Requirement '
Type Medium Requiranents Status. Action, to be taken to attain ARAR I
Chemical- Groundwater Federal Groundwater Protection To Be EPA's GPS includes a component which 8 To be considered in selecting remedial I
I
Specific (cont'd) StrateI}' (BrA, August 1984) . Considered states that groundwater is ecologically vital, alternative. I
(co~t'd) if the aquifer provides the base now for a I
I
particularly sensitive ecosystem which, if 8 The aquifer below the Study Area does
polluted, would destroy a unique habitat. not provide the base now for a sensitive
habitat.
Sediment Federal Interim Sediment Quality To Be Sediment quality criteria were compiled from 8 To be considered in sdecting remedial I
Criteria Considered studies of effects of toxic compounds in alternative. I
sediments on benthic biota. Sediment quality
criteria have been published for metals, 8 Sediment quality would improve due to
, PAHs, and other persistent organic presence of cap on SWDA and IWS
compounds. Areas; however, sediment quality
criteria for Contaminants of Concern
that are currently exceeded will continue
to be exceeded Wltil or unless the source
is depleted and/or natural degradation
processes reduce their respective
concentrations in sediment below the
reconuiumded criteria.
Action- N/A Vermont Hazardous Waste Applicable Hazardous waste that is generated from 8 Hazardous wastes generated during
Specific Regulations (EPR Chapter 7 r'Cmediai activities and requires off-site remcdial activities will be managed in
Subchapter 3) disposal will need to be manaaed in accordance with generator requirements.
accordance with generator requirements,
. including identifiCation of waste, .i
accumulation in containers or tanks, marking .'.
and labelling, and manifesting the waste to
its final destination.
Vermont Hazardous Waste Applicable Hazardous waste that is manifested off-site 8 Hazardous wastes shipped off-site will
-.
Regulations (EPR Chapter 7 will require notification to the TSDF that the be accompanied by LDR notification to
. Section 7-106) waste is a restricted waste and either meets the TSDF.
or docs not meet LDR treatment standards.
. .
File :parker/.r1n/lhI4. D. wp
,II/wI'
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. TAbLE 4-4
ARARs SPECIFIC TO REMEDIAL ALTERNATIVES 4 and 8A':
. Parker Landfill Peasibility Study
Lyndonville, Vermont
I'~
R"vilillil. ()
1>1'''; III HI".
Type Medium aoqui~ts Status Synopsis of Requirement Action to be taken to allain ARAR ;
;
Action- N/A Vermont Hazardous Waste Applicable These regulations establish requirements for 8 Alternative 4 or 8A will satisfy securily
Specific ReguJatiODl (BPR Chapter 7 bazardous waste facilities, including faCility requirements aodaccomplish the Ii
(cont'd) Subcb8pler 5) standards, emergency preparedness and specified objectives of closure and post-
prevention, and contingency planning. closure care that arc applicable to IWS
Closure of land disposal units shall be Areas.. !
implemented to accomplish the objectives
detailed in 40 CPR 264 Subpart P (Releases .
from waste management units), Subpart G I
!
(Closure and post-closure), and Subpart N I
(Landfills).
I
Vennont Solid Waste Applicable Pinal cover on solid waste landfills are 8 Alternative 4 or 8A will satisfy the final I
Regulations (EPR Section 6-702) required to have a minimum slope of S cover requirements applicable to Ihe I
percent and a maximum slope of 33'Aa SWDA.
percent. Grass or ground cover must be
established within four months of final cover,
or as soon as weather permits.
Pederal Solid Waste Regulations To Be The final cover system installed on a solid 8 Vennont solid waste cover requirements
(40 CPR 158.60) Considered waste landfill must be designed to minimize are more stringent.
infiltration and erosion, and consis, of an
infiltration layer underlying an erosion layer.
The infiltration layer must have at least 18.
of earthen material that bas a low
permeability. The erosion layer must consist .
of at least 6. of earthen material that is ;
capable of sustaining native plant growth.
EPA Technical Guidance To Be Presents EPA mcommcndations on design 8 To be considered in designing a cal) Il,r
Document: Pinal Covers on Considered specifications for multilayer landfill caps. IWS Areas.
Hazardous Waste Landfills and
Surface Impoundments
Federal Noise Control Applicable Establish noise emission standards applicable 8 Construction equipment wiil be rC4luired
Regulations (40 CFR 204, 2OS) to portable air compressors and medium and to comply with applicable lIoise emissioll
heavy duty Irucb. standards.
Fit" :plrlcr/lrar'/lbI4. D. wp
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TAhLE4-4
ARARs SPECIPIC TO REMEDIAL ALTERNATIVES 4 and 8AI:
Parker Landfill Feasibility Study
Lyndonville, VenDont
I'~,
Ncvi....",- (I
Dale: IIIHN-\
Type Medium Requirements Status Synopsis of Requirement Action to be taken to attain ARAR II
I,
"
"
Action- N/A Vennont Land Use and Relevant and Construction of improvements on tracts of . Alternative 4 or 8A facilitates "
!
Specific Development ~w (Act 250 - 10 Appropriate land larger than to acres are required to compliance with the Act by reducing
(cont'd) VSA Chapter 151) comply with criteria specified in the Act, ' leachate generation and controlling "
"
including no undue air or water pollution, DO erosion from SWDA and IWS Areas. ~ ;
disposal of harmful or toxic substances to '
groundwater, no unreasonable soil erosion,
compliance with wetlands rules, and no
adverse affects on aesthetic values. ,
Air Federal Proposed Regulation for To Be Proposes emission standards for vacs from . To be considered in predesign studies. I
Control of VOCI Considered groundwater treatment units such as air I
i
strippers. ;'
.,
!,
Surface Vermont Water Quality Applicable Stormwlter runoff shan not have an undue 8 Alternative 4 or 8A will facilitale r
Waters Standards (EPR Section 2-05» adverse effect on the ~eiving waters. compliance with this requirement by \:
controlling erosion and runoff from
SWDA and IWS Areas. !
,
Location- Floodplains Vermont Hazardous Waste Relevant and Hazardous waste disposal facilities are not to . IWS Areas are not located in a I
Specific and Seismic Regulations (EPR 7-502) Appropriate be located in seismically active areas nor in seismically active area or in a loo-year
Zones IOO-year floodplains (unless washout can be floodplain.
prevented or no adverse effects of washout
can be substantiated).
Groundwater, Vermont Solid Waste Relevant and Solid waste disposal facilities arc not to be 8 The SWDA is not located in the
Wetlands, and Regulations (EPR 6-502, 503) Appropriate located in Class I or Class II groundwater sensitive areas outlined.
Floodplains areas, significant wetlands, or a tOO-year
Roodplain/Rood stage elevation. Solid waste
facilities arc to be located so as not to
adversely affect drinking water supplies.
Wetlands Vermont Wetland Rules Applicable These regulations include procedures for the . Alternative 4 or 8A improves proleclion
identification, classification, and protection of significant wetlands.
of wetlandi~
hie :".rker/aran/lbH -0. "'p
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. T AIiLE 4-4
ARARs SPECIFIC TO REMEDIAL ALTERNATIVES 4 and SAI:
Parker Landfill Feasibility Study
Lyndonville, Vermont
.;s
Revi.ion: II
Dale: 1/18/94
Type Medium Requirements Status Synopsis of Requirement Action to be taken to attain ARAR
Location- Wetlands Federal Guidelines for Relevant and A proposed disposal site for the discharge of 8 Alternative 4 or SA minimizes adverse
Specific (cont'd) Specification of Disposal Sites Appropriate dredged or fill material is determined to be . effects to wetlands in the Study Area.
(cont'd) for Prodaod or Fill Material (40 either in compliance or non-compliance with
CPR 230) the guidelines given here. These guidelines
cover potential impacts on bUDW1 use
characteristics and pOtential impacts on
aquatic ecosystems including: physical and
cbemical characteristics, biological I
cbaracteristics, and special aquatic sites. The
reguJations also specify evaluation and testing
to make determinations, and actions to i
,
minimize adverse effects.
Federal Fish and Wildlife Applicable Establishes requirements for a consultation 8 Alternative 4 or SA meets this
Coordination ReguJations (SO with U.S. Fish and Wildlife Service and state requirement. I
CPR 297) wildlife agencies to mitigate losses of fish i
and wildlife that rcsuJt from modification of I
i
waters. j
Federal Army Corps of Relevant and Lists conditions that must be met for the 8 Substantive conditions for a gencrnl
Engineers Nationwide Permit Appropriate nationwide general permit to. discharge permit will be met under this alternative.
Program Regulations (33 CPR dredged or fill material. These conditions
330, Appendix A) include consideration of maintenance, erosion
and siltation controls, aquatic life
movements, equipment usage, endangered
species, suitable material, and mitigation.
Federal Executive Order 11990 Applicable Directs federal agencies to avoid, where 8 To be considere<1 in predcsign shulics.
Protection of Wetlands (40 CPR possible, adversely effecting or destroying
6, Appendix A) wetlands. Requirements for wetlands
determination, assessment, and preservation
or restoration arc set forth.
File :l'arker/uan/11>14- D. wI'
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. TAbLE 4-5 .
CHEMICAL-SPECIFIC ARARs: CRITERIA, ADVISORIES, AND GUIDANCE
Parker Landfill Feasibility Study .
LyndOnville, Vermont
I'S
R~vibiun. ()
Dlle: 11111/94
Medium RequiremeotJ Statue Alternatives Synopllis of Roquirement Action to be taken to attain ARAR !1
STATE REGULATORY REQUIREMENT 1\
,I
Air Vermont Air Pollution Control Relevant and 2; 3; 4; 5; 8a; Address controlling emissions of conventional . Gas collection system for the IWS ;1
Rcgulations (EPR Chapter 5) Appropriate 8b pollutants and hazardous air pollutants to Areas will be evaluated to I
prevent ambient concentrations from exceeding determine if pollution thresholds
NAAQS and Hazard Limiting Valucs, are exceeded for control technology
respectively; minimizing fugitive particulate application.
emissions from material handJing and . .\
constRiction; and controlling nuisances and
odors. I
I
I
Groundwater Vcrmont Hazardous Waste Relevant and I; 2; 3; 4; S; Establishes the maximum permissible . Maximum permissible I
Regulations (EPR 1-502) Appropriate 8a; Sb concentrations of hazardous constitucnts in concentrations were considered in. I
groundwater in the uppermost Iqwfer dcvcloping cleanup levels. I
underlying the waste managcment area beyond I
!
tho point of compliance. i
!
Vermont Groundwater Protection Applicable 1;2; 3; 4; S; Primary Ground Water Quality Standards . Water quality standards were
Regulations (EPR 12) 8a; Sb cover. broad noge of chemicals that may considered in developing cleanup I
I
detract from the intended use of the ground standards. I
I
water. Secondary Ground Water Quality I
Standards cover parameters that affect I
I
aesthetic qualities. I
FEDERAL REGULATORY REQUIREMENTS .1
Air federal NESHAP for Vinyl Relevant and 2; 3; 4; 5; Sa; Specifics that the concentration of vinyl . Vinyl chloride threshold was I
I
. Chloride (40 CPR 61 Subpart P) Appropriate 8b chloride in exhaust gas from control considered for control technology I
oqwpment must not exceed 10 ppm. application. I
File :plrker/aran/chm-1p. rl
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PIgd J ..t' J
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TAba...rl 4-S
CHEMICAL-SPECIFIC ARARs: CRITERIA, ADVISORIES, AND GUIDANCE
Parker Landfill Peasibility Study .
Lyndonville, Vermont.
I;S
Rel/i,iun: II
DaCe: 111819.1
Medium . Requirements Status Altel'Q8tiv~ .. Synopsis of Requirement Action to be taken to attain ARAR
Air (cont'd) Federal NESHAP for Benzeno Rclevant and 2; 3; 4; S; Sa; Specifies that benzene waste treatment 8 Benzene threshold was consi~ered
Waste Operations (40 CPR 61 Appropriate Sb processes either: (1) removes benzene from for control technology application.
Subpart Fp) the waste stream to a level less than 10 ppm,
or (2) removes benzene from the waste stream
by 99 percent or more on . mass basis, or (3)
incinerates the benzene in a combustion un.it
that achieves a 99 percent destruction
efficiency.
Groundwater Federal Safe Drinking Water Rclevant and 1; 2; 3; 4; Sj MCLs have been promulgated for a number of 8 The concentrations of constituenls
Maximum Contaminant Levels Appropriate Sa; Sb common organic and inorganic contaminants; were compared to MCLs. MCLs
(MCLs) for organic and and action levels have been promulgated for were considered in developing
inorganic chemicals (40 CPR lead and copper. These levels regulate the recommended cleanup levc:ls for
141 Subparts B, G, and I) concentration of contaminants in public groundwater.
drinking water supplies, but may also be
considered appropriate for groundwater
aquifers potentially used for drinking water.
Federal Safe Drinking Water Relevant and I; 2: 3; 4; S: MCLGs arc heaJth-bascd goals (non- 8 MCLGs were considered in
Maximum Contaminant Level Appropriate Sa; 8b enforceable) for public water supplies. developing recommended cleanup
Goals (MCLGs) for organic and MCLGs arc levels considered to have no levels for groundwater.
inorganic chemicals (40 CPR known or anticipated negative heaJth effects
141 Subpart F) which includes a margin of safety. These
goals arc available for a number of organic
and inorganic contaminants.
Federal Safe Drinking Water ToBc I: 2; 3; 4; S: These regulations control contaminants that 8 SMCLs were considered in
National Secondat)' Maximum Considered Sa; Sb affect the aesthetic qualities of drinking water developing cleanul) levels.
Contaminant Levels (SMCLs) such as appe8.rancc. odor, and taste. SMCLs
(40 CPR 143.3) arc not federaJly enforceable but arc intended
to be used by stateS as guidelines.
Federal Safe prinking Water ToBc I; 2; 3; 4: S; These a:egulations would establish MCLs for 8 Proposed MCLs were considered in
proposed MCLs for synthetic Considered 8a; Sb certain chemical species. developing cleanup levels.
organic chemicals and inorganic
chemicals (40 CPR 141)
File :parkcr/.r.n/~hm-'I'. r,
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TAba..S 4-5
CHEMICAL-SPECIfiC ARARs: CRITERIA, ADVISORIES, AND GUIDAN'CE
Parker Landfill'Peasibility Study
Lyndonville, Vennont
I'S
Rcvi.iun. U
n.le; 111111'1-1
Medium Rcquiremcn" . . StabJ8 A1te.......y~; Sypopsis of Requirement Action to be taken to allain ARAR
Groundwater 'Federal Drinking Water Health To Be 1;2;3;4;S; EPA publishes contaminant-specific health . Health advisories were consider&:
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T AuLE 4-6
ACTION-SPECIFIC ARARs: CRITERIA, ADVISORIES, AND GUIDANCE
Parker Landfill Feasibility Study
Lyndonville, Vermont
I.S
Revi.iun. II
nale: 1I18N~
Medium Rcquirements Status Alternatives - Synopsis 01 RcquireQtCnt Action to be taken to auain ARAR I
!
,
STATE REGULATORY REQUIREMENT .
,
N/A Vermont Hazardous Wute Applicable 3;4;5; BA; 88 Hazardous waste that is generated from 8 Spent carbon generated during i
Regulations (EPR Chapter 1 remedial activities and requires off-site remedial activities will be managed in
Subchapter 3) disposal will need to be managed in accordance with generator
accordance with generator requirements, requirements. I
including identification of waste,- I
,
accumulation in containers or tanks,
marking and labelling, and manifesting the
waste to its final destination.
Vern10nt Hazardous Waste Applicable 3; 4; 5; 8A; 88 Hazardous waste that is manifested off-site 8 Hazardous wastes shipped off-site will
Regulations (EPR Chapter 7 will require notification to the TSDF that be accompanied by LDR notification
Section 1-1(6) the waste is a restricted waste and either to the TSDF.
meets or docs not meet LDR treatment
standards.
Vermont Hazardous Waste Applicable 2; 3; 4; 5; 8A; These regulations establish requirements 8 Security requirements and specified
Regulations (EPR Chapter 1 88 for hazardous waste facilities, including objectives of closure and post-closnre
Subchapter 5) facility standards, emergency preparedness care that arc applicable to IWS Areas,
and prevention, and contingency planning. were considered in developing
Closure of land disposal units shall be remedial alternatives.
implemented to accomplish the objectives
detailed in 40 CPR 264 Subpart P
(Releases from waste management units), -
Su~part G (Closure and post-closure), and
Subpart N (Landfills).
Vermont Solid Waste Applicable I; 2; 3; 4; 5; Pinal cover on solid waste landfills are 8 Final cover requirements applicahle 10
Regulations (EPR Section 6-102) 8A; 88 required to have a minimum slope of 5 the SWDA were considered in I
percent and a maximum slope of 33% developing remedial alternatives. .
percent. Grass or ground cover must be
established within four months of final
cover, or as soon as weather permits.
File :parker/a rali/acl"p,",
dtlwp
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TAbLE 4-6
AcnON-SPECIFlC ARARs: CRITERIA; ADVISORIES, AND GUIDANCE
Parker Landfill Peasibility Study
Lyndonville, Vermont
I-~
Reviaion: \I
Dlle: 1/18/9-\
Medium Require~ta Status AltcmatiVC8 Synopsis 01 RequireIDCQt' Action to be taken to attain ARAR I
N/A Vennont Land Use and Relevant and I; 2; 3; 4; S; Construction of improvements on tracts of 8 Act 250 requirements were considered
Development Law (Act 2SO - 10 Appropriaac 8A;88 land larger than 10 acrea arc required to in developing remedial alternatives.
VSA Chapter ISI) comply with criteria specified in the Act,
including DO undue air or water pollution,
DO disposal of harmful or toxic substances
to groundwater, no unreasonable soil
erosion, compliance with wetlands ruleS,
and no adverse affects on aesthetic values.
Surface Vennont Water Quality Applicable 3; S; 88 Outlines criteria for discharging into 8 These criteria will be considered in
Waters Standards (EPR Section I-(4) waters of the state and discusses the prcdesign.
usimilative capacity of such waters.
Vennont Water Quality Applicable 3; S: 88 Water quality criteria arc to be calcuJated 8 The requirement will be considered in
Standards (EPR Section 2-(2) OD the basis of 1QI0 now values. predesign.
Vemiont Water Quality Applicable 3; S; 88 A specific portion of the receiving waters 8 These requirements will be considered
Standards (EPR Section 2~3) that docs not exceed 200 feet from the in predesign.
point of discharge shall be the designated
mixing zone for properly treated waste. . ,
i
The mixing ZODe shall Dot have adverse !
effects OD human health, aquatic life, or !
existing uses of the receiving waters. i
1
Vennont Water Quality Applicable I; 2: 3; 4: S; StonDwater nmoff Shall not have an undue 8 Stormwater runoff was considered in i
Standards (EPR Section 2~5» 8A:88 adverse effect on the receiving waters. developing remedial alternatives.
Vennont Water Quality Applicable 3; S: 88 Outlines the established criteria for 8 These criteria will be considered in I
Standards (EPR Section 3~1) dissolved oxygen, temperature, predesign.
phosphorus, nitrates, aquatic habitats,
sludge deposits or solid refuse, solids and
oil, alkalinity, pH, and toxic substances, I
except in mixing zones.
Vennont Water Quality . Applicable 3; S; 88 Outlines the criteria for turbidity, E. coli, 8 These criteria will be considered in I
Slandards (EPR Section J-(4) color, taste;and odor, except in mixing prcdesign. i
zones.
Filc:parkcllll8r./a~I'al' - fa
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. T Au....E 4-6
ACTION-SPECIFIC ARARs: CRITERIA, ADVISORIES, AND GUIDANCE
Parker Landfill Peasibility Study .
~yndOnville, Vermont
I'S
Revi.iun: 0
Dale: 11111/94
Medium Requirementa Status Alterpativea Synopsis o( Requirement Action to be talcen to altain ARAR
Surface Vermont Water Quality Applicable 3; 5; 88 Toxic wastes concentrations shall not have 8 This requirement will be considered in
Waters Standards (EPR Section ]-(6) an adverse impact on human health, or predesign.
(cont'd) aquatic life.
Vermont Water Quality Applicable 3;5; 88 Outlines current water quality criteria for 8 These criteria will be considered in
Standards (EPR Appendix D) the protection of aquatic biota. predesign.
Vermont NPDES Permit Relevant and 3;5; 88 Specify the procedures required to obtain 8 A NPDES permit will be ohillinc:tl for
Program Regulations (EPR Appropriate a NPDES permit to ~scharge any waste discharges to the Passumpsic River.
Chapter 13) into the waters of Vermont, and the terms
and conditions of permits. Requirements
for monitoring, recording, and reporting
arc also included.
FEDERAL REGULATORY REQUIREMENTS
N/A Federal Solid Waste Regulations To Be I; 2; 3; 4; 5; The final cover system installed on a solid 8 Vermont solid waste cover
(40 CFR 258.60) Considered 8A; S8 waste landfill must be designed to requirements are more stringent.
minimize infiltration and erosion, and
consist of an infiltration layer underlying
an erosion layer. The infiltration layer
must hav~ at least IS8 of earthen material
that has . low permeability. The erosion
layer must consist of at least 68 of earthen
material that is capable of sustaining
native plant growth.
EPA Technical Guidance To Be 2; 3; 4; 5; SA; Pl'esmts EPA recommendations on design 8 To be considered in designing a cap
Document: Pinal Covers on Considered 88 specifications for multilayer landfill caps. for IWS Areas.
Hazardous Waste Landfills and
Surface Impoundments
. ,
FederaJ Noise Control Applicable 2; 3; 4; S; 8A; Establish noise emission standards 8 Construction equipment will com,lly
Regulations (40 CPR 204,205) 88 applicable to portable air compressors 'and with applicable noise emission
medium and heavy duty trucks. standards.
File :parker/ara ro/acl-.p. r.
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T Aa.......B 4-6
,AcnON-SPECIFlC ARARs: CRITERIA,'ADVISORlES, AND GUlDANCE
Parker Landfill Feasibility Study ,
Lyndonville, Vermont
'.s
Revision: 0
Dale: 1I181'1~
Medium . Requ.irementa, Status Altemativ- '. Synopsis of Requirement Action to be taken to attain ARAR I
Air Federal Proposed Regulation for To Be 2; 3; 4; S; 8A; Proposes emission standards for VOCs 8 To be considered in predesign ~tudies.
Control of VOCs Considered 88 from groundwater treatment units such as
air strippers.
Surface Federal Quality Criteria for Applicable 3; S; 88 Pursuant to Section 304(a)(I) of the Clean 8 These criteria will be considered in
Waters Water Water Act, the EPA establishes ambient predesign.
water quality criteria. These criteria
present scientific data and guidance on the
environmental effects of pollutants. The
criteria can contribute to establishing
regulatory requirements that govern
impacts to water quality.
I.;
~. !
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TABl.H 4-7 . '
LOCA 110N-SPECIFIC ARARs: CRITERIA, ADVISORIES, AND GUIDANCE
Parker Landfill Feasibility Study
Lyndonville, Vermont
FS
Revi.ion: 0
Oa'e: 11181'>4
Medium Requiromoatt Stttua Altemadvu . Synoptl. of Requirement Action to be taken to attain ARAR
STATE REGULATORY REQUIREMBNTS
. I' I: 2: 3: 4: S; Sa: Hazardous waste disposal facilities are not to 8 IWS Areas are not locakd in a
Floodplains Vermont Hazardous Waite Relevant and
and Seismic Regulations (EPR 7-5(2) Appropriate Sb be located in seismically active areas nor in seismically active area or in a
Zones loo-year floodplains (unless washout can be tOO-year floodplain.
prevented or no adverse effects of washout
can be substantiated).
Groundwaler, Vermont Solid Wasle Relevant and I: 2: 3; 4: 5; Sa: Solid waste disposal facilities are not to be 8 The SWDA is nol located in the
Wetlands, and Regulations (EPR 6-502, 503) Appropriate Sb located in Class I or Class II groundwater sensitive areas oullined.
Floodplains areas, significant wetlands, or a loo-year
floodplain/flood stage elevation. Solid waste
, facilities are to be located so as nol to
adversely affect drinking water supplies.
Wetlands Vermont Wetland Rules Applicable 2: 3; 4; S; Sa; Sb These regulations include procedures for the 8 Protection of significant wetlands
identification, classification, and protection was considered in development of
of wetlands. remedial alternatives.
FEDERAL REGULATORY REQUIREMENTS
Wetlands Federal Guidelines for Relevant and 2; 3; 4; 5; Sa: Sb These guidelines cover potential impacts of 8 Wetland impacls and miligalion
Specification of Disposal Sites Appropriate depositing ,fill material in wetlands on human alternatives will be assessed
for Dredged or Pill Material (40 use characteristics and on aquatic ec08ystems during predesign sludies.
CFR 230) . including: physical and chemical
characteristics, biological characteristics, and
special aquatic sites. The regulations also
specify evaluation. and testing to make
determinations, and actions to minimim
adverse effects.
Federal, Filih and Wildlife ApplicabJe 2; 3; 4; 5; Sa; Sb Establishes requirements for. consultation 8 Agencies willlic consulled 10
Coordinalio~ Regulalions (SO with-U.S. Fiab and Wildlife Service and state assist in minimizing and/or
Ca:R 297) wildlife agencies to mitigate losses of fish mitigating impacts-
and wildlife that result from modification of
waters.
File :"arker/aran/lllc-.", f.
dtlwp
"al:e I III:!
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TAoa...E 4-7
LOCATION-SPECIFIC ARARs: CRITERIA, ADVISORIES, AND GUIDANCE
Parker Landfill Peasibility Study
Lyndonville, Vermont
1'5
Reviaion: 0
Dale: III 8/94
Medium Requirementa Status Alternativ~ Synopsis of ~uiremcot Action to be laken 10 atlain ARAR
Wetlands federal. Army Corps of Relevant and 2; 3; 4; S; 8a; 8b Lists conditions that must be met for the . Nationwide permit conditions will
(cont'd) Engineers Nationwido Permit Appropriate nationwide general permit to discharge be considered in predesign
Program Regulations (33 CPtl dredged or fill material. These conditions studies.
330, Appendix A) include consideration of maintenance, erosion
and siltation controls, aquatic life
movementa, equipment usage, endangered
species, and mitigation.
Ft:deral Executive Order 11990 Applicable 2; 3; 4; S; 8.; 8b Directs federal agencies to avoid, where . Wetland impacts will be
Protection of WetJands (40 CPR possible, adversely effecting or destroying minimized and/or mitigatt:d.
6, Appendix A) wetJands. Requirements for wetlands
determirlation, assessment, and preservation
or restoration are set forth.
Floodplains federal Executive Order 11988 Applicable 3; S; 8b Requires federal agencies to avoid, where To be considered in predesign
floodplain Management (40 possible, adversely effecting floodplains. studies.
CPR 6, Appendix A) Requirements for floodplains determination,
assessment; and preservation or restoration
are set forth.
I'ile :I,.rker/ar.nJloc'ap. f.
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APPENDIX C
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. State of Vermont.
Department 01 Fish and Wildlife
Department 01 ForeslS. Par1ls and Recreation
Department 01 Environmental Conservation
Slate Geologist
Natural ResoUrces Conservation Council'
RELAY SERVICE FOR THE HEARING IMPAIRED
1-800.253-<1191 TDD>Voice
1.800-253-0195 Voice> TDD
AGENCY OF NA11JRAL RESOURCES
Department or Environmental Conservation
Hazardous Materials Management Division
103 South Main Street/West Ofrlce
Waterbury, VermoDt 05(;71-0404
(802) 241-3888
FAX (802) 241-3296
March 23, 1995
lohn De Villars, Regional. Administrator
USEP A, New England Region
m Federal Building
. Boston, MA 02203
RE: Parker Landfill Superfund Site'in Lyndonville, Vermont
Dear Mr. DeVillars:
The Vermont Department of Environmental Conservation (VfDEC) has reviewed the various
remedial alternatives developed for the Parker 'Landfill site, and we support the selected remedy, .
which is: Containment (SWDA, IWS Areas 1,2, and 3)/ source control groundwater extraction,
treatment, discharge! institutional controls. The selected remedy is in compliance with. applicable or
relevant and appropriate State environmental laws and regulations. The State of Vermont concUrs with
. the selected remedy for the Parker Landfill Site.
The VTDEC is sensitive to the potential economic effects of this remedy to the local area~ .The
Record of Decision (ROD) provides the maximum flexibility to implement the most cost effective
measures during the design phase. ' In addition, the ROD states that much of the costs for the selected
remedy could be spent locally and that the use of local materials will be encouraged to the extent
practicable. The VTDEC will continue to work with EPA to fmplement cost-effective measures,
materials and technologies in the remedial design phase.
. Sincerely,
William Brierley, Acting C
Department of Environm
c: tShena ECkriiai~, US~ A" .)
1plsir.eaf770013/CODh.rocI
Chlorine Free 100% Recycled Paper
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