United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01 -88/033
September 1988
SEPA
Superfund
Record of Decision
Old Springfield Landfill, VT
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30277-101
REPORT DOCUMENTATION
PAGE
ir REPORT NO.
EPA/ROD/R01-88/033
3. Recipient's Accession No.
I 4. Title and Subtitle
SUPERFUND RECORD OF DECISION
,pld Springfield Landfill, VT
first Remedial Action
5. Report Date
09/22/88
7. Authors)
8. Performing Organization R«pt. No.
9. Ptrforming Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(0
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
I
S~ AT*hrect6'i3't's2prrn'g¥ield Landfill site is located approximately one mile .southwest of the
city center in Springfield, Windsor County, Vermont. The land use within a 1 mile
radius of, the 27-acre site is primarily low density residential housing, light
agriculture, undeveloped forest land, and commercial development. The landfill was
operated by the Town of Springfield between 1947 and 1968 for the disposal of municipal
solid waste and hazardous industrial liquid and semi-liquid waste. The site is
Currently owned by Springfield Mobile Home Estates, which operates a trailer park
Currently consisting of 38 mobile homes. Approximately 60 people reside in the
Springfield Mobile Estates trailer park, built on top of the landfill. The site first
came to the attention of the Vermont Department of Health because of a complaint by a
nearby resident of foul-smelling water. Investigation of the site found VOC
contamination in a spring and in a residential well near the mobile home park. EPA
began investigations at the site in 1976. Four areas of contamination have been
identified at the site where industrial waste was either disposed of in discrete
trenches or mixed with the municipal waste. This remedial action addresses landfill
seepage and ground water contamination. The remedial action is designed for management
of contaminant migration and study of final remediation alternatives. The primary
(See Attached Sheet)
or«
Old Springfield Landfill, VT
First Remedial Action
Contaminated Media: gw, sw, soil, sediments
Key Contaminants: organics (PAHs, PCBs), VOCs (benzene, PCE, TCE, toluene)
b. Identlfiers/Open-Ended Terms
c. COSATI Reid/Group
'Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
212
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 <»-77>
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R01-88/033
kd Springfield Landfill, VT
rst Remedial Action
16. ABSTRACT (continued)
contaminants of concern affecting the ground water, surface water, soil, and sedio.ients
are VOCs including benzene, PCE, TCE, toluene, and other organics including PCBs and
PAHs.
The selected remedial action for this site includes: construction of an underground
collection system to collect leachate; installation of wells for extraction of
contaminated ground water; onsite treatment of the collected leachate and extracted
ground water, or discharge to the Publicly Owned Treatment Works (POTW) for treatment;
institutional controls to restrict the use of ground water that exceeds MCLs; multimedia
monitoring; and conducting additional studies to determine the feasibility of isolating
waste r. tterials from the ground water (e.g., french drain, slurry wall, or waste
removal). The estimated present worth cost for this remedial action is $5,374,000 with
annual O&M costs of $173,000.
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Record of Decision
Old Springfield Landfill
Springfield, Vermont
STATEMENT OP PURPOSE
This Decision Document represents the selected remedial action for
an operable unit for remediation of groundvater emanating from the
seeps and known areas of groundvater contamination at the Old
Springfield site developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the extent practicable,
the National Contingency Plan (NCF) 40 CFR Part 300 et seq., as
amended. The Region I Administrator has been delegated the
authority to approve this Record of Decision.
The State of Vermont has concurred on the selected remedy for the
operable unit for seeps and limited groundvater and has
determined, through a detailed evaluation, that the selected
remedy is consistent with its lavs and regulations.
STATEMENT OF BASIS
This decision is based on the administrative record vhich was
developed in accordance vith Section 113(k) of CERCLA and vhich is
available for public reviev at the Springfield Town Library in
Springfield, Vermont, and the EPA Region I Waste Management
Division Record Center in Boston, Massachusetts. The attached .
index identifies the items vhich comprise the administrative
record upon vhich the selection of a remedial action is based.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for the Old Springfield Landfill site is a
management of migration operable unit for seeps and, to a limited
extent, groundvater.
1. Leachate Collection/Groundvater Extraction System
•
The method for collection of leachate vill be an underground
system vhich collects the groundwater at or upgradient of the
points of seep-emanation. The collection system vill collect all
ten of the detected seeps on the eastern slope and all four of the
detected seeps on the western slope vith provisions to collect any
other seep should it develop. \
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In addition to leachate collection, groundvater will be extracted
from the sand and gravel zone on the western portion of the site.
The collected groundvater and leachate would be conveyed to a
wastewater treatment facility.
Detailed criteria will be developed during remedial design to
determine the best design and construction techniques for the
leachate collection system and the best placement and number of
extraction wells.
Underground leachate collection and groundwater extraction are the
most effective means of capturing contaminated groundwater after it
has migrated away from the source area. The system will allow for
the addition of other seeps should there be additional breakouts
during the duration of the remedy. Underground collection of
leachate will eliminate the pathway for contaminants to volatilize
at the seeps by collecting the seeps underground before contact
with the air. Leachate collection will also reduce the potential
for contaminants to travel into the Black River and Seavers Brook
via surface drainage, thus reducing possible contamination of fish
in those rivers. A non-continuous underground leachate collection
system may be appropriate if it can be demonstrated during design
to fulfill the following system objectives:
- collect groundwater on the eastern and western slopes
which emanates from the landfill as leachate seeps in
order to eliminate the contamination and potential
contamination in uncontaminated seeps, migrating to
Seavers Brook and the Black River and into the bedrock
aquifer;
extract groundwater on the western side of the site in
the permeable sand and gravel unit;
eliminate the volatilization and direct contact risk
associated with the leachate seeps; and
have collection and extraction systems in place which
could be extended should new locations of contaminated
leachate or practically extractable and contaminated
groundwater be located.
2. Treatment of Groundwater and Leachate
The treatment system for the collected leachate and extracted
groundwater will treat the collected leachate and extracted
groundwater to meet all federal and state requirements.
Treatment will be on-site. However, should the Publicly Owned
Treatment Works (POTW) have the ability, capacity, and willingness
to treat the extracted groundwater and leachate and meet all
federal and state requirements, the collected leachate and
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extracted groundwater will be piped to the POTW and treated. If
the collected groundvater and leachate is directed to the POTW, it
will be pretreated if pretreatment is necessary to meet applicable
standards, attain surface water quality goals and maintain
effective POTW operations. If a demonstration of ability, capacity
and willingness is not made, the treatment system will remain
onsite.
The Town of Springfield has demonstrated the willingness and
capacity to treat the collected leachate and extracted groundvater
at the POTW, and has had a review of the system to evaluate if the
system has the ability to handle the wastes. This initial
evaluation indicates that the POTW may have the ability to treat
the wastes. Samples of the collected leachate and extracted
groundwater will be bench scale tested during design to ensure
effectiveness.
3. Institutional Controls
The selected remedy includes restricting the use of groundwater
where it may exceed Maximum Contaminant Levels (MCLs). EPA
recommends to the State and Town of Springfield that they
implement and enforce ordinance 88-2 passed by the Town of
Springfield as an institutional control. Specifically, EPA
recommends a prohibition on groundwater use in the area bounded by
Route 11 on the east, Mr. Curtin's present property boundary on the
south, Seavers Brook Road on the west and Mr. Curtin's present
property boundary on the north until a time when groundwater levels
reach MCLs. The ordinance is attached as Exhibit 1.
4. Monitoring
Monitoring of environmental media will be conducted for thirty
(30) years to monitor effectiveness of the remedy and to identify
any further impacts to human health and the environment.
Additionally, as required by CERCLA at sites where any hazardous
substances, pollutants or contaminants remain, a review of the
site will occur every five (5) years.
5. Additional Studies
Additional studies will be conducted to determine the feasibility
of isolating waste materials from groundwater through diverting
groundwater flow around waste materials, creating physical
barrier* to separate waste materials from groundwater, landfilling
of waste materials in a Hazardous and Solid Waste Amendments (HSWA)
landfill, or other appropriate technologies. The additional
studies will include but not be limited to:
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1) and evaluation of the feasibility, effectiveness, and cost of
isolating wastes from groundwater, including a detailed
evaluation of:
a. an upgradient, permeable vertical groundvater diversion
structure similar in function to a french drain;
b. physical barriers, such as a slurry vail, that separate
waste material from groundwater and/or depress the water
table to minimize contact between waste and groundwater;
c. a deans of lowering the water table in areas of waste
disposal to eliminate or minimize contact between waste
and groundwater;
d. removing the waste, including that waste in contact with
groundwater, for disposal in a HSWA landfill;
e. removing the waste, including that waste in contact with
groundwater, for treatment by incineration or
vitrification;
f. other means of isolating waste materials from
groundwater; and
g. combinations of the above.
2) a quantitative determination of the amount of infiltration
and flow contacting buried waste from vertical infiltration
and lateral groundwater flow. For each of the evaluations
conducted in 1) above, quantitatively compare the amounts of
infiltration and groundwater flow contacting waste through
vertical infiltration and lateral groundwater flow before and
after remedy implementation; and
3) an identification and characterization of outlying areas of
potential contamination which may have escaped detection in
earlier investigatory work including the western slope area
between Seavers Brook Road and Hill Dean Road and an area on
the southwestern portion of the site near Will Dean Road, as
indicated by the magnetic anomaly in Figure 3-3 of the
Supplemental Remedial Investigation, to determine if there
are additional source of contamination. It additional
contamination is found, it will be remediated as part of the
source control operable unit, or taken offsite for disposal
in accordance with EPA's offsite policy.
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DECLARATION
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate, and is cost-effective.
This remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable for this operable
unit. Treatment of leachate and contaminated groundwater will
occur at the POTW or onsite and will be the maximum extent to which
treatment is practicable.
z 2.
Date Michael R. Del and
Regional Administrator
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OLD SPRINGFIELD LANDFILL RECORD OF DECISION
TABLE OF CONTENTS
Contents Page
I. SITE NAME 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 3
A. Response History 3
B. Enforcement History 4
C. Community Relations 4
IV. SCOPE AND ROLE OF RESPONSE ACTION 5
V. SITE CHARACTERISTICS fc 6
A. Hydrogeology/Groundwater 6
B. Soil 8
VI. SUMMARY OF SITE RISKS 8
VII. DOCUMENTATION OF SIGNIFICANT CHANGES .... 11
VI11. DEVELOPMENT AND SCREENING OF ALTERNATIVES 12
A. Statutory Requirements/Response Objectives 12
B. Technology and Alternative Development and
Screening 14
IX. DESCRIPTION /SUMMARY OF THE DETAILED AND COMPARATIVE
ANALYSIS OF ALTERNATIVES 15
X. THE SELECTED REMEDY 17
A. Description of the Selected Remedy 17
B. Estimated Remedial Schedule ' 22
C. Rationale for Selection/Points of Compliance .... 22
XI. STATUTORY DETERMINATIONS 26
A. The Selected Remedy is Protective of Human Health
and the Environment 26
B. The Selected Remedy Attains ARARs 26
C. The Selected Remedial Action is Cost Effective ... 27
D. The Selected Remedy Utilizes Permanent Solutions
and Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent
Practicable 28
E- The Selected Remedy Satisfies the Preference for
Treatment as a Principal Element ......_.... 28
XII. STATE ROLE 28
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Old Springfield Landfill Site
Record of Decision Summary
LIST OP FIGURES
Figure be
Figure 1. Site Location ................... 2
Figure 2. Monitoring Nell Locations ............. 7
Figure 3. Waste Areas ...... ..... ...... ... 9
EXHIBIT
Town of Springfield Ordinance 88-2 ......... Exhibit 1
Letter from Town of Springfield - POTW Use ...... Exhibit 2
APPENDICES
Responsiveness Summary ............... Appendix A
Administrative Record Index ............. Appendix B
State Concurrence Letter ............... Appendix C
ATTACHMENT
Monitoring Well/Leachate Seep Data ......... Attachment 1
Soil Data ..................... Attachment 2
Contaminants of Concern .............. Attachment 3
Management of Migration .............. Attachment 4
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ROD DECISION SUMMARY page 1
Old Springfield Landfill
I. SITE NAME: Old Springfield Landfill
LOCATION: Springfield, Vernont
DESCRIPTION
The 27-acre Old Springfield Landfill site, is located
approximately one mile south-west of the city center in
Springfield, Windsor County, Vermont (See Figure 1). The site is
situated on an upland terrace with slopes that descend steeply to
the north, east, and vest. Seavers Brook runs vest of the site
and the Black River runs east of the site. Seavers Brook flows
northward until it reaches the Black River, which flows to the
south and empties into the Connecticut River.
The Town of Springfield has a population of 10,180, according to
the 1980 National Census. The villages of Goulds Mill and
Hardscrabble Corner are located within a one-mile radius of the
site. Approximately 60 people resided in the Springfield Mobile
Estates trailer park located atop the site. A number of these
individuals are believed to have sold their trailers during the
summer of 1988; however, a limited number of resident remain in
the trailer park. A condominium complex (Bluegrass Hills) vas
constructed adjacent to the site to the north. The condominium
complex has 44 single-family units in six buildings with
approximately 100 residents.
Approximately 15 homes are located within a one-half mile of the
site, along with a few other commercial establishments. Three
homes are on the terrace adjacent to the mobile home park.
Approximately 200 homes and condominiums are located within a one-
mile radius of the site, housing an estimated population of
between 650 and 750 people.
The land use within a one-mile radius of the site is primarily low
density residential housing, light agriculture, undeveloped forest
land and commercial.
Natural resources in the vicinity of the site include groundvater,
surface water, fish and game, arable land, forest, woodland, and
minerals.
Users of. the bedrock aquifer groundwater in the site vicinity are
located primarily upgradient of the site. Two groundwater users
have been identified downgradient of the site. Presently their
water supply remains unaffected by the site. The remaining
residents receive Springfield municipal town water.
A more complete description of the site can be found in Section
1.1 of the Feasibility study Report.
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ROD DECISION SUMMARY
Old Springfitld Landfill
pag« 2
rigur« 1. Bit* Location
ISEAVERS BROOK
ROAD
HARDWARE/LUMBER STORE
A
PLUMBING SUPPLY STORE
BLACK RIVER
GRASS HILLS
ROUTE II
SPRINGFIELD
•* MOBILE ESTATES
ITUOT UU IKINCI
WILL DEAN ROAD
e too
«uu « nrr
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ROD DECISION SUMMARY page 3
Old Springfield Landfill
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Response History
The Old Springfield Landfill, also referred to as the Will Dean
Dump, was operated by the Town of Springfield between 1947 and
1968. Hazardous industrial waste from local industries was co-
disposed with municipal trash. Also, some of the industrial waste
was disposed of in discrete trenches in addition to being mixed
with municipal solid waste. Most hazardous material was disposed
of in bulk liquid and semi-liquid form. Shortly after the site was
closed in 1968 it was sold. The former landfill was developed for
use as a mobile home park. At the time of the park's development,
the Vermont Department of Health (DOH) recommended that drilled
wells not be used to supply water to the park because the
development was located over areas that had been used for chemical
disposal. Municipal water lines were extended to serve the mobile
homes. Springfield Mobile Home Estates trailer park currently
consists of 38 mobile homes. A six-building condominium complex
and 13 single family residences are located near the site of the
Old Springfield Landfill.
Shortly after the opening of the Springfield Mobile Estates
trailer park, a nearby resident's complaint about foul-smelling
water prompted an investigation of the site by the Vermont DOH and
the Vermont Agency of Environmental Conservation (VTDEC). In
response to finding volatile organic compound contamination in a
spring and the in residential well near the mobile home park, the
spring was abandoned and an affected home near the mobile home -
park was connected to the public water supply.
EPA entered into the investigation of the Old Springfield Landfill
site in 1976 to review VTDEC data on residential wells on the site.
In late 1982, after the VTDEC requested that the site be reviewed
for inclusion in the Superfund Program, the site was added to the
National Priorities List of hazardous waste sites eligible to
receive federal funding for study and cleanup. The results of
EPA's initial Remedial Investigation (RI), released in September
1985, showed contamination in site soils, seeps, and ground-water.
EPA determined that a supplemental RI was necessary to delineate
the former waste disposal areas, and to better define the nature,
extent, and potential adverse human health effects of site
contamination.
Supplemental RI activities included taking samples from soil,
leachate seeps, residential wells, groundwater, and sediment at
the site. These activities included a soil boring program in the
trailer park area. Because of the potential for mobile home park
residents to be exposed to contaminants during this soil boring
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ROD DECISION SUMMARY page 4
Old Springfield Landfill
program, EPA temporarily relocated mobile home park residents
between July 6 and July 18, 1987. EPA completed Phase I field
investigations in October 1987, and Phase II in May 1988, and
released the final RI report in June 1988. EPA has conducted the
Phase II investigation simultaneously with the Feasibility Study,
released in June 1988, to identify and evaluate cleanup
alternatives for the site.
A more detailed description of the site history can be found in
the Remedial Investigation, Supplemental Remedial Investigation
Report section 1.2, and the Feasibility Study report at section
1.1.
B. Enforcement History
On January 6, 1984, April 17, 1987, and May 14, 1987, EPA notified
nine parties who either owned or operated the facility, generated
wastes that were disposed of at the site, arranged for the disposal
of wastes at the facility, or transported wastes to the facility,
of their potential liability with respect to the site.
In January 1984, EPA had discussions with Emhart Corporation,
Textron Incorporated, the Town of Springfield and other
Potentially Responsible Parties (PRPs) about installing a water
line to two private homes and conducting the Remedial
Investigation and Feasibility Study. Emhart Corporation, Textron
Corporation and the Town of Springfield came to an agreement on the
installation of the water line only. EPA then used Trust Fund
monies to conduct the Remedial Investigation and Feasibility Study.
EPA met with a committee of potentially responsible parties
several times between June 26, 1987 and September 19, 1987 to keep
them apprised of findings at the site. EPA also met with a
committee of potentially responsible parties on June 29, 1988 to
present the results of the Feasibility Study and the Proposed Plan
and on a number of occasions in July and August of 1988. On
August 24, 1988 the PRPs submitted written comments on EPA*s
proposed plan. The comments have been included in the
administrative record.
*
C. Community Relations
Through the site's history, community concern and involvement has
been high. EPA has kept the community and other interested
parties apprised of the site activities through informational
meetings, fact sheets, press releases and public meetings.
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ROD DECISION SUMMARY page 5
Old Springfield Landfill
In February 1985, EPA released a community relations plan which
outlined a program to address community concerns and keep citizens
informed about and involved in activities during remedial
activities. In September 1985, EPA held an informational meeting
in the town to describe the plans for Remedial Investigation and
Feasibility Study.
On September 15, 1985 EPA held an informational meeting to
describe the results of the Remedial Investigation.
On October 16, 1986, EPA held an informational meeting to discuss
the Supplemental Remedial Investigation and Feasibility Study work
plan.
Between July 6, and July 18, 1987, EPA held several meetings with
residents of Springfield Mobile Estates to inform them of site
conditions during the temporary relocation.
On March 29, 1988, EPA held a public meeting to discuss the
results of the Supplemental Remedial Investigation and
Endangerment Assessment.
On July 7, 1988, EPA held an informational public meeting to
discuss the cleanup alternatives presented in the Feasibility
Study and to present the Agency's Proposed Plan. The Agency also
answered questions from the public during this meeting. From July
8 to August 24, the Agency held a seven week public comment period
to accept comment on the alternatives presented in the Feasibility
Study, the Proposed Plan, and all other documents previously
released to the public. During that comment period, on July 21,
1988, the Agency held a public hearing to accept oral comments. A
transcript of this meeting as well as written comments received,
and the Agency's response to these comments are included in the
attached responsiveness summary and are part of the Administrative
Record. After the Record of Decision (ROD) is signed, EPA will
publish notice of its decision in the local paper.
IV. SCOPE AND ROLE OF RESPONSE ACTION
The selected remedy addresses management of migration (or
groundwater) technologies to obtain an operable unit for
remediation of water emanating from the seeps and present in known
areas of groundwater contamination. The remedy provides for the
following components: leachate collection and extraction of
groundwater; treatment of leachate and extracted groundwater;
institutional controls; long-term monitoring; and additional
studies. This remedy does not address the source of groundwater
or air contamination. After additional studies, remedial actions
designed to control the contamination source will be evaluated.
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ROD DECISION SUMMARY page 6
Old Springfield Landfill
V. SITE CHARACTERISTICS
A complete discussion of the site characteristics can be found in
the Remedial Investigation and Supplemental Remedial Investigation
Reports.
Chapter One of the Feasibility Study contains an overview of the
Remedial Investigation. The significant findings of the Remedial
Investigation are summarized below.
A. Hydrogeology/Groundwater
Hydrogeologic investigations were conducted at the site to
characterize groundwater flow, contaminant transport and discharge
to* the seeps. A total of 36 monitoring wells (Figure 2) were
installed in six geologic formations. Monitoring well water levels
indicate that the hydrogeologic system is a sequence of unsaturated
sands overlying low permeability, saturated glacial till which in
turn is underlain by high permeability sands and gravel and
fractured bedrock. The water-table surface is near the top of the
glacial till over most of the site. Because of its low hydraulic
conductivity, drainage from the till is slow, and the till is
saturated over much of its thickness in most areas of the site. A
localized, seasonally perched water table was observed in the
western central part of the site. Beneath the till is the sand and
gravel deposit which has a hydraulic conductivity nearly two orders
of magnitude greater than the glacial till. The buried sand and
gravel stream bed deposit acts as a drain, causing flow in the
overlying glacial till to converge towards it.
Horizontal groundwater flow approaches the site from the south,
but divergent flows to the east toward Black River and to the west
toward Seavers Brook were observed in the immediate site vicinity.
The most recent investigation determined that the site is a major
recharge area and that there is a large downward component of
groundwater flow.
The leachate seeps and springs on the outslopes of the site are
major groundwater discharge zones. The major groundwater
contamination at the site consists primarily of trichloroethene
(TCE), tetrachloroethene (PCE), 1,1,1-trichloroethane (TCA),
trans-l*2-dichloroethene, vinyl chloride, toluene, and total
xylenes. The most concentrated of groundwater seep contamination
was detected in two leachate seeps which flow from the face of the
buried ravines^in the eastern portion of the site near Waste
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ROD DECISION SUMMARY
Old Springfiald Landfill
pag« 7
Figur« 2. Monitoring Well Location*
••300
LMCKO
MOMTOIIIIM WCLL
•200
•20
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t * ^»
s&^
£fe
s//A-^-^
- ^-. ^
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^vrVx-.'-.rv-o
• **-^ V "'-. ^ •» -
s.. . .\».. . x.T1:^. r.
•OUUCI
MM
•00
100
SCALE Ht rift
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ROD DECISION SUMMARY page 8
Old Springfield Landfill
Area 3. Groundvater contamination is found in greatest
concentrations beneath the southeastern portion of the landfill in
the southeast corner of the site. Attachment 1 shows the
groundwater monitoring data.
B. Soil
The Remedial Investigation and Supplemental Remedial Investigation
Reports identify four major waste disposal areas. (See Figure 3)
Waste Area One is the smallest and is located in northern portion
of the site. Waste Areas 2 and 3 are on the eastern edge of the
site. These two waste areas are former ravines that were filled
during landfill operation. Waste area 4 is located at the southern
end of the site and was the last active part of the landfill.'
Soil samples in the Waste Areas show high levels of organic
contaminants. Forty-five different contaminants were found in the
site soils. They fall into four major groups of contaminant
types. Polycyclic Aromatic Hydrocarbons (PAHs); Polychlorinated
Biphenyls (PCBs); Chlorinated Aliphatic Hydrocarbons (CAHs) and
Monocyclic Aromatic Hydrocarbons (MAH). Attachment 2 illustrates
the contaminants, frequency of detection, and minimum and maximum
values in soils.
A more complete discussion of the site characteristics can be
found in the Supplemental Remedial Investigation Report.
VI. SUMMARY OF SITE RISKS
An Endangerment Assessment (EA) was performed to evaluate the
potential adverse human health and environmental effects and
estimate the probability and magnitude of potential adverse human
health and environmental effects from exposure to contaminants
associated with the site. Attachment 3 lists the contaminants of
concern that were selected for evaluation in the EA.
These contaminants constitute a representative subset of the more
than seventy-five contaminants identified at the site during the
Remedial Investigation. The contaminants were selected to
represent potential onsite and offsite hazards based on toxicity,
level of contamination, mobility, and persistence in the
environment.
Potential human health effects associated with the contaminants of
concern in subsurface soils groundwater, sediments and air were
estimated quantitatively through the development of several
hypothetical exposure scenarios. Incremental lifetime cancer
risks and a measure of the potential for non-carcinogenic adverse
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ROD DECISION 8UKKARY
Old Springfield Landfill
Figure 3. Wast* Areas
mr
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ROD DECISION SUMMARY page 10
Old Springfield Landfill
health effects vere estimated for the various exposure scenarios.
Exposure scenarios vere developed to reflect the potential for
exposure to hazardous substances based on the characteristic uses
and location of the site.
a. Direct Contact with Soils
Hunan health risks vere calculated for an adult, assuming contact
vith surface soils once or tvice per veek via gardening or other
activities. The excess lifetime cancer risks range from 3 x 1Q~7
under site-vide average contaminant concentrations and 2 x 10~5 in
the site-vide maximum concentrations. Most of the risk is
attributable to PCBs and PAHs. Hazard indices are less than one
under both cases.
For children (one to six years old) assuming play in the soil for
six months of the year tvo time per veek under the average case
and 4 times per veek under the maximum case, the excess lifetime
on-site incremental cancer risk ranged from 1 x 10~7 under site-
vide average contaminant concentrations and 2 x 10"5 under site-
vide maximum concentrations. These estimates include both direct
contact and soil ingestion and the risks are mainly attributable
to PCBs and PAHs. Hazard indices are less than one under both
cases.
b. Groundvater
Groundvater on site is not currently used for drinking vater;
however, according to the EPA Groundvater Protection Strategy the
aquifer underlying the site is classified as a Class IIB aquifer
(i.e. having a potential for future use). Therefore the lifetime
cancer risk and the non-carcinogenic health risks associated vith
the ingestion of on-site groundvater vere assessed. The excess
lifetime cancer risks range from 1 x 10~3 under site-vide average
contaminant concentrations and 7 x 10"2 under site-vide maximum
concentrations. The chemicals contributing most to the risk are
vinyl chloride, 1,1-dichloroethene and PCBs.
The future lifetime excess cancer risks for groundvater in the
western area of the site vere calculated to be 6 x 10"4 under
average contaminant concentrations and 7 x 10~* under maximum
contaminant concentrations found on the vestern slope. Vinyl
chloride and 1,1-dichloroethene contribute most to the risk.
c. Air
Risks due to inhalation exposure to landfill gas contamination and
the volatilization of contaminants from leachate seeps vere
modeled. The landfill gas exposure route indicates an excess
lifetime cancer risk of 9 x 10~5 under site-vide average
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ROD DECISION SUMMARY page 11
Old Springfield Landfill
contaminant concentrations and 5 x 10""3 under site-vide maximum
contaminant concentrations. Chemicals contributing most to the
risk are benzene, chloroform and trichloroethene. Using the
assumption that the concentrations of contaminants in the air at
the nearest off-site residence are the same as on-site, the
average and maximum excess lifetime cancer risks are the same off-
site as on-site.
Exposure risks from volatilized contaminants from leachate seeps
indicate a lifetime excess cancer risk of 1 x 10~4 under site-
wide average contaminant concentrations and 1 x 10~3 under maximum
contaminant concentrations. Chemicals contributing most to the
risk are vinyl chloride, 1,1-dichloroethene and
1,1-dichloroethane.
d. * Surface Water
Excess lifetime cancer risks associated with current consumption
of fish from the Black River based on concentrations estimated
from the mass balance model are 3 x 10-8 and 2 x 10-6 for the
average and plausible maximum cases, respectively, with nearly all
of the risk attributable to PCBs.
A complete discussion of risks can be found in Section 1.4 of the
Feasibility Study and the Endangerment Assessment.
VII. DOCUMENTATION OF SIGNIFICANT CHANGES
EPA published a proposed plan (preferred alternative) for
remediation of the site on July 7, 1988. The remedy published in
the proposed plan provides for source control by combining the
following components: capping according to RCRA regulations and
performance standards set for in RCRA guidance; leachate
collection and extraction of groundwater; treatment of leachate
and extracted groundwater at a treatment facility; institutional
controls; long-term monitoring; and relocation of residents.
During the public comment period several commenters, including the
State of Vermont, indicated that EPA's proposed plan for source
control did not adequately address lateral groundwater flow through
buried waste, or the potential for bedrock groundwater
contamination. On August 26, 1988 EPA received a letter from the
State of Vermont conveying its concern with the adequacy of the
proposed cap to protect groundwater. In subsequent discussions
between EPA and the State, the governments agreed that further
studies would be appropriate before selecting a final remedial
action; however they also agreed that the seep collection and
groundwater extraction and treatment portion of the remedy was
adequate for the specific limited exposure routes concerned and
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ROD DECISION SUMMARY page 12
Old Springfield Landfill
should be selected as an operable unit. As the relocation was
based on the need to move residents while constructing the cap, no
decision is being Bade with respect to relocation options in this
Record of Decision.
In the nanagement of migration portion of the proposed plan, EPA
stated that the extracted groundwater and leachate would be
treated at a facility to be constructed onsite. During the public
comment period, EPA received information that the Town of
Springfield has the willingness and capacity to treat the
extracted groundwater and leachate at their Publicly Owned
Treatment Works (POTW) located about one-half mile from the site.
It has not been determined however, whether the POTW has the
ability, either with or without pretreatment, to treat the wastes.
This determination will be made during the remedial design. Since
it may be more easily implementable, cost-effective, and have
greater community acceptance, use of the POTW is included in the
remedy with a provision for on-site treatment if acceptable
treatment at the POTW cannot be demonstrated and ensured.
In the proposed plan, EPA specified leachate collection designs.
With respect to the leachate collection portion of this remedy,
EPA has modified the remedy to allow for alternate designs as long
as the alternate design meet the objectives and performance
standards outlined. This modification was made to accommodate the
potential constructability difficulties that may be encountered due
to the steep slopes surrounding the landfill.
VIII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. Statutory Requirements/Response Objectives
Prior to the passage of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), actions taken in response to
releases of hazardous substances were conducted in accordance with
CERCLA as enacted in 1980, and the revised National Oil and
Hazardous Substance Pollution Contingency Plan (NCP),
40 CFR Part 300, dated November 20, 1985. Until the NCP is
revised to reflect SARA, the procedures and standards for
responding to releases of hazardous substances, pollutants and
contaminants shall be in accordance with Section 121 of CERCLA and
to the maximum extent practicable, the current NCP.
•
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
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ROD DECISION SUM1W page 13
Old Springfield Landfill
remedial action, when complete, comply with applicable or relevant
and appropriate environmental standards established under federal
and state environmental lavs unless a statutory waiver is granted;
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 statutory preference for remedies
that permanently and significantly reduce the volume, toxicity or
mobility of hazardous wastes over remedies that do not achieve such
results through treatment. Response alternatives were developed to
be consistent with these Congressional mandates.
A number of potential exposure pathways were analyzed for risk and
threats to public health and the environment in the Endangerment
Assessment. Guidelines in the Superfund Public Health Evaluation
Manual (EPA,1986) regarding development of design goals and risk
analyses for remedial alternatives were used to assist EPA in the
development of response actions. As a result of these assessments,
remedial response objectives were developed to mitigate existing
and future threats to public health and the environment. These
response objectives are to:
1. Prevent direct contact (incidental ingestion and dermal
absorption) with contaminated surface soils throughout the
site by residents and by construction workers;
2. Prevent the volatilization of contaminants from contaminated
soils, wastes, and leachate seeps;
3. Prevent the contamination of fish in the Black River by
preventing leaching of contaminants from site soils to
shallow groundwater to the bedrock aquifer with subsequent
discharge to Seavers Brook and into the Black River; and
4. Prevent the leaching of contaminants from site soils to
shallow groundwater with subsequent transportation from the
shallow groundwater to the potable bedrock aquifer.
As discussed above, subsequent to the publication of the proposed
plan, the scope to this Record of Decision was limited to an
operable unit for seep collection and treatment and limited
groundwater extraction and treatment. Therefore, the remedial
objectives addressed by this ROD include only the those associated
with the groundwater emanating from leachate seeps; these include
objectives 1, and to a limited extent 2, 3, and 4.
B. Technology and Alternative Development and Screening
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ROD DECISION SUMMARY page 14
Old Springfield Landfill
CERCIA, the NCP, and EPA guidance documents, including "Guidance
on Feasibility Studies Under CERCIA" dated June 1985, and the
"Interim Guidance on Superfund Selection of Remedy1[EPA Office of
Solid Waste and Emergency Response (OSWER), Directive No. 9355.0-
19 (December 24, 1986) set forth the process by which remedial
actions are evaluated and selected. In accordance with these
requirements and guidance documents, treatment alternatives were
developed for the site ranging from an alternative that, to the
degree possible, would eliminate the need for long-term management
(including monitoring) at the site, to alternatives involving
treatment that would reduce the mobility, toxicity, or volume of
hazardous substance as their principal element. In addition to the
range of treatment alternatives, a containment option involving
little or no treatment and a no-action alternative were developed
in accordance with Section 121 of CERCLA.
Section 121(b)(l) of CERCLA presents several factors that at a
minimum EPA is required to consider in its assessment of
alternatives. In addition to these factors and the other
statutory directives of Section 121, the evaluation and selection
process was guided by EPA document "Additional Interim Guidance
for FY'87 Records of Decision " dated July 24, 1987. This
document provides direction for consideration of SARA cleanup
standards and sets forth nine criteria that EPA should consider in
its evaluation and selection of remedial actions. The nine
criteria are:
1. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs).
2. Long-term Effectiveness and Permanence.
3. Reduction of Toxicity, Mobility or Volume.
4. Short-term Effectiveness.
5. Implementability.
6. Community Acceptance.
7. State Acceptance.
8. Cost.
•
9. Overall Protection of Human Health and the Environment.
Chapter 4 of the Feasibility Study identified, assessed and
screened technologies based on implementability and effectiveness.
These technologies were combined into source control (SC),
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ROD DECISION SUMMARY page 15
Old Springfield Landfill
management of migration (MM) and Resident Relocation (RR)
alternatives. Chapter Five in the Feasibility Study presented the
remedial alternatives developed by combining the technologies
identified in the previous screening process in the categories
required by OSWER Directive No. 9355.0-19. The purpose of the
initial screening vas to narrow the number of potential remedial
actions for further detailed analysis while preserving a range of
options. Each alternative was then evaluated and screened in
Chapter 6 of the Feasibility Study on the basis of effectiveness,
implementability and cost. In summary, of the seven source
control, six management of migration, and three resident relocation
remedial alternatives screened in Chapter €, five source control,
two management of migration and three resident relocation options
were retained. As noted above, this ROD addresses only the
leachate seeps and to a limited extent, groundwater contamination;
source control and resident relocation alternatives will be
addressed in a subsequent ROD or RODs; therefore, Attachment 4
identifies only the management of migration alternatives that were
retained through the screening process as well as those that were
eliminated from further consideration.
IX. DESCRIPTION /SUMMARY OF THE DETAILED AND COMPARATIVE ANALYSIS
OF ALTERNATIVES
This section presents a narrative summary and brief evaluation of
each alternative according to the evaluation criteria described
above. A detailed tabular assessment of each alternative can be
found in Chapter 7 of the Feasibility Study at Tables 7-28 and
7-34.
Management of Migration (MM) Alternatives Analyzed
Management of Migration alternatives address, in part,
contaminants that have migrated from the original source of
contamination. At the Old Springfield Landfill site, some
contaminants have migrated from the source area into groundwater
and emanated as leachate seeps on the east and west side of the
landfill. The management of migration alternatives evaluated for
the site include a minimal no action with monitoring alternative
and a continuous leachate and groundwater extraction followed by
treatment alternative.
MM-1
Management of Migration Alternative 1
No Action with Monitoring Alternative
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ROD DECISION SUMMARY page 16
Old Springfield Landfill
Estimated Present Worth Cost: $1,628,000.
Annual Operation and Maintenance Cost: $86,000.
The law requires consideration of this alternative as a baseline
comparison to other management of migration alternatives
considered. No action for groundwater would consist of installing
fences around leachate seeps, eliminating the use of septic systems
for on-site residents and instituting a long-term sampling program
to assess the movement of contamination from the landfill.
This alternative does not provide adequate protection of human
health and the environment in either the long or short-term,
because contaminated leachate would continue to seep from the
eastern and western slope, volatilize and flow to surface water in
an uncontrolled manner. It does not reduce the toxicity, mobility
or volume of contaminants. This alternative does not meet any of
the remedial objectives relating to migration of contaminants such
as reducing direct contact with leachate, eliminating
volatilization of contaminants to the air from seeps, or
eliminating the migration of contaminants to the Black River and
bedrock aquifer. Also, this alternative does not meet ARARS.
MM-5
Management of Migration Alternative 5
Continuous Collection of Leachate Seeps with Groundwater
Extraction and On-site Treatment
Estimated Present Worth Cost: $5,374,000
Annual Operation and Maintenance Cost: $173,000.
This alternative would involve construction of an underground
collection system to collect all contaminated seeps from the
eastern and western slopes descending from the site; the
installation of wells on the western side of the site near Will
Dean Road to extract contaminated groundwater for treatment; and
the treatment of the collected leachate and extracted groundwater
onsite.
This alternative will be protective of human health and the
environment by eliminating the pathway for contaminants to
volatilize at the seeps by collecting the seeps underground before
contact with the air. It will also reduce the potential for
contaminants to travel into the Black River and Seavers Brook via
surface drainage, thus reducing the possible contamination of fish
in those rivers. It will reduce the mobility of contaminants by
collecting the seeps and treating them before they can discharge to
surface water or leach further into the groundwater. 'This
alternative will attain ARARs.
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ROD DECISION SUMMARY page 17
Old Springfield Landfill
X. THE SELECTED REMEDY
The selected remedy addresses management of migration technologies
to obtain an operable unit for remediation of groundwater emanating
from the seeps and known areas of groundwater contamination. The
remedy provides for the following components: leachate collection
and extraction of groundwater; treatment of leachate and extracted
groundwater; institutional controls; long-term monitoring; and
additional studies. This remedy does not address the source of
groundwater or air contamination.
A. Description of the Selected Remedy
The selected remedy consists of a five pronged remedial action
that includes: 1) leachate collection and groundwater extraction
(Management of Migration Alternative 5); 2) treatment of the
leachate and groundwater; 3) institutional controls; 4)
monitoring; and 5) additional studies.
1. Leachate Collection/Groundwater Extraction System
The method for collection of leachate will be an underground
system which collects the groundwater at or upgradient of the
points of seep emanation. The collection system will collect all
ten of the detected seeps on the eastern slope and all four of the
detected seeps on the western slope with provisions to collect any
other seep should it develop.
In addition to leachate collection, groundwater will be extracted
from the sand and gravel zone on the western portion of the site.
The collected groundwater and leachate would be conveyed to a waste
water treatment facility.
Detailed design criteria will be developed during remedial design
for best design and construction techniques for the leachate
collection system and the best placement and number of extraction
veils.
Underground leachate collection and groundwater extraction are the
most effective means of capturing contaminated groundwater after it
has migrated away from the source area. The system will allow for
the addition of other seeps should there be additional breakouts
during the duration of the remedy. Underground collection of
leachate will eliminate the pathway for contaminants to volatilize
at the seeps by collecting the seeps underground before contact
with the air. Leachate collection will also reduce the potential
for contaminants to travel into the Black River and Seavers Brook
via surface drainage, thus reducing possible contamination of fish
in those rivers. A non-continuous underground leachate collection
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ROD DECISION SUMMARY page 18
Old Springfield Landfill
system nay be appropriate if it can be demonstrated during design
to fulfill the following system objectives:
collect groundwater on the eastern and western slopes
which emanates from the landfill as leachate seeps in
order to eliminate the contamination and potential
contamination in uncontaminated seeps, migrating to
Seavers Brook and the Black River and into the bedrock
aquifer;
extract groundwater on the western side of the site in
the permeable sand and gravel unit;
eliminate the volatilization and direct contact risk
associated with the leachate seeps; and
have collection and extraction systems in place which
could be extended should new locations of contaminated
leachate or practically extractable and contaminated
groundwater be located.
The extracted groundwater and collected leachate would be treated
at the POTW or onsite as described below.
EPA cannot at this time predict when the leachate collection and
groundwater extraction system will fully accomplish its objectives
until additional field work and design and implementation of the
remedial action are accomplished. An estimate of the time that the
system will be in operation will be made after implementation of
the source control remedy. A monitoring program will be necessary
to determine whether the goals of the system have been achieved.
This data may also be used as the basis for modification of the
system or the time of its operation, or other appropriate action.
Should additional points or area of groundwater extraction or
leachate collection be identified in the future, the system will
be expanded to include collection and treatment of these waters if
such actions are determined by EPA to be practical and consistent
with the leachate collection and groundwater extraction system
stated above.
2. Treatment of Groundwater and Leachate
The treatment system for the collected leachate and extracted
groundwater will treat the collected leachate and extracted
groundwater to -meet all federal and state requirements.
Treatment will-be on-site. However, should the Publicly Owned
Treatment Works (POTW) have the ability, capacity, and willingness
to treat the extracted groundwater and leachate and meet all
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ROD DECISION SUMMARY page 19
Old Springfield Landfill
federal and state requirements, the collected leachate and -
extracted groundvater will be piped to the POTW and treated, if
the collected groundvater and leachate is directed to the POTW, it
will be pretreated if pretreatment is necessary to meet applicable
standards, attain surface water quality goals and maintain
effective POTW operations. If a demonstration of ability, capacity
and willingness is not made, the treatment system will remain
onsite.
The Town of Springfield has demonstrated the willingness and
capacity to treat the collected leachate and extracted groundvater
at the POTW, and has had a review of the system to evaluate if the
system has the ability to handle the wastes. This initial
evaluation indicates that the POTW may have the ability to treat
the wastes. Samples of the collected leachate and extracted
groundwater will be bench scale tested during design to ensure
effectiveness.
The objective of treatment is to treat the contaminants to levels
that would allow them to be discharged to surface water under the
Clean Water Act.
3. Institutional Controls
The selected remedy includes restricting the use of groundwater
where it may exceed Maximum Contaminant Levels (MCLs). EPA
recommends to the State and Town of Springfield that they
implement and enforce ordinance 88-2 passed by the Town of
Springfield as an institutional control. Specifically, EPA
recommends a prohibition on groundwater use in the area bounded, by
Route 11 on the east, Mr. Curt in's present property boundary on the
south, Seavers Brook Road on the west and Mr. Curt in's present
property boundary on the north until a time when groundwater levels
reach MCLs. The ordinance is attached as Exhibit 1.
4. Monitoring
Monitoring of environmental media will be conducted for thirty
(30) years to monitor effectiveness of the remedy and to identify
any further impacts to human health and the environment. The
objectives of monitoring are:
»
• to monitor the effectiveness of this and subsequent
remedies;
• to continue to monitor the bedrock aquifer to evaluate
the possibility that there are new or existing
contaminated bedrock flows, discharge points, or
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ROD DECISION SUMMARY page 20
Old Springfield Landfill
residential veils which have not been detected with
current monitoring data;
to identify further impacts to public health and the
environment; and
to monitor groundvater changes due to the implementation
of this and subsequent remedial actions.
The monitoring program will address groundwater, surface water,
sediment, soil/debris leachate and air and will include but not be
limited to:
installing and monitoring of new bedrock wells,
including locations east of the Black River, to be
determined by fracture trace analysis, remote
geophysical methods, or other techniques;
monitoring of residential wells;
inspecting for and monitoring of any new seeps;
monitoring of the collected untreated and treated
leachate and groundwater;
monitoring of surface water;
assessing groundwater for the presence of chemical
mixtures should more than one chemical be detected; and
developing of a statistical test to determine when
groundwater and leachate attains the target cleaning
levels described below.
The condition and usefulness of existing wells will be checked and
compared with future data needs. This comprehensive monitoring
well network will be designed to provide sufficient information to
evaluate dispersion of the contaminant plume, and the distribution,
of contaminant migration off-site.
Monitoring wells will be sampled and analyzed on a quarterly basis
until completion of the final remedial action to improve the
existing database. After completion of the final remedial action
it is anticipated that, monitoring wells will be sampled and
analyzed on a quarterly basis for the first three years. Samples
in years 4 and 5 are anticipated to be done semi-annually. Samples
in years 5 through 10 are anticipated to be collected once per
year. After year 10 well sampling are anticipated to be conducted
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ROD DECISION SUMMARY page 21
Old Springfield Landfill
every other year. The useful life of the leachate collection
system should exceed thirty years.
Initially, all samples will be analyzed for HSL VOCs, SVOCs PCBs,
and metals. Specific parameters may be added or deleted depending
on sampling results and observed trends. The duration of
monitoring activities vill also be assessed after major portions of
the remedy have been implemented and periodically thereafter.
Additionally, as required by CERCLA at sites where any hazardous
substance, pollutants or contaminants remaining after completion
of the remedy, a revlev of the site will occur every five (5)
years. Evaluation of the need for monitoring plan modification
will be included in the scope of the five (5) year review.
5. Additional Studies
Additional studies will be conducted to determine the feasibility
of isolating waste materials from groundwater through diverting
groundwater flow around waste materials, creating physical
barriers to separate waste materials from groundwater, landfilling
of waste materials in a Hazardous and Solid Waste Amendments (HSWA)
landfill, or other appropriate technologies. The additional
studies will include but not be limited to:
1) and evaluation of the feasibility, effectiveness, and cost of
isolating wastes from groundwater, including a detailed
evaluation of:
a. an upgradient, permeable vertical groundwater diversion
structure similar in function to a french drain;
b. physical barriers, such as a slurry wall, that separate
waste material from groundwater and/or depress the water
table to minimize contact between waste and groundwater;
c. a means of lowering the water table in areas of waste
disposal to eliminate or minimize contact between waste
and groundwater;
d. * removing the waste, including that waste in contact with
groundwater, for disposal in a HSWA landfill;
e. removing the waste, including that waste in contact with
groundwater, for treatment by incineration or
vitrification;
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ROD DECISION SUMMARY
Old Springfield Landfill
page 22
f. other neans of isolating waste materials from
groundvater; and
g. combinations of the above.
2) a quantitative determination of the amount of infiltration
and flow contacting buried waste from vertical infiltration
and lateral groundwater flow. For each of the evaluations
conducted in 1) above, quantitatively compare the amounts of
infiltration and groundwater flow contacting waste through
vertical infiltration and lateral groundwater flow before and
after remedy implementation; and
3) an identification and characterization of outlying areas-of
potential contamination which may have escaped detection in
earlier investigatory work including the western slope area
between Seavers Brook Road and Hill Dean Road and an area on
the southwestern portion of the site near Hill Dean Road, as
indicated by the magnetic anomaly in Figure 3-3 of the
Supplemental Remedial Investigation, to determine if there
are additional source of contamination. If additional
contamination is found, it will be remediated as part of the
source control operable unit, or taken offsite for disposal
in accordance with EPA's offsite policy.
B. Estimated Remedial Schedule
Record of Decision
Negotiations with PRPs
Remedial Design
Construction
Complete Remedial Action
Construction
September 1988
December 1988-March 1989
May 1989-November 1990
December 1990-December 1992
January 1993
C. Rationale for Selection/Points of Compliance
The rationale for choosing the selected alternative is based on
the assessment of each criteria listed in the evaluation of
alternatives section of this document. In accordance with Section
121 of CERCLA, to be considered as a candidate for selection in the
ROD, th*e alternative must have been found to be protective of human
health and the environment and able to attain ARARs unless a waiver
is granted. Therefore, in choosing among alternatives, the
difference in the remaining criteria, namely short term
effectiveness, long term effectiveness, implementability, use of
treatment to permanently reduce the mobility, toxicity and volume,
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POD DECISION SUMMARY page 23
Old Springfield Landfill
and the cost were the focus of the evaluation, while the
nontechnical factors that affect the implementability of a remedy,
such as state and community acceptance, also were considered.
Based upon this assessment, taking into account the statutory
preferences of CERCLA, EPA selected the remedial approach for the
site.
1. Leachate Collection/Groundvater Extraction
The objective of the leachate collection and groundwater
extraction system is to collect contaminated groundwater as close
the site boundary as practicable, and prevent the exposures to
chemicals in groundwater discharging in seeps as soon as is
practically possible. The objective of underground leachate
collection is to eliminate the volatilization of leachate
contaminates. To meet this objective in a manner consistent with
the nine selection criteria, two areas of leachate collection
(east slope and west slope) and one area of groundwater extraction
have been identified and are described below.
Underground leachate collection and groundwater extraction are the
most effective means of capturing contaminated groundwater. The
system will allow for the addition of other seeps should there be
additional breakouts during the duration of the remedy.
Underground collection of leachate will eliminate the pathway for
contaminants to volatilize at the seeps by collecting the seeps
underground before contact with the air. It will also reduce the
potential for contaminants to travel into the Black River and
Seavers Brook via surface drainage thus reducing the possible
contamination of fish in those surface waters.
Groundwater extraction wells in the sand and gravel unit above the
bedrock on the western side of the site near Will Dean Road is a
most effective means of capturing contaminated groundwater as close
to the site boundary as possible. The groundwater extraction
portion of the management of migration remedy will likely reduce
the time required to meet the groundwater target cleanup levels.
Groundwater and Leachate Target Cleanup Levels
The evaluation of groundwater target cleanup levels focused on the
type of groundwater contamination at the site, the groundwater use,
the levels necessary to protect public health and the environment
and the time required to achieve remediation goals. The Superfund
Public Health Evaluation Manual and EPA's Groundwater Protection
Strategy aided in the development of groundwater remediation target
levels. The groundwater's current and potential uses and the
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ROD DECISION SUMMARY page 24
Old Springfield Landfill
levels necessary to protect human health and the environment'.
influences groundvater cleanup levels and the time of restoration.
Based on the contaminants found in groundwater during the Remedial
Investigation, and discussions in the ARARs section, the following
contaminants and their respective MCLs were identified as
appropriate groundwater cleanup levels at the extraction veils and
at the point where leachate emanates at the seeps.
Incremental
Lifetime
Contaminants Clean up Levels Cancer Risk
Benzene 5 ppb 4 x 10"fe •
1,1-dichloroethene 7 ppb 3 x 10"5
Trichloroethene 5 ppb 2 x 10~*
Vinyl Chloride 2 ppb 1 x 10~4
The preceding compounds were selected because they were compounds
which were documented to exceed their respective MCLs at the
leachate seep and in the western sand and gravel zone. Lifetime
exposure to these four contaminants individually will result in
lifetime cancer risk levels ranging from 10~4 to 2 x 10~6 which is
within the risk range of 10~4 to 10"' for Superfund remedies. The
groundwater should also be assessed for the presence of chemical
mixtures should more than one chemical be detected. Thus, in
addition to attaining ARARs, the cleanup levels will be protective
of human health and the environment.
2. Treatment of Leachate and Groundwater
The use of the Town of Springfield's POTW may be the cost-
effective method to treat collected leachate and extracted
groundwater from the site. As noted above, this is the rationale
to be used in determining whether treatment will be on site or at
the POTW. The POTW is designed to treat 2 millon gallons of waste
water per day and the current average flow is 1 million gallons per
day.
Although not required by the State at this time, if required at
some future point, pretreatment will be easily implementable. The
Town of Springfield has indicated its willingness to place the
pretreatment unit on property presently owned by the Town adjacent
to the treatment plant. The Town's letter is attached as Exhibit
2. *>
3. Institutional Controls
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ROD DECISION SUMMARY page 25
Old Springfield Landfill
The selected remedy includes restricting the use of groundvater
where it may exceed Maximum Contaminant Levels (MCLs). EPA
recommends to the State and Town of Springfield that they
implement and enforce ordinance 88-2 passed by the Town of
Springfield as an institutional control. Specifically, EPA
recommends a prohibition on groundvater use in the area bounded by
Route 11 on the east, Mr. Curtin's present property boundary on the
south, Seavers Brook Road on the vest and Mr. Curt in's present
property boundary on the north until a time vhen groundvater levels
reach MCLs. The ordinance is attached as Exhibit 1.
4. Monitoring
The monitoring program vill be designed to meet the RCRA
groundvater monitoring requirements and site specific objectives
vill be tailored to site specific hydrogeologic conditions. Wells
vill be sampled on a periodic basis as previously described to
evaluate dispersion of the contaminant plume, the effectiveness of
the remedy, and evaluate attainment of groundvater cleanup goals
and monitor contaminant concentration in groundvater.
5. Additional Studies
Additional studies vill be conducted to determine the feasibility
of isolating vaste materials from groundvater. As noted above the
need to isolate groundvater vas conveyed to EPA by commenters
during the public comment period and by the State of Vermont on
September 2, 1988. The diverting of groundvater flov from vaste
materials, creating physical barriers separating vaste materials
from groundvater, landfilling of vaste materials in a Hazardous
and Solid Waste Amendments (HSWA) landfill, or other appropriate
technologies vill be studied in order to determine if such
diversion vould decrease the time needed to attain groundvater
cleanup levels and eliminate the risks associated vith the
contamination of bedrock.
Also included vill be an investigation of the western slope area
betveen Seavers Brook Road and Will Dean Road and a magnetic
anomaly near Will Dean Road, to determine if it is an additional
source of contamination. The vestern slope area is a location
vhere the type and quantity of contamination needs further
characterization. Debris and a number of metal 55 gallon drums
have been observed in the area. What this appears to be the
result of limited incidental dumping over the slope from Pine
Ridge Road or Will Dean Road. This area may be an additional
source of contamination of the vestern seeps or represents a
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ROD DECISION SUMMARY cage ?f
Old Springfield Landfill
direct contact, volatilization threat or both. Therefore camples
will be collected in the western slope area.
XI. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Old
Springfield Landfill cite is consistent with CERCLA and, to the
extent practicable, the NCP. The selected remedy is protective of
human health and the environment and attains ARARS. The selected
remedy also offers the best combination of effectiveness,
implementability, and cost in comparison with the other
alternatives that provide the same level of protection.
A. The Selected Remedy is Protective of Human Health and
the Environment
The remedy at this site will reduce the risks presently posed to
human health and the environment by the leachate seeps and to a
limited extent groundwater contamination. Significant public
health and environmental benefits are provided by leachate
collection and groundwater extraction. Leachate collection and
groundvater extraction will prevent inhalation, ingestion and
direct contact exposures froa chemicals migrating from the site.
Underground collection of groundvater will eliminate the
volatilization of contaminants from the leachate seeps, prevent
the spread of contaminants via surface water flow to the Black
River and Seavers Brook with subsequent contamination of fish.
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 this
operable unit at the site. Environmental laws which are
applicable or relevant and appropriate to this operable unit
remedial action at the Old Springfield Landfill site are:
Resource Conservation and Recovery Act (RCRA) _
National Pollution Discharge Elimination System (NPDES)
Safe Drinking Water Act (SDWA)
A brief narrative summary of the ARARs follows.
•K •"
Monitoring of environmental media for 30 years will comply at a
minimum with RCRA groundwater monitoring requirements under 40 CFR
Part 264, Subpart F.
-------
ROD DECISION SUMMARY page 27
old Springfield Landfill
«
If the collected leachate and extracted groundvater is treated
onsite, the National Pollution Discharge Elimination System
(NPDES) requires that the discharge of water into public surface
waters must meet NPDES permitting requirements. The water
treatment system would be designed, constructed and operated to
insure that all discharge effluent are in compliance the NPDES
requirements.
The Proposed Standards for Control of Emissions of Volatile
Organics (52 FR 3748, February 5, 1987) proposes standards for VOC
air emissions from units such as air strippers. Air strippers may
be part of the treatment system. This proposed standard would
require air treatment equipment to be designed, constructed, and
operated in tandem with air stripping units.
If the collected leachate and extracted groundwater is conveyed to
the Town of Springfield POTW for treatment, the Domestic Sewage
Exclusion (40 CFR Section 261.4(a)(1)) provides that a hazardous
waste, vhen mixed with domestic sewage, is no longer considered a
solid waste. Therefore, hazardous waste may be mixed with domestic
sewage and sent to the POTW which does not have a RCRA treatment,
storage and disposal facility permit.
The POTW is required to have an NPDES permit to discharge to the
Black River, and has a history of compliance with its NPDES
permit.
In addition, drinking water standards established under the Safe
Drinking Water Act (SDWA) are used to set cleanup levels for
groundwater outside the area of institutional controls. This area
may be used as a drinking water source, therefore MCLs established
under the SDWA are relevant and appropriate and will be attained.
C. The Selected Remedial Action is Cost Effective
Once EPA has identified alternatives that are protective and
attain ARARs, unless a waiver is granted, EPA analyzes those
alternatives to determine a cost-effective means of achieving the
cleanup.
Each of the alternatives underwent a detailed cost analysis to
develop costs to the estimate accuracy of -30 to +50 percent. In
that analysis, capital and operation and maintenance costs were
estimated*and then used to develop present worth costs. In the
present worth analysis, annual costs were calculated for thirty
years (estimated life of an alternative) using a five (5) percent
interest rate factor and were based on 1988 costs.
The preferred remedy is cost-effective. The alternative estimated
to cost less than the preferred remedy are less protective and do
-------
ROD DECISION SUMMARY page 28
Old Springfield Landfill
not meet the remedial objectives and ARARs. The no action .
alternative provides little protection and does not Beet ARARs.
D. The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment Technologies or Resource Recovery
Technologies to the Maxima Extent Practicable
This operable unit remedy utilizes permanent solutions and
alternative treatment or resource recovery technologies to the
maximum extent practicable for this site. Treatment of the
collected leachate and extracted groundvater will permanently and
significantly reduce the volume, toxicity and mobility of the
contaminants. The pumping veils in the sand and gravel unit .
provide a further reduction in mobility by reducing the amount of
contaminants leaching to bedrock and Seavers Brook. Collection of
the seeps before they reach the surface reduces the air toxicity.
However, EPA will require that institutional controls restricting
groundvater use be implemented.
E. The Selected Remedy Satisfies the Preference for
Treatment as a Principal Element
The principal element of the selected remedy is the collection and
treatment of leachate and groundvater. This addresses the primary
threat for this operable unit. Treatment of leachate and
contaminated groundvater satisfies the statutory preference for
treatment.
XII. STATE ROLE
The Vermont Department of Environmental Conservation has revieved
the various alternatives and has indicated its support for the
selected remedy. The State has also revieved the Remedial
Investigation, Supplemental Remedial Investigation, Endangerment
Assessment, and Feasibility Study to determine if the selected
remedy is in compliance vith applicable or relevant and
appropriate State environmental lavs and regulations. The state
of Vermont concurs vith the selected remedy for the Old
Springfield Landfill site. A copy of the declaration of
concurrence is attached as Appendix 1. In accordance vith Section
104 of CERCLA, the State of Vermont is responsible for at least 50
percent* of the cost of the remedial action and all operation and
maintenance.
-------
ATTACHMZKT 1
-------
K»IIO«I« «u onmic MIA, un sia.
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-------
, GROUND WATER MONITORING WELL RESULTS
(WEST SIDE)
OLD SPRINGFIELD LANDFILL SITE
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-------
LEACHATE SEEP/SPRING ORGANIC RESULTS
(WEST SIDE)
OLD SPRINGFIELD LANDFILL SITE
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-------
ATTACHMENT 2
-------
SOIL ORuftNJC WtTA-COaPOWD FRECUENCY DISTRIBUTION FflW SURFACE TO 4.5 FOOT INTERVAL.
FREQUENCY MINIMUM WHIMUK
OF DETECTED DETECTED
DETECTION VALUE VALUE
BENZO(B)FUJORAKTHEIC
CLASS COMPOUND
-- I-ONOCYOJC AROMATIC HY&RGCftRBONS
V BENZENE
V CHLORDBENZENE
V ETHYLKNZEM
V TPLUEKS
V XYLENES (TOTAL)
- CHLORINATED ALIPHATIC HYDROCARBONS
V XETHYLENE CHLORIDE
V TE7RACH.OROETHENE
V TRA.NS-1,2-DICHLORQET>£NE
V 1,1,1-TSICHLCRGETHflNE
V TRICK.OfiO£Tt£NE
V TRAtt-i,3-DICHLOSQPROPENE
- aiSCELWEOUS VOLATILE COMPOUNDS
V CHLORQFOS.1
V STYRENE
V 2-BUTA.ONE
V CAR50K DISU.FIDE
- POLYCYaiC AROKATiC HYDROCARBONS
B ftCtNAPHTKENE
B ACENAPffTHYLENE
6 ANTHRACENE
3
B
B
B
B
B
B
B
B
B
B
B
B
—
B
B
B
B
B
B
B
B
B
A
A
P
P
P
B£KZO(6,K,I)PESYLO£
CHRYSEfC
IW»CU,a,3-CD)PYR£NE
KAPHTKALEXE
PH£MMTHRS£
PYRENE
PWHALATE ESTERS
BIS(&-ETHYLHaYL)PHTHftLATE
BUTYLBENZYLPHTMLATE
OIETHYLPH7HALATE '
OI-M-fiUTYLPHTHALATE
DIHHCTYL PHTHAUTE
MlSCELBXcOJS NON-VOLATILE COMPOUNDS-
1,2-DICHLOROBCNZENE
N-NITROSODIPHENYLAMIfC(l)
DIFENZOFURAN
g^ETHYLNAPHTHALENE
4-KTHYLPHML
BENZOIC ACID
PCBS AND PESTICIDES
BETA-&C
PCfi-125*
PC6-1260
5
1
3
17
7
1
2
1
2
6
1
6
8
0
0
0
3
5
S
6
B
2
2
6
10
2
2
2
9
10
1
4
2
4
3
5
j«
1
1
1
3
0
0
2
6
7
2
1700
2
2
9
7500
SO
140
S
14
5000
1
11
KA
NA
KA
32
120
250
330
330
130
3SO
460
210
51
330
4600
130
330
170
380
42
14
330
330
17000
1000
15
2300
NA
NA
7.7
30
40
5600
1700
2600
3300
4200
7500
51
140
1600
5600
5000
360
70
NA
*A
NA
330
3600
12000
10000
11000
ttOO
4800
12000
30000
5000
4400
5600
17000
24000
170
23000
330
3700
2700
4700
17000
1000
15
6000
NA
NA
8.3
190(0
5t&
-------
OLD SPRINGFIELD INORGANIC SOIL DATA-ELEMENT FREQUENCY DISTRIBUTE FROM SURFACE TO 4.5 FOOT INTERVAL,
FREQUENCY RINIKJM HAI1KJM
OF DETECTED DETECTED
DETECTION VALUE VALUE
FREQUENCY MINI** KAHft*
Of DETECTED DETECTED
DETECTION VALUE VALUE
AUW1NUK
ARSENIC
BARll*
KRYUIlp
CADKIUK
CALCIUM
CMOKIUK
COBALT
COPPEB
IRON
LEAD
M&CSItr.
MANGANESE
CRCURY
NICKEL
POTASSIUM
SILVER
SODIl*
TIM
VANADIUM
ZINC
CYANIDE
46
21
44
14
13
37
46
39
46
46
46
37
46
10
39
23
3
IS
3
44
46
0
2260
0.5
9.9
0.2
0.06
403
2.5
1.3
5
4006
2.8
607
42
0.067
4.S
346
1.6
104
8.4
3.7
13
0
14900
10
164
0.6
7.3
19227
70
10
147
27300
139
4960
467
0.26
36
2100
22
1470
39
41
441
0
-------
SOIL QKfnK DflTft-OWOUND FfttWENCY DISTfclftJTlCW Fiiurt 4.5 70 S.5 FuOT INTERVAL.
FREQUENCY MINIMUM
OF DETECTED DETECTED
DETECTION VALUE VALUE
CLASS COMPOUND
- fCNCCYQJC AROMATIC HYDROCARBONS
V BENZENE
V CHLDSOBEX7.ENE
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V XYLENES (TOTAL)
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V METHYLEK CHLORIDE
V TETRACHLOROETHENE
V TRAKS-1.2-D1CKOROETHENE
V 1,1,1-TSlCHLOSOETHANE
V TR1CH.OROETHENE
V TRANS-1,3-DICHLOSOPROP£NE
-- MISCELANEOUS VOLATILE COMPOUNDS
V CHLOROFORM
V STYREK
V
V
CARBCN DISULFIDE
POLYCYCLIC AROMATIC HYDROCARBONS
ACENAPHTKENE
ACBJAPKTHYLEKE
ANTHWCOC
BENZQ(A)PYRENE
BENZO(B)FIUORAKTHE)€
BEKZOtklFLUORANTHEXE
B£NZO(6,H,I)PERYLE*C
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B
B
B
B
B
B
B
B
B
B
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B PHENAVTHRE&
B PYREK
B OIBENZO(a,h)ANTHJ(ACE>e
- PHTHOLATI ESTERS
B BIS(2-ETWU&YUPHTHALATE
B BUTYLf€KZYLPHTHAUnE
B DIETKYIPHTHPLATE
B DI-#-flUTYLPHTHfiLflTE
B Dm-OCTYL WTHALATE
- WSCaflNEOUS NQN-VOLATILE COMPOUNDS'
B L,2-D10CDfDB£N2£>£
B N-HITROSOOIPHENYLAMI^d)
B DIECKZOFURAN
B a-METHYLNAPHTHRLEKE
A 4-METHYL PHENOL
A GCN20IC ACID
- POS AND PESTICIDES
P ECT(H4C
P PCB-1854
P PCB-1260
0
0
4
4
3
0
Z
2
0
3
0
0
0
0
0
3
2
3
Z
'£.
I
1
2
3
S
3
2
4
S
5
1
5
1
0
1
0
0
1
2
3
0
0
0
7
1
NA
HA
1000
ea
5900
HA
10
S
HA
3
NA
NA
NA
KA
NA
24
250
440
970
1100
1800
30000
430
210
280
27
440
63
68
500
20000
2600
360
NA
2300
NA
NA
1600
no
40
NA
NA
NA
250
720
tt
NA
3dCO
1300
24000
NA
16000
15
w
26
NA
HA
NA
NA
NA
7700
12000
35000
51000
40000
32000
30000
28000
45000
130000
21000
23000
5500
150000'
79000
20000
16000
360
NA
2300
NA
NA
1600
16000
3700
NA
NA
NA
42000
720
-------
OLD SM1NSF1ELD INORGANIC SOIL DATA-ELEMENT FREQUENCY OISTRIHJT10M FROM 4.3 TO 9.5 FOOT INTERVAL
FRtOIDCY WNIKJN MAXIMUM
OF DETECTED DETECTED
DETECTION VALUE VALUE
FREOUENCY HlNlftlfl HAIIKUM
OF DETECTED DETECTED
DETECTION VALUE VALUE
AUmlNUK
MSEMC
BARIUM
BERYLLIUM
CACXIUX
WICIWI
MOXIUM
caw.:
COPPER
IRON
LEAD
KASNESIl*
MAKGANESE
KRORY
MCKEi
POTftSSioH
SILVER
SODIiin
THAU.lJ?(
TIN
VANADItX
2INC
CYANIDE
36
22
36
22
B
36
36
33
36
36
34
36
36
S
33
13
13
4
2
3
39
33
20
1190
1.2
6.3
0.2
2.1
133
2.6
2.7
S
4100
3
566
43
0.082
3.3
342
1.3
123
0.3
S
4.3
13
0
16000
13.2
1266
0.9
7.6
49279
163
12
1997
65000
833
7533
809
0.13
ISO
2232
14.9
831
0.57
43
32
1023
3.8
-------
SOIL ORGANIC DATA-COMPOUND FREQUENCY DISTRIBUTION BELOW 9.5 FOOT LEVEL
CLASS COMPOUND
Mfy/Typi IP fiOfKiflTir HYIiRnrflRfiflMQ
^^^^^^nu«TUU i WU1U nnurviiAw niyniA^iiwUrQ
V BENZENE
V CHLOROBENZENE
V ETHYLKNZENE
V TOLUENE
V XYLEKE3 (TOTAL)
CHUMINATED ALIPHATIC HYDROCARBONS •
V METKYLENE CHLORIDE
V TETJWHOHJETHQ*
V TRft\S-J, a-DICH-ORDETVENE
V 1,1,1-TRICHLOROETHANE
V TRICKLOROETHENE
V 7RANS-1 , 3-DICHLOROPROPENE
KSCELfiNEDUS VOLATILE COMPOUNDS •
V CHLC3CFORN
V STYfitNE
V 2-2U7ANQ4
V CAi&OX DISULFIDE
POLYCYCUC MOmnC hYWOWSBOSS •
3 ACENAPHTKEKE
3 ACENAPHTHYLENE
B ANTHSACENt
3 BENZOc
3 DIr£X2C(a,h)AXTrRACEN£
3 BIS(2-ETWLH£XYUPHTHALATE
B KJTOEWYLPHTHALflTE
3 DIE'n-fr.PHTHALATE
B K-«r-BJTYL?HTHALATE
3 KHH3CTYL ^THALATE
T!!£tlttJCQLC NQN-UnOTTIF niMOnNnC<
r.tawCLMVUAO WWfT^fUUH 1 i UC LUnrUUWW
B MiIT5C-SODI3r€NYLAMlN£(l) __
B DIKXZDFUiWX —
B 2-r£ThY,.NA?HTHALEN£
fi 4-Vn
27000
1400
.\R
r«
3
76
NA
NA
110
KC
sa
i:
-------
OLD SPRItfFIELD INORGANIC SOIL DATA-ELEMENT FREQUENCY DISTRIBUTION BtLOU 9.5 FOOT L£VEL
FREQUENCY MINIMUM MAXIMUM
OF DETECTED DETECTED
DETECTION VALUE VPLUE
FREQUENCY MINIMUM MAXIMUM
OF DETECTED DETECTED
DETECTION VALUE VALUE
ALUMINUM
ARSENIC
M3IUI
BERYLLIUM
CADMIUM
CA.CIUM
CKWIUN
CQWLT
COPPER
IRON
LEAD
MAGNESIUM
MAM6ANESE
MERCURY
NICKEL
POTASSIUM
SILVER
.SODIUM
THALLIUM
TIN
VANADIUM
ZIfC
CYANIDE
IS
8
IS
7
1
IS
IS
IS
IS
IS
14
IS
IS
3
14
13
Z
4
e
i
is
14
3
1830
1.&
8.7
0.2
3
672
2.6
15
7
3690
12
1030
44
0.17
6.4
529
1.6
106
0.53
20
4.S
22
1.2
9446
S.4
1100
13
3
12700
70
43
470
24900
302
4600
494
0.23
41
2490
2.4
3190
0.63
20
17.4
2330
3.3
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ATTACHMENT 3
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SUMMARY OF SELECTION OF CHEMICALS OF POTENTIAL CONCERN
OLD SPRINGFIELD LANDFILL SITE
Chemical
Chlorinated Aliphacicss
Vinyl Chloride
Methylene chloride
1 , 1-Dichloroethene
1,1-Dichloroe thane
trans -1,2 - Dichloroe thene
1 , 1 , 1-Trichloroethane
Trichloroe thene
Tetrachloroe thene
Chloroform
Monocvclic Aromatics
Benzene
Toluene
Chlorobenzene
1 , 2-Dichlorobenzene
Echylbenzene
Xylenes
Soil
• ^
X(b)
X(a)
X
X
X(b)
X
X
X
X(a)
X(a)
X
Monitoring
Veils
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Leachate
Seeps
X
X
X
X
X
X
X
X
X
X
X
X
Leachate
Sediments
X
X
X
X
X
X
X
X
X
X
Other Volatiles
Acetone
Semi-Volatiles
'Diethy1 Phthaiate
Bis (2 - e thylhexyDphthalate
Naphthalene
Di-n-butylphthalate
Carcinogenic PAHsC
PCBS
X(b)
X
X
X
X
X
X
X
X
X
X
Inorganics
Cadmium
Mercury
Copper
Nickel
X(b)
X
X
X
X
2-13
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ATTACHMENT 4
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SUMMARY OF IH1TIAL SCREENING OF REMEDIAL ALTERNATIVES
OLD SPRINGFIELD LANDFILL SITE
FEASIBILITY STUDY REPORT
Retained for Eliminated from
Further Further
Alternative Evaluation Evaluation
Management of Migration
Alternatives
MM-1 Minimal No-Action X
MM-2 Selective Seepage Point
Collection and Onsite
Treatment *
MM-3 Selective Continuous
Seepage Collection and
Onsite Treatment *
MM-4 Seepage Point Collection
and Onsite Treatnent of
All Seeps x
MM-5 Continuous Seepage
Collection and Onsite
Treatment of All Seeps X
MM-6 Ground Water
Extraction by
Wellpoints and
Onsite Treatment X
• Alternatives MM-2 through MM-4 were eliminated in lieu of
Alternative MM-5, based on a comparison evaluation
of effectiveness vs. cost.
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EXHIBIT 1
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TOWN OF SPRINGFIELD
ORDINANCE 88-2
Be it ordained by the Town of Springfield:
SECTION I.
SECTION II
SECTION III.
SECTION IV.
PURPOSE: For protection of the herlth, safety,
and welfare of the inhabitants of the Town of
Springfield, it is necessary for the Board of
Selectmen to have authority to determine
where and when necessary, that certain
parcels of land within the Town contain
hazardous wastes, toxic materials or harmful
chemical matter. Upon such determination,
the Board of Selectmen may restrict the uses
and activities upon said lands consistent
with the provisions hereinafter set forth.
This Ordinance shall apply to any parcel of
land determined to contain hazardous waste,
harmful and/or toxic substances by the United
States Environmental Protection Agency (EPA)
and declared to be a Superfund Site or an
otherwise hazardous place.
This Ordinance shall'also apply to any parcel
of land determined to contain hazardous
waste, harmful ?nd/or toxic substances by the
Board of Selectmen of the Town of
Springfield, or any applicable agency of the
State of Vermont.
The restrictions hereinafter set forth may
apply to any parcel of land adjacent to land
deteraiaed to be subject to Sections I-III
hereof, or to any parcel of land which
carries seepages or any above or below ground
watercourse containing hazardous or toxic
materials from land defined in Sections
I-III.
-1-
-------
SECTION V. RESTRICTIONS: The Board of Selectmen to
protect the health and welfare of the
inhabitants of the Town of Springfield nay,
upon the designation that a parcel of land '
contains hazardous, harmful or toxic wastes
or chemicals, by resolution/ restrict the
subject land in one or more of the following
ways:
A. Prohibit the construction of, or the
maintenance of, habitable buildings or
other structures upon the subject
premises;
B. Prohibit the breaking of the surface
of the soil by digging, trenching,
drilling, boring or disruption of the
soil surface;
C. Prohibit the growing of crops upon
the subject premises, the consumption
thereof or transportation thereof;
D. Prohibit any residential, commercial
or recreational .use of said premises;
E. Prohibit the taking, use or
cor. sue pi ion of water froc or which flows
through the subject premises either
above or below the soil surface;
F. Prohibit the excavation, filling or
depositing sf any solid or liquid
material on the subject premises,
including the sewage, sludge or other
waste material;
G. Prohibit the making of any change in
the topography of the subject premises;
H. Prohibit the entry upon the subject
premises by any person where the degree
-------
of danger is such as to be a threat to
life or to health;
I. Prohibit any activity on or near the
subject premises which would tend to
alter the water table thereon;
J. To place any other restriction on
the subject premises which nay in the
exercise of prudence be necessary for
public protection, including posting or
fencing of the premises.
SECTION VI. The Board of Selectmen shall designate such
parcels of land as are subject to this
Ordinance by Resolution, and in said
Resolution determine the applicable
restrictions necessary to carry out the
purposes of this Ordinance.
SECTION VII. Prior to the adoption, modification or
removal of a limitation imposed by Resolution
pursuant to the terms of this Ordinance, the
Board of Selectmen shall cause notice to be
given to each affected landowner, and to any
other person who may have a record interest
in said premises, and shall also give notice
to any necessary State or Federal agency.
*• Notice. Notice shall include:
(1) A statement of the time, place
and nature of the hearing;
(2) A statement of the legal
authority and jurisdiction under
which the hearing is to held;
(3) A reference to the partiuclar
sections of the statutes and rules
involved; and
(4) A short and plain statement
of the matters at issue.
-3-
-------
If the Board of Selectmen or other
agency is unable to sta.te the natters in
detail at the time notice is served, the
initial notice may be limited to a
statement of the isssues involved. As
soon as possible thereafter, a more
definite and detailed statement shall be
furnished.
B. Hearing. All persons who respond to
said notice shall have opportunity to
present evidence and argument on all
issues involved.
C. Inforaal Disposition. Unless
precluded by lav, informal disposition
may be sade by stipulation, agreed
settlement, consent order, or default.
D. Record. The record in each case
shall include:
(1) All pleadings, motions,
intermediate rulings;
(2) All evidence received or
considered;
(2) A statoner.t of matters
c!ficially ncflce-i;
(A) Questions and offers of proof,
objections and rulings thereon;
(5) Proposed findings and
exceptions; and
(6) Any decision, opinion or
report.
E. Evidence. Findings of fact shall be
based exclusively on the evidence and on
matters officially noticed.
F. Transcript. Oral proceedings or any
part thereof shall be transcribed on
request of any party subject to other
-4-
-------
applicable provisions of lav, and upon
payment by the requesting party of the
reasonable costs thereof.
Dated at Springfield, County of Windsor and State of
Vermont, this 16thday of teril . * 1988.
Board of Selectmen
June 10, 1988
I hereby certify that the foregoing is a true copy of
Ordinance 088-2 as it appears in the Book of Ordinances for
the Town of Springfield, Vermont.
Attest:/
-5-
-------
EXHIBIT 2
-------
Off ice cf the Manager TOWN OF SPRINGFIELD
SPRINGFIELD. VERMONT 05156 / (802) 885-2104
August 24, 1988
RECEIVED
Paula Lia Fitzsimmons
Remedial Project Manager ^|J5 3 C 88
U.S. Environmental Protection Agency
Region 1
JFK Federal Building «.^rm^£S»«i
Boston, MA 02203 MANAGEMENT BRANCH
RE: Old Springfield Landfill Site
Dear Paula,
This letter is in response to your inquiries made to the Town
of Springfield with regards to the possible use of the Springfield
Sewage Treatment Plant in remediation efforts of the Old
Springfield Landfill Site. As you are now aware, so-called
"Operative Unit No. 1", the remedial alternative presented to EPA
by Emhart Corporation, Textron Corporation and the Town of
Springfield in June of 1988 included as part of the leachate
treatment system the utilization of the Town's wastewater
treatment facility.
That "offer" was made only after careful consideration of the
Town's administrative staff and elected officials. Our decision
to include the plant was based primarily upon a report provided to
the Town by the engineering firm of Dufresne-Henry. I am
including with this letter a copy of the analysis provided the
Town by Dufresne-Henry lor your consideration.
While at this juncture, I am still comfortable with the
concept of making available the treatment plant, as part of the
leachate treatment system, I must reserve the right to once again
have our engineering consultants, Dufresne-Henry, evaluate the
specifics of any new or revised proposal. This is said in light
of the fact that we must recognize we are not at the point in the
process where we Xnow the specific design criteria of the final
system. Therefore, it is impossible for me and the Town to make a
final decision on the involvement of the POTW without first
realizing What a proposed pretreataent process and other details
will entail. This is not to say that I have any reason to believe
that a mutually satisfying arrangement cannot be made.
Additionally, I understand that it is premature to know who will
be responsible for the design and implementation of the remedy;
however, regardless of how those negotiations end, I welcome the
opportunity to work with the design engineers in involving the
Town's POTW.
PROGRESS THROUGH PRECISION
-------
Paula Lia Fitzsimnons -2- August 24, 1988
Furthermore, it has recently been expressed by citizens
living in the area of the Old Springfield Landfill Site that they
are concerned with locating a pretreatment facility on or near the
site. Upon hearing those concerns, the Springfield Board of
Selectmen nade an offer to consider locating a pretreatnent
facility on or near the location of the current Town POTW. I
again extend this offer to the EPA for consideration; but, again,
I oust qualify that offer by reserving the right to make further
evaluations of the natter as more detail becomes available. And
like the POTW, the Town feels it necessary to be involved in the
design efforts of the final remedial plan.
Sincere
Wj/liam R. "Stecle
Town Manager
WRS/jf
cc: Linda Biagioni, Emhart Corporation
Paul Duff, Textron Corporation
Gerald Conk1in. President, Dufresne-Henry
John Parker, Esq.
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APPENDIX 1
-------
REM III PROGRAM
REMEDIAL PLANNING ACTIVITIES
AT SELECTED UNOONTBOT.TFD HAZARDOUS SUBSTANCE DISPOSAL SITES
WITHIN EPA REGIONS i - iv
EPA CONTRACT NUMBER: 68-01-7250
WORK ASSIGNMENT NUMBER: 50-1139
FINAL RESPONSIVENESS SUMMARY
OLD SPRINGFIELD LANDFILL SITE
SPRINGFIELD, VERMONT
SEPTEMBER 1988
Prepared By:
Approved By:
Diane E. Ready (;
Connunity Relations Specialist
REM III/ICF Inoorporated
Russell H. Boyd Jr. , P.E.
REM in Regional Manager
Region I
Ebasco Services, Inc.
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TABLE OF CONTENTS
I. OVERVIEW OF THE PREFERRED ALTERNATIVE AND OTHER REMEDIAL
ALTERNATIVES CONSIDERED IN THE FEASIBILITY STUDY .... 3
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS .... 6
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS 9
A. COMMENTS FROM CITIZENS 9
B. COMMENTS FROM THE PRPs 17
C. STATE OF VERMONT COMMENTS 21
IV. SUMMARY OF CONCERNS RAISED DURING THE INFORMAL QUESTION AND
ANSWER PERIOD OF THE JULY 21,1988 PUBLIC MEETING AND EPA
RESPONSES 23
V. REMAINING CONCERNS TO BE ADDRESSED BY EPA 27
ATTACHMENT A - COMMUNITY RELATIONS ACTIVITIES CONDUCTED BY EPA AT
THE OLD SPRINGFIELD LANDFILL SITE
ATTACHMENT B - COMPLETE TEXT OF PRP COMMENTS AND DETAILED EPA
RESPONSES
ATTACHMENT C - COMPLETE TEXT OF STATE OF VERMONT COMMENTS
List of Exhibits
Exhibit 1 Old Springfield Landfill Site Map
Area of Proposed
Cap 11-1
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Preface
The U.S. Environmental Protection Agency (EPA) held a public
comment period between July 8, 1988 and August 24, 1988 for
interested parties to comment on the Remedial Investigation (RI),
Feasibility Study (FS), and Proposed Plan for the Old Springfield
Landfill Superfund site. The RI, released by EPA in September 1985
and the Supplemental RI, released in June 1988, examine the nature
and extent of contamination at the site. The FS, released by EPA
in July 1988, examines and evaluates various cleanup options,
called remedial alternatives, for addressing contamination at the
site. EPA announced its preferred alternative for the cleanup of
the site in the Proposed Plan issued at the start of the public
comment period.
The purpose of this Responsiveness Summary is to document EPA
responses to the comments and questions raised during the public
comment period. EPA considered all of the comments summarized in
this document before selecting a final remedial alternative for the
Old Springfield Landfill site.
This Responsiveness Summary is divided into the following sections:
I. Overview of the Preferred Alternative and Other Remedial
Alternatives Considered in the Feasibility Study - This
section briefly outlines the remedial alternatives,
including EPA's preferred alternative, that are described
and evaluated in detail in the Feasibility Study and the
Proposed Plan.
II. Background on Community Involvement and Concerns - This
section provides a brief history of the site and of
community interests and concerns regarding the Old
Springfield Landfill site.
III. Summary of Comments Received Purina the Public Comment
Period and EPA Responses to These Comments - This section
summarizes both written and oral comments received by EPA
during the public comment period and provides EPA's
responses to them. These comments are separated into
three categories: 1) comments from citizens; 2) comments
from potentially responsible parties (PRPs); and 3)
comments from the State of Vermont.
IV. Summary of Concerns Raised During the Informal Question
and Answer Period of the July 21. 1988 Public Meeting -
•This section summarizes questions raised after the close
of the public hearing portion of the July 21, 1988 public
meeting during which EPA accepted formal comments. This
section also provides EPA responses to these questions.
-------
V. Remaining Concerns to Be Addressed bv EPA - This section
describes concerns to be addressed by EPA during the
Remedial Design and Remedial Action (RD/RA) phase of the
cleanup process.
This Responsiveness Summary also includes the following
attachments.
Attachment A - This attachment lists the community relations
activities conducted by EPA to date at the Old Springfield
Landfill site.
Attachment B - This attachment includes the complete text of
written comments received from PRPs and EPA's detailed
responses. The comments and responses in this section expand
on the summarized comments and responses provided in Section
III. B. of this document.
Attachment C - This attachment consists of the complete text
of written comments offered by the State of Vermont.
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I. OVERVIEW OF THE PREFERRED ALTERNATIVE AND OTHER REMEDIAL
ALTERNATIVES CONSIDERED IN THE FEASIBILITY STUDY
Alternatives Evaluated in the Feasibility Study
The Feasibility Study (FS) prepared by EPA for the Old Springfield
Landfill site identifies and evaluates seven remedial alternatives
for achieving EPA's cleanup objectives for the site. The seven
remedial alternatives are organized into two categories: 1) source
control alternatives to address the source of contamination present
at the site, and 2) management of migration alternatives to address
the spread of contamination. The FS for the Old Springfield
Landfill site also examines resident relocation alternatives as a
component of the source control alternatives.
The Proposed Plan, which identifies the alternatives EPA recommends
for the site, also contains brief descriptions of each of the
alternatives considered in detail in the FS. These source and
management of migration alternatives, including the preferred
alternatives identified in the Proposed Plan, are outlined below.
More complete descriptions of these alternatives are contained in
the FS and Proposed Plan for the site, which are available as part
of the Administrative Record for the site at the Springfield Public
Library and the EPA Records Center at 90 Canal Street, Boston,
Massachusetts.
After consideration of comments received from the public, the State
of Vermont, and the PRPs during the public comment period, EPA has
decided to address source control issues at the site separately
from the management of migration issues. This means that EPA will
issue at least two distinct RODs for the site, one that addresses
management migration through an operable unit for seeps and a
subsequent one that addresses source control issues. This
responsiveness summary is being developed in conjunction with EPA's
ROD outlining a remedy to address management of contaminant
migration through the seeps at the site. A source control
alternative, including a relocation option, will be selected and
described in a separate Record of Decision for the site, to be
developed after further site study in accordance with comments
received during the public comment period.
1. Source Control
The purpose of implementing a source control remedial alternative
at the Old Springfield Landfill site is to address soil
contamination, which is considered to be a source of groundwater
contamination. The FS for the Old Springfield site evaluates the
five source control alternatives outlined below.
-------
unsuitable for incineration, would be placed in an on-site
RCRA landfill, as described in alternative b. above.
Residents would be relocated under this alternative.
d. In-Situ Vitrification - This alternative would require
excavating contaminated waste and placing it in on-site
trenches. Electrodes would be placed in the waste trenches
to melt, or vitrify, the waste. The extremely high
temperatures generated would destroy many of the
contaminants and solidify any remaining contamination into a
glass-like substance. The trenches would be covered with
fill and seeded to provide a vegetative cover. Residents
would be relocated under this alternative.
e. No Action (soils)- This alternative would involve leaving
contaminants untreated on site, and fencing and monitoring
the site. Resident relocation would not be necessary to
implement this remedy.
2. Management of Migration
The FS also evaluated two alternatives to manage the migration
of contaminants by collecting and treating contaminated
groundwater and leachate to prevent the spread of
contamination. These alternatives are outlined below:
a. Continuous Leachate Seepage Collection and Treatment
(Preferred Management of Migration Alternative) - This
alternative would involve construction of underground
interceptor trenches to collect all seeps from the slopes
descending from the site. Wells would be installed on the
western side of the site to extract contaminated groundwater
for treatment on-site. The treatment system would use
technologies such as air stripping and activated carbon
treatment. During air stripping, air is forced up over
contaminated water, causing a transfer of volatile
contaminants from the water into the air stream. The air is
then passed through activated carbon filters, where the
contaminants adhere to the carbon so that only treated air
is released to the environment.
b. No* action fqroundwater) - This alternative would require no
collection or treatment of contaminated groundwater, only
long-term monitoring of contamination levels in the
groundwater.
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II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The 27-acre Old Springfield Landfill Superfund site is located
approximately one mile south-west of the city center in
Springfield, Vermont. The Springfield Mobile Home Estates,
currently consisting of 12 mobile homes, is located on the site.
The site has contained up to 43 mobile homes since its opening. A
six-building condominium complex and 13 single family residences
are also located near the site.
The Old Springfield Landfill, also referred to as the Will Dean
Dump, was operated on the site between 1947 and 1968. Shortly
after the landfill closing, the site was sold and the former
landfill was developed for use as a mobile home park. There was
little public interest in the site prior to the sale of the closed
landfill, however upon proposal of the mobile home park, neighbors
to the site petitioned to prevent the development of a mobile home
park on the site.
Potential contamination problems at the site were first brought to
the attention of the State of Vermont in 1970, when a resident
living near the site on Will Dean Road complained that his well
water had become foul-smelling. Testing by the State of Vermont
showed that contamination was present in the well and in a
community spring near the site. Subsequently, the State
recommended that the affected resident should cease using his well
water, and that the spring should be abandoned. A high level of
citizen concern and awareness of the site has predominated since
the contamination was first confirmed by the Vermont Department of
Health in 1974. The major issues of concern to Springfield
residents since contamination was confirmed at the site are
summarized below.
Water Supply and Water Quality
The major concern shared by residents of the mobile home park and
neighbors of the site has been the site's potential impact on
groundwater quality, and problems in securing alternative water
supplies for affected residents. After the State confirmed
contamination in well water near the site, the Town of Springfield
proposed that a one-inch municipal water line that served the
mobile home park be extended to serve the resident on Will Dean
Road whose well was contaminated. This alternative did not meet
the resident's concern that site contaminants could enter the one-
inch water line, contaminate household plumbing, and pose a
potentia*! threat to human health. The matter was settled out-of-
court in 1977, and the resident received a partial subsidy from the
town to connect to the eight-inch municipal water line.
In 1981, testing conducted by the State of Vermont revealed that
contamination was present in two more area wells and in 1982 the
-------
site was added to the National Priorities List of sites eligible to
receive federal funds for investigation and cleanup. Newspaper
accounts of these events heightened community awareness and concern
about the site. A study released by the Vermont Department of
Health in 1983 concluded that municipal water lines should be
extended to affected residents and a full site investigation should
be conducted. During community interviews conducted in 1984,
residents living near the site expressed anger over continued
delays in securing alternate water supplies. The Town of
Springfield and two PRPs connected one of the two affected homes in
1984, and connected the second affected home in 1985.
Potential Contaminant Migration
Residents interviewed by EPA in 1985, as well as residents
attending public meetings to discuss the site, expressed their
concerns that the contamination could be spreading down the steep
slopes of the site, as well as into the Black River, which flows to
the east of the site. Residents also complained of the potential
for exposure to contamination present in the red-tinged seeps that
emerge from the slopes of the site. These areas were investigated
during EPA's Remedial Investigation of the site conducted between
1984 and 1988. The findings of the Remedial Investigation and
Supplemental Remedial Investigation are available as part of the
site Administrative Record available at the Springfield Public
Library and at the EPA Records Center at 90 Canal Street in Boston,
Massachusetts.
Possible Relocation
Since the contamination was first discovered, residents of the
mobile home park have been anxious to know whether they would
eventually be relocated because their homes sit directly over the
former landfill. Many have said that they did not know the park
was built over a former landfill when they moved into the area.
Residents of the park have consistently requested that EPA provide
ample warning of any plan to relocate residents. Since work began
at the site, EPA has informed residents that because waste was
located beneath residences, relocation would be considered as part
of the remedy for the site, however no decision on whether
relocation would be necessary could be made until EPA completed the
site investigation and evaluation of cleanup options.
Progress*of the Site Investigation
At public meetings held by EPA concerning the Old Springfield
Landfill site, residents have complained of delays in taking action
at the site. Residents noted that EPA announced its plans for
conducting a site study in 1983, but did not begin the
-------
investigation until 1984. Community concern over unresolved water
quality issues remained high even after the site study commenced.
After the municipal water line was extended to serve affected
residences, concern shifted to complaints about the length of the
study and the length of time before the site cleanup could begin.
Cost Allocation
The community has voiced concern about the potential cost to the
Town of Springfield, for extensions of water service, the site
investigation, and eventual cleanup. The Town of Springfield has
been identified as a potentially responsible party at the site and
residents fear costs to the town will be passed on to local
taxpayers.
Effects on Property Values
In community interviews conducted by EPA and during public meetings
to discuss the site, residents have expressed concern about the
site's impact on the value of their properties on or near the site.
One resident complained that his property had been assessed at a
higher value since discovery of contamination at the site, despite
the fact that, at the time of the assessment, no public water
supply had yet been made available to him. The resident did not
feel he should pay higher taxes on his property, since he did not
have what he considered and adequate water supply.
Limits to Development;
The owner of the mobile home park voiced concern about economic
losses to his business at the mobile home park pending the outcome
of EPA's study of the site. Residents also expressed concern that
the site would discourage businesses and individuals from locating
in Springfield.
8
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III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS
This Responsiveness Summary summarizes the comments received by EPA
concerning the Remedial Investigation (RI), the Feasibility Study
(FS) and the Proposed Plan for the Old Springfield Landfill site.
Eleven sets of written comments were received from residents, the
potentially responsible parties (PRPs), and the State of Vermont.
In addition, two residents offered oral comment during the public
hearing conducted by EPA on July 21, 1988. Copies of the hearing
transcript are available in the Administrative Record located at
the Springfield Public Library and the EPA Records Center in
Boston, Massachusetts.
The comments are summarized and organized into the following three
sections: 1) comments from citizens; 2) comments from PRPs; and 3)
comments from the State of Vermont.
This Responsiveness Summary contains all public comments received
during the public comment period on both source control and
management of migration alternatives described in the FS, but in
this document EPA responds only to those comments on the management
of migration decision that is the subject of this ROD. EPA will
respond to comments on source control alternatives for the site as
part of the development of a separate ROD addressing source control
issues at the site.
A. COMMENTS FROM CITIZENS
1. Comments on the Preferred Alternative
a) A resident asked if continued horizontal or vertical
migration of contaminants could occur if the proposed
alternative (capping) is implemented.
EPA Response;
Since this Record of Decision does not address source control,
EPA does not think it is appropriate to address this comment at
this time.
b) A group of residents asked that area wells be tested annually
or bi-annually for contamination after the Record of Decision
is signed. Residents also requested that the remedy include a
provision for the State to take independent well samples to
confirm EPA results.
EPA Response;
EPA has included in the Record of Decision (ROD) continued
monitoring of residential wells. The number and location of
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the authority to expend fund money to improve the aesthetic
quality of an area or alter the remedy to make it more
aesthetically pleasing unless it can be shown that such
improvements would be cost effective or more protective of .
human health and the environment.
f) A group of citizens living in the site area asked that EPA
treat contaminated groundwater from the site at an off-site
treatment facility, such as the Springfield municipal sewage
treatment plant. The comroenters stated that an on-site
treatment facility would be aesthetically detrimental to the
neighborhood around the site and would not be as economical as
treatment using the existing plant in town. One resident
expressed support for pretreatment of waste from the site prior
to treatment at the municipal treatment plant.
EPA Response;
EPA concurs that the treatment of groundwater at the
Springfield municipal sewage treatment plant may be more cost-
effective than the construction of a facility on site. At the
time of the release of the Proposed Plan, however, no
assurances had been made to EPA that the plant had the
willingness, capacity, or ability to treat the contaminants.
Since release of the Proposed Plan, the Town of Springfield has
demonstrated the willingness and confirmed the capacity to
treat the extracted groundwater and leachate at the Publicly
Owned Treatment Works (POTW). if the treatment and discharge
of the extracted groundwater and leachate meets all state and
federal requirements, and should treatment at the POTW prove
cost-effective, the groundwater and leachate may be treated at
the POTW. Pretreatment also may be implemented, if necessary,
to allow for treatment of the extracted groundwater and
leachate at the POTW.
Should the POTW not have the ability to treat the extracted
groundwater and leachate consistent with Federal and State
requirements, a treatment system would be constructed on site.
g) Residents requested that EPA design the cap to maintain the
current ground level rather than creating a higher elevation at
the site. The residents also asked that well-heads be capped
at ground-level to reduce maintenance and risk of injuries.
EPA Response;
See response to citizen comment A.I.a. above.
h) Residents asked that the proposed fence around the site enclose
the capped area only and not excavated areas north of the cap
11
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11-1
Exhibit 1
Old Springfield Landfill Site
Area of Proposed Cap
MoMtoHoiiM
I I MatUanoa
(///7/y Approximate Extant of Propoaod Cap
xTi Aroa* to be bceavatod and
iltX Plaeod In Capping ATM
—•— SltaFono*
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(See Exhibit 1). Residents also requested that warning signs
be posted along the fence at access points only.
EPA Response:
See response to citizen comment A.I.a. above.
i) Residents asked that EPA do everything in its power to make the
Old Springfield Landfill site a model for other remediation
efforts and provide for at least minor additional expenditures
to meet residents' concerns about the aesthetic impact of the
capped site. Residents encouraged cooperation among EPA, the
PRPs, and the State of Vermont to achieve a mutually
satisfactory and economically reasonable plan for site
remediation.
EPA Response:
EPA uses the same strict evaluation criteria to select remedies
for all Superfund sites to select the best remedy for each
individual site. EPA strives to select each remedy as a model
remedy for the specific conditions of each site.
As noted above this remedy does not address source control
(capping) ; however, as for EPA recommending "minor
expenditures" for aesthetic improvements, as stated previously,
EPA cannot use fund money for additional expenditures that
improve only the aesthetics of the remedy and are not legally
justifiable.
Regarding cooperation among EPA, the PRPs, and the State of
Vermont, the three parties have had and will continue to have
discussions about the site. EPA plans to continue these
discussions and informational exchanges after the ROD is
signed.
j) A resident suggested that excavation of outlying areas and
capping of the site be deferred until EPA can evaluate the
effectiveness of the leachate collection and treatment system
alone. The commenter suggested that EPA should allow rainfall
to flow through the site to "flush" contaminants into the
leachate collection system for a more cost-effective remedy
than constructing a cap.
EPA Response;
See response to citizen comment A.I.a. above.
12
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..
2. Comments Concerning Public Participation ?••
a) A group of residents asked for a summary in layman's terns of
the current and projected human health risks posed by
contamination at the site.
EPA Response;
At the public meeting conducted on July 21, 1988, EPA
distributed a public information fact sheet explaining the
purpose and results of the Endangerment Assessment performed by
EPA to identify human health and environmental risks posed by
contamination at the Old Springfield Landfill site. The fact
sheet also was mailed to all area residents and interested
parties on the site mailing list. The fact sheet listed an EPA
contact person to call or write for further information about
the Endangerment Assessment.
3. Comments Concerning Relocation
a) A resident asked when EPA first discussed the possible
permanent relocation of residents of -the Springfield Mobile
Home Estates.
EPA Response;
EPA has always maintained that relocation, either permanent or
temporary would be considered as part of the remedy for the Old
Springfield Landfill site, and would be evaluated in the FS for
the site. EPA announced its formal proposed plan to
permanently relocate residents of the Springfield Mobile Home
Estates at a meeting with residents, and a press conference
held June 23, 1988. EPA described its proposed remedy, which
included permanent relocation, in the Proposed Plan issued on
July 7, 1988. Since this Record of Decision does not address
source control, and since implementation for the source
control remedy necessitated relocation, resident relocation
will not be part of this Record of Decision, but will instead
be evaluated as part of a subsequent ROD to address source
control issues.
b) A former resident of the Mobile Home Park commented that she
and her husband had arranged with the potentially responsible
parties (PRPs) to sell their mobile home and move off the site.
During this move, the couple incurred significant personal
expenses in excess of the money they received for their mobile
home from the trust fund established by PRPs at the site to
facilitate the relocation of mobile home park residents. The
comroenter complained that the PRPs had not offered them the
same terms as had been offered to another resident whose hone
was purchased by the PRPs. The commenters also expressed their
13
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opinion that the Town of Springfield should never have allowed
the mobile home park to be built over the former landfill.
EPA Response;
Although EPA included permanent relocation as an element of the
proposed plan for the site, EPA will not be including permanent
relocation in this Record of Decision. Any purchases of mobile
homes are purchases between private parties in which EPA will
not intervene.
The construction of the mobile home park was made by the Town
of Springfield prior to the enactment of the Superfund laws.
c) Residents expressed support for the plan to permanently
relocate residents, and commented that a government agency, not
the PRPs, should conduct the relocation of site residents. A
resident questioned the methods by which PRPs settled on the
fair market value of residents' properties. The commenter
asked whether site residents who have not arranged to sell
. their property to the PRPs should approach the PRPs or EPA for
future relocation assistance and information.
EPA Response;
As stated above permanent relocation will not become a final
policy decision until a ROD addressing relocation is signed at
some future date. This ROD does not address relocation issues.
Prior to the source control ROD signing, all purchases are
between private parties and EPA has no authority to become
involved. If a ROD is signed which includes permanent
relocation, all remedial actions at the site will be conducted
by either EPA, in cooperation with the Federal Emergency
Management Agency (FEMA), or the PRPs working under EPA
oversight through a legal Consent Decree. Therefore, residents
who wish to sell their mobile homes prior to a ROD which
includes permanent relocation may wish to contact the PRPs.
4. Comments Concerning the Extent of Contaminant Migration
a) A resident asked whether the drilling of monitoring wells had
created any new pathways for contaminant migration.
EPA Response:
The potential for any monitoring wells to create new pathways
for contaminant migration is minimal. All wells were
constructed in a manner that minimizes the chances for vertical
contaminant movement. None of the wells actually drilled into
waste materials penetrated beyond the underlying materials upon
which waste materials were originally deposited. Additionally
all wells were constructed with the steel augers. As the
14
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augers were removed, the space surrounding the well was grouted
with cement.
b) Residents asked that EPA compose individual letters to each
resident in the area describing any contamination or other
negative impact that the site or site cleanup may have on his
or her property.
EPA Response;
Nearly all samples collected during the Remedial Investigation
were confined to the Springfield Mobile Home Estates. A
limited number of samples were collected from nearby
residential wells, and some soil sampling was done on
residential property. Results from all samples were reported
in the Remedial Investigation Report, which is available in the
site information repository at the Springfield Public Library.
Two soil samples were collected from the property immediately
to the south of the site. No contaminants were detected in
these samples. Four samples were collected from the properties
west of the site adjacent to Will Dean Road. In three of these
samples, no contaminants were detected. Levels of volatile
organic chemicals significantly below federal standards (less
than 1 part per million) were detected in one sample collected
along Will Dean Road.
Nine domestic wells were sampled for organic and inorganic
substances. Low levels (less than .05 parts per million) of
organic chemicals were found in four wells, representing low
risk values. Two of the wells are located upgradient of the
site, and are therefore not in the path of contaminant
migration. With the exception of one well located on Route 11,
none of the contaminants detected in the sampled domestic wells
were contaminants that are found on site. The Route 11
residence has since been connected to the Springfield municipal
water supply.
Once design of the remedy is complete, EPA will be able to
inform residents of potential impacts, such as noise or truck
traffic, that construction of the remedy may have on the
community.
EPA does not assess the economic impact that Superfund sites
have on adjacent properties, and therefore is not able to
comment on any effects that proximity to the site may have on
property values. (See response to Comment A.5.a., below.)
•
c) Several commenters asked whether EPA's site investigations
identify the full extent of vertical and horizontal migration
of contamination.
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EPA Response:
The investigation of a hazardous waste site is primarily an
effort to sample a natural environment which is always dynamic,
extremely variable in composition from place to place, and very
large in comparison to the volume of samples that can be
collected. Because the entire environment cannot be sampled,
the full extent of contamination will never be known to its
exact limit. However, the objective of any such investigation
is not to determine the absolute limit of contamination, but to
obtain a representative understanding of how contaminants are
distributed so that risks to human health can be estimated and
cleanup alternatives can be designed with a reasonable degree
of certainty. At the Old Springfield Landfill site, it has
taken nearly three years and over 500 environmental samples to
achieve such an understanding. These investigations have
resulted in a good understanding of the extent of contamination
at the Old Springfield Landfill site, allowing EPA to make its
decision on a site remedy. The potential for additional
sources of contamination and undetected migration pathways to
exist is small. Even so, future cleanup remedies will include
monitoring to safeguard against the possibility of undetected
contamination.
5. Comments On the Future Impact of the Site on Property Values
and Land Use
a) Off-site residents living near the site asked whether EPA would
place any restrictions on the future use of their property or
wells as a result of contamination from the Old Springfield
Landfill site.
EPA Response;
The selected remedy includes restricting the use of groundwater
where residual contamination may exceed maximum contaminant
levels (MCLs). EPA recommends to the State and Town of
Springfield that they implement and enforce ordinance 88-2
passed by the Town of Springfield. Ordinance 88-2 gives the
Town of Springfield control over the use of any hazardous waste
sites in the town. Specifically, EPA recommends prohibiting
groundwater use in the area bounded by Route 11 on the east,
Mr. Curtin's present property boundary on the south, Seavers
Brook Road on the west, and Mr. Curtin's present property
boundary on the north until such time that groundwater levels
fall within MCLs.
•
b) Residents asked whether proximity to the site affects the fair
market value of their property. Residents also requested that
EPA prepare local property impact statements, which would be
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similar to environmental impact statements, to be used during
the evaluation of remedial alternatives.
EPA Response:
As already noted, EPA's authority at a Superfund site is
limited to activities that protect human health and the
environment. EPA does not assess the economic impact that
Superfund sites have on adjacent properties. Because the site
is not likely to be the only factor affecting property values
in the area, the Town of Springfield may better be able to
address questions related to property value assessments within
its borders.
c) Residents suggested that, to avoid problems associated with
absentee ownership, the ownership of the site should be
transferred to the Town of Springfield since the Town will be
responsible for long-term maintenance of the site.
EPA Response:
EPA will determine the party who will be responsible for long-
term maintenance of the site through negotiations between EPA
and the PRPs, including the Town of Springfield. If no
agreement can be reached, EPA can implement the remedy using
Superfund money, and the State of Vermont would be responsible
for operation and maintenance of the remedy.
d) Residents asked that EPA build flexibility into the ROD to
ensure funding to address any new areas of contamination that
may be detected during future EPA cleanup activities at the
site.
EPA Response:
Since the remedy is an operable unit for seeps and limited
groundwater contamination, and does not include a remedy for
source control, EPA will continue its investigation of
contamination at tie site. If the total remedy is not a
permanent remedy, under the Superfund law it will be re-
examined every five years to evaluate whether any modification
of the remedy should be implemented to protect human health and
the environment in the vicinity of the site.
B. COMMENTS FROM THE PRPs
Written comments were submitted by the law firm of Breed, Abbot,
and Morgan, and by REMCOR, consultants to Textron, Emhart
Corporation, and the Town of Springfield who are some of the PRPs
at the site. The full text of these written comments, and detailed
17
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EPA responses, is appended as Attachment B of this document. Below
is a summary of PRP comments and EPA responses.
1. Comments on the Preferred Alternative
a) The selection of the 10"7 incremental cancer risk as the target
risk level does not appropriately reflect site characteristics
and is not consistent with recent EPA Region I policy at other
sites.
EPA Response;
EPA did not select the 10"7 incremental cancer risk as the
target risk for this operable unit for seeps. EPA chose target
risk levels between 10"4 and 2 x 10~6 for groundwater cleanup,
which are within the risk range of 10-4 to 10-7 for Superfund
remedies. These target risk levels are consistent with recent
EPA Region I policy at other sites.
Because this remedy does not address source control, EPA does
not this it is appropriate to address this comment at this
' time.
b) The Remedial Investigation does not support the need for the
capping of the landfilled wastes to protect against future
ingestion of bedrock ground water to the east of the former
landfill. EPA's calculations regarding contaminant migration
into the bedrock aquifer and air are erroneous. EPA's
calculations concerning exposure to contaminants through
consumption of fish from the Black River are erroneous.
EPA Responsei
Because this remedy does not address source control, EPA does
not think it appropriate to address this comment at this time.
c) The Remedial Investigation does not support the need for
capping landfilled wastes to protect against off-site exposure
to contaminants via inhalation of chemicals in landfill gas.
EPA Response;
See response to PRP comment B.l.b. above.
d) The outslopes of the former landfill should not be capped.
"Response t
See response to PRP comment B.l.b. above.
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e) The potential risk associated with contact with contaminated
surface soils suggests covering and fencing approximately 1.5
acres of the former landfill to address a target risk level of
10~6, rather than constructing the eight acre-cap described in
EPA's Proposed Plan.
EPA Response;
See response to PRP comment B.l.b. above.
f) The data do not support the need for the cap proposed by EPA.
The Record of Decision should specify performance objectives
rather than a detailed cap configuration.
EPA Response;
See response to PRP comment B.l.b. above.
g) The data developed in the Remedial Investigation do not support
the need for excavation of areas beyond the limits of the
former landfill and consolidation of these materials under the
proposed cap.
EPA Response;
See response to PRP comment B.l.b. above.
h) The design of the leachate collection system on the eastern
side of the site should be modified to address collection of
those seeps evidencing contamination, and the instability of
the eastern outslopes should be considered in locating the
collection system.
EPA Response;
As part of the final remedy for the site, EPA will require the
collection of all leachate seeps on the eastern and western
slopes of the site. The actual design of the leachate
collection system will be completed during the remedial design
phase of the cleanup. In addition, EPA has specified certain
performance objectives for the leachate collection and
treatment system in the ROD.
i) Placement of interceptor wells along Will Dean Road into the
sand and gravel water bearing zone should be reevaluated.
EPA Response;
EPA recognizes that sufficient data for the final design of the
well extraction system currently is not available. Further
evaluation is recommended in the FS (see the FS report, p. 7-
127). Specific items to be designed include the number of
extraction wells, well placement, and extraction rates.
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However, some wells will be installed tc address groundwater
contamination in the Will Dean Road area identified in this
comment.
j) Leachate (and extracted groundwater) from the site should be
pretreated and discharged to the Springfield Publicly Owned
Treatment Works (POTW) or to a new facility built on land
adjacent to the municipal treatment plant, rather than
discharged directly to surface drainage following on-site
treatment.
EPA Response;
See EPA response to the citizen comment in section A.l.f. of
this document.
X) The slurry wall proposed by EPA as an option within the
preferred alternative would have limited effectiveness.
EPA Response:
As part of this ROD, additional studies will be done to
determine the feasibility of diverting groundwater from contact
with the waste. The evaluation for the effectiveness a slurry
wall will be determined at that time.
1) The seep collection system and treatment plant should be
designed after the ROD is signed, during the design phase of
the remedy implementation.
EPA Response!
The seep collection will be designed after the ROD is signed to
meet the objectives outlined in the ROD. As stated above, in
the ROD for the site EPA expresses a preference for use of the
POTW and would require construction of a new treatment facility
only if the criteria outlined in the ROD cannot be met.
2. Comments on Enforcement Issues
a) If there is a basis for the suggestion by the State of Vermont
that there are uncertainties regarding the ownership and
operation of the landfill, Emhart Corporation and Textron would
like an opportunity to submit additional comments and evidence
to EPA on this issue.
•
EPA Response;
EPA welcomes efforts to provide pertinent information.
20
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b) The Participation Agreement among Esihart, Textron, and the Tcwn
of Springfield provides a structure for cooperation among the
parties, while specifically disclaiming any binding allocation
of responsibility with respect to the site. The agreement to
date is limited to such matters as relocation of residents'and
conduct of technical activities and does not in any way address
the remedy to be adopted at the site.
EPA Response:
EPA was and is not a party to the participation, agreement among
the PRPs and therefore offers no response to this comment.
C. STATE OF VERMONT COMMENTS
The full text of comments offered by the State is appended as
Attachment C of this document.
1. Extent of Contamination
a) EPA should further investigate the bedrock hydrogeology east of
the site to ascertain whether contamination in the bedrock may
represent an additional exposure pathway and whether extraction
and treatment of the groundwater from the bedrock might be
necessary. Also, if all of the contaminated groundwater moving
through the sand and gravel unit discharges into the western
seeps, then it appears that the extraction wells may not be
necessary.
EPA Response;
EPA's current findings indicate that contamination has not
reached bedrock east of the site. As part of the long-term
monitoring of the site, the ROD prescribes the installation and
monitoring of additional bedrock monitoring wells. These wells
will be designed to ascertain whether contamination may be
present in the bedrock and to detect potential contamination in
the future. It is EPA's practice to extract and treat
contaminated groundwater where feasible. EPA intends to place
groundwater extraction wells in a highly permeable zone at the
Old Springfield Landfill site to facilitate the cleanup of
groundwater in the area.
b) EPA should investigate and define waste disposal areas on the
western side of the site to identify any potential risk and
determine whether any remedial action is warranted.
•
EPA Response:
The ROD includes a provision for exploration of waste disposal
areas on the western slopes of the site and an area of the
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southwest portion of the site as indicated by geophysical
techniques used in the Remedial Investigation.
2. The Preferred Alternative
a) EPA should provide a clearer explanation of how it determined
the depths to which EPA would excavate contaminated soil from
outlying areas of the site. EPA also should specify the depths
to which contaminants from sloped sections of Waste Areas 2 and
3 would be excavated, and how EPA would resolve the potential
problem of continued leaching from contaminants left beneath
the excavated areas.
EPA Response:
See response to PRP comment B.l.b. above.
b) It may be possible that with proper pre-treatment the
Springfield sewage treatment plant may be able to accept
collected leachate from the site. The Vermont Department of
Environmental Conservation notified EPA that additional
information is necessary for DEC to determine if the town
treatment plant can be used as part of a more cost-effective
remedy.
EPA Response:
See EPA response to citizen comment A.l.f., above.
c) The proposed remedy relies heavily on future operation and
maintenance activities that could place a large burden on the
resources of the State of Vermont and the Town of Springfield.
Because operation and maintenance activities may have to be
continued indefinitely into the future, the proposed remedy may
not meet the requirement for a permanent remedy.
EPA Response;
See EPA response to citizen comment A.I.e. above.
2. Cost Allocation
a) There is a lack of information to conclusively resolve the
historic ownership and operation issues and resulting
allocation of costs for site remediation.
•
EPA Response:
It is EPA's current understanding that the site was operated by
the Town of Springfield. Issues related to making a
determination of the allocation of costs of the site cleanup
22
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among the PRPs will be addressed during negotiations between
EPA and the PRPs after the signing of the ROD.
IV. SUMMARY OP CONCERNS RAISED DURING THE INFORMAL QUESTION AND
ANSWER PERIOD OF THE JULY 21,1988 PUBLIC MEETING AND EPA
RESPONSES
The following section summarizes questions asked after the close of
the portion of the July 21, 1988 public meeting devoted to
accepting formal public comment. EPA is responding to these
informal questions in this document to address issues of concern to
the community that were not raised as part of the formal public
comment process.
A. Comments on Health Studies
1) A resident asked whether the State of Vermont monitored the
health of residents at EPA Superfund sites.
EPA Response:
The State of Vermont does not have any program to monitor the
health of residents in the vicinity of federal Superfund sites.
B. Comments on the Preferred Alternative
1) A resident asked EPA to improve a deteriorated section of
roadway leading to the site during the implementation of the
remedy.
EPA Response!
Improving road conditions goes beyond EPA's authority to
cleanup the waste at the site. Road maintenance is an issue
that the Town of Springfield may better be able to address.
2) A resident asked whether the preferred alternative proposed for
the Old Springfield Landfill Site has been successfully
implemented at similar Superfund sites elsewhere in the United
States.
EPA Response;
Because each site is different and presents unique challenges,
the success or failure of a remedy at one site cannot be used
to predict the likelihood of success or failure at another.
However, leachate collection and groundwater extraction are
remedial actions that are commonly used as parts of groundwater
cleanup at Superfund sites.
23
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3) A resident asked when cap construction would begin if EPA
selects a cap as part of the site remedy.
EPA Response:
Because this remedy does not address source control, EPA is
unable at this tine to predict when a source control remedy
would be selected and implemented.
4} Residents were concerned about the aesthetic impact of the cap.
i.e., what kind of fence and vegetation would be used and
whether trees could be planted on or around the cap.
EPA Response;
Since this ROD does not address source control, EPA is unable
to address this comment at the present time.
5) Residents asked whether EPA could implement cleanup innovations
perfected in the future, if a cap is used as the current remedy
for the Old Springfield Landfill site.
EPA Response;
See EPA response to comment IV.B.4. above.
6) What effect will the groundwater cleanup activities have on
groundwater levels south of the site.
EPA Response;
The passive collection of the seeps at the point of emanation
will not have an effect on groundwater levels south of the
site. The active pumping at an estimated 15 gallons per minute
(gpm) from the wells in the sand and gravel zone on the west
side of the site should not have a detectable influence on off-
site wells south of the site.
C. Comments on the Public Participation Process
1) Several residents wanted to know how EPA would respond to
comments offered during the public comment period and whether a
public meeting could be held to discuss EPA's responses to all
comments.
EPA Response;
EPA summarizes and responds to public comments received during
the comment period in this Responsiveness Summary, which is
issued with the ROD* The Responsiveness Summary presents a
brief summary of the information that EPA used to evaluate the
public comments received during EPA's decision-making process
24
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toward drafting the final cleanup approach described in ROD for
the site. Both the ROD and Responsiveness Summary are
available to the public as part of the Administrative Record
for the site available at the Springfield Public Library and
EPA Records Center in Boston, Massachusetts.
EPA considered all comments received during the public comment
period in carrying out its responsibility to select a remedy
that meets EPA's nine criteria for remedial alternatives.
These criteria are:
1. Overall Protection of Human Health and the Environment;
2. Compliance with Applicable or Relevant and Appropriate
Requirements;
3. Long-tern Effectiveness and Permanence;
4. Reduction of Toxicity, Mobility, and Volume;
5. Short-term Effectiveness;
6. ImplementaJaility;
7. Cost;
8. State Acceptance; and
9. Community Acceptance.
Because often no single alternative meets each of these nine
criteria equally, EPA selects the alternative that would
achieve the best balance among the nine criteria.
In response to the request of area residents, EPA will hold a
public meeting to discuss the ROD and Responsiveness Summary
during the fall of 1988, after the signing of the ROD.
2) A resident suggested that EPA work with residents, PRPs, and
the State of Vermont to gather information about the site and
to develop an appropriate cleanup response to site
contamination.
EPA Response;
EPA has worked with residents, the PRPs, and the State of
Vermont throughout the site investigation and evaluation of
cleanup alternatives for the site. As one of the first steps
in EPA's Remedial Investigation of the site EPA placed
newspaper advertisements asking that anyone with information
about the site come forward. EPA conducted geophysical and
other investigations of the site to verify and build on
information gathered during interviews with residents conducted
during 1984 and 1986. EPA has invited comment and input from
all interested parties, including the PRPs and the State, at
numerous public meetings and through information fact sheets
distributed to area residents and interested parties throughout
the process of investigating and evaluating remedial
alternatives for the site. In addition EPA has made documents
and technical reports related to EPA activities at the Old
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Springfield Landfill site available to the public at the
information repository at the Springfield Public Library.
3) A resident asked for an explanation of the way the criteria of
State and Community Acceptance are factored into EPA's final
selection of a remedy for the site.
EPA Response:
Because community residents may offer divergent comments on the
Proposed Plan, EPA must gauge whether there is a majority view
among the community, based on the number and content of
comments received. EPA weighs community comments and the
State's comments as two of the nine factors to consider in
selecting a remedy for site contamination. EPA does not retain
or reject a remedy, however, based on how well the remedy meets
any single criteria, but rather on how well the remedy meets
the sum of the nine criteria. (See comment IV. C. 1. for the
list of nine criteria.)
4) Commenters asked if the comment period could be extended beyond
August 8, 1988.
EPA Response;
EPA extended the public comment period to August 24, 1988.
Notice of the extension was mailed to all interested parties
and announced in local newspapers serving the Springfield area.
5) Residents asked to continue to receive information about the
schedule for site cleanup activities.
EPA Response;
Once the design phase of implementing the remedy is underway,
EPA will revise the community relations plan that was prepared
for the site in 1985 to identify any new or emerging concerns
that can be addressed through specific community relations
activities. The revised community relations plan will discuss
community concerns and outline the activities through which EPA
will continue to provide information on site activities to the
public during the design and implementation of the remedy.
€) A resident asked to receive copies of the comments EPA receives
during the public comment period.
EPA Jtesoonset
EPA has forwarded copies of the comments received to the
parties that requested them. A transcript of oral comments
offered at the hearing, as well as copies of the written
comments received during the public comment period, are
26
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available for public review at the Administrative Record &t the
Springfield Public Library and at the EPA Records Center at
Region I EPA Headquarters, 90 Canal Street, Boston,
Massachusetts.
D. Comments on the Contaminant Migration
1) A resident asked if the Blue Grass Hills Condominium properties
have been contaminated by the site and if there is any danger
to children playing around the condominiums.
EPA Response;
EPA has found that the condominium properties have not been
contaminated by the site. Also, the condominiums have always
been supplied by town water, so there would be no current
health risk to condominium residents due to ingestion of
groundwater.
2) A resident asked whether there is a danger of explosion from
methane gas generated by the landfill wastes.
EPA Response;
All landfills generate methane gas, which should present no
threat of explosion as long as a gas venting system is
installed as a way to control the buildup of methane beneath
the landfill surface.
V. REMAINING CONCERNS TO BE ADDRESSED BY EPA
Many of the comments offered during the public comment period
concerned issues that EPA could not address fully prior to the
development of a ROD for the source control operable unit, or prior
to the design activities that will follow the signing of the ROD
for the management of migration operable unit for seeps at the
site. Although these issues are addressed individually in EPA's
responses to comments in Section III of this Responsiveness
Summary, these items are grouped together in this section as
remaining concerns because they include concerns that can be
addressed more fully by EPA after the completion of investigations
necessary for the development of the exact designs for remedy
implementation.
The issues to be addressed through future EPA activities are
•
outlined below.
A. Design of the Cap
27
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Because this remedy does not include capping of the site, EPA
is unable to address this issue.
B. Restrictions on Site Use
EPA will identify restrictions on site use that nay be
necessary to protect the integrity of the design implemented at
the site. EPA will recommend restrictions on construction and
on the use of groundwater in the area.
C. Design of the Leachate and Seep Collection and Treatment System
Items to be resolved during studies to design the leachate and
seep collection system include 1) the exact locations for
leachate and seep collection around the site, 2) the number,
placement, and rates of extraction for veils to extract
contaminated groundwater for treatment, and 3) the feasibility
of using the town sewage treatment plant to treat collected
' leachate from the site.
D. Residential Well Monitoring
EPA will determine the number and location of residential wells
to be monitored for contamination, as requested during the
comment period, as part of the studies undertaken to design the
site remedy.
F. Relocation Assistance
Since this remedy does not address resident relocation, EPA is
unable to address this issue.
E. Cost Allocation
The allocation of costs of the cleanup among PRPs will be
determined through negotiations between the PRPs and EPA.
As soon as possible after EPA has designed the remedy, EPA will
hold a public meeting and release a fact sheet to address the
issues outlined above related to the remedy selected for the
management of migration operable unit for seeps.
28
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ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES AT THE
OLD SPRINGFIELD LANDFILL SITE
SPRINGFIELD, VERMONT
Community relations activities conducted at the Old Springfield
Landfill site to date have included:
o August 1983 - EPA conducted a public meeting to present
information about EPA's planned Remedial Investigation of
the site.
o July 1984 - EPA conducted interviews with community
residents to prepare a community relations plan. The
community relations plan, released in February 1985,
describes citizen concerns about the site, and outlines a
program to address these concerns and to keep citizens
informed about and involved in site activities.
o September 1985 - EPA conducted a public meeting in
Springfield to present the results of the Remedial
Investigation.
o October 16, 1986 - EPA conducted a public meeting to present
the Summary Report on the results of the first phase of the
site investigation and EPA's work plan for further site
investigation activities. EPA released a fact sheet
summarizing the results of the Summary Report to those
present at the meeting and to the site mailing list of
residents requesting written information about the site.
o June 2, 1987 - EPA met with the residents of the Springfield
Mobile Estates to discuss EPA plans to conduct a temporary
relocation of mobile home park residents during
investigations to be conducted in the vicinity of mobile
homes on the site. Following the public meeting, EPA
conducted a press conference. Concurrently, EPA released a
brief written update for residents attending the meeting and
for those on the site mailing list.
o June 11, 1987 - EPA conducted a public meeting to discuss
EPA's planned on-site investigation and temporary relocation
of residents and to answer questions from the community.
o July, 6 - July 18, 1987 - A representative of the Federal
Emergency Management Assistance Agency (FEMA) remained at
the motel where residents had been relocated to assist
residents during the temporary relocation. EPA officials
met with residents during the relocation to answer questions
29
-------
about the progress of the investigation during the temporary
relocation.
July 11, 1987 - EPA established an information hotline for
residents to call for updates on EPA activities at the site
and for residents to leave questions and comments for EPA.
EPA continues to monitor the hotline and returns calls as
soon as possible after they are received.
March 29, 1988 - EPA conducted a public meeting to present
the results of the Supplemental Remedial Investigation (RI),
discuss the schedule for future EPA activities, and answer
questions from the community. Concurrently, EPA released a
fact sheet on the Supplemental RI results and upcoming EPA
activities to those attending the meeting and the site
mailing list.
June 23, 1988 - EPA officials met with individual residents
of the mobile home park to discuss EPA's recommendation for
permanent relocation of mobile home park residents as part
of the Proposed Plan for site cleanup. EPA also conducted a
press conference to announce its recommendations for
permanent relocation of residents and the site cleanup.
July 7, 1988 - EPA conducted a public meeting to present the
results of the Feasibility Study (FS) and Proposed Plan, and
answer questions from the community. EPA released its
Proposed Plan to those attending the meeting and to the site
mailing list.
July 8 - August 24,1988 - EPA conducted a public comment
period to accept oral and written comments for the FS and
Proposed Plan. EPA conducted a mailing to all those on the
site mailing list to announce the extension of the comment
period from August 8 to August 24th.
July 21, 1988 - EPA conducted a public hearing to accept
formal oral comment and answer questions from the community.
At the hearing, EPA released a fact sheet presenting the
results of EPA's Endangerment Assessment of risks from the
site to human health and the environment. The fact sheet
was also mailed to persons on the site mailing list.
August 1, 1988 - EPA met with concerned citizens in the area
to listen to comments and concerns.
August 19, 1988 - EPA held an informal discussion with
residents regarding recent progress at the site.
30
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ATTACHMENT B OF RESPONSIVENESS SUMMARY
BREED, ABBOTT & MORGAN
INTCftNATlONAL COUAMC
1875 EYE STREET. N.W.
WASHINGTON. D.C.2OOO6-S47I
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(202) 466-1104
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August 23, 1986
VIA FEDERAL EXPRESS
Ms. Paula Lia Fit2Simmons
Remedial Project Manager
U.S. Environmental Protection Agency
Hazardous Waste Division (HPS-1)
JFK Federal Building
Boston, HA 02203
RECEIVED
24 88
WEiVTWiSTE
MANAGEMENT BRANCH
Re: Old Springfield Landfill CERCLA Site,
Springfield, Vermont
Dear Ms. Fitzsimmons:
On behalf of Emhart Corporation and Textron Inc.V we are
submitting these comments for inclusion in the Administrative
Record for the Old Springfield Landfill site in Springfield,
Vermont. These comments supplement comments submitted under
separate cover on behalf of Emhart, Textron and the Town of
Springfield.
In its written comments and during the public hearing on
July 7, 1988, the State of Vermont suggested that issues regarding
state funding obligations under S 104(c)(3) of CERCLA cannot be
resolved due to uncertainties regarding the ownership and opera-
tion of the Old Springfield Landfill. We cannot understand the
basis for this comment since we are not aware of any uncertainties
regarding the fact that the Old Springfield Landfill was operated
as a public municipal landfill by the Town of Springfield. The
Town operated the site for over 20 years pursuant to a 1947 lease
agreement with the site owners. If there is a basis for the
suggestion by the State of Vermont that there are uncertainties
regarding the ownership and operation of the landfill, we would
like an opportunity to submit additional comments and evidence to
.the Agency on this issue.
-------
Ms. Paula Li a Fitzsimmons
August 23, 1988
Page 2
Secondly, we would like to call EPA's attention to the
Participation Agreement between Emhart, Textron, and the Town of
Springfield with respect to this site. We are aware that public
comments have been made to the effect that this Agreement allo-
cates responsibility between the parties with respect to this site
and, specifically, that the Agreement allocates responsibility for
the remedy to be adopted at the site. On the contrary, this
Agreement merely provides a structure for cooperation among the
parties, while specifically disclaiming any binding allocation of
responsibility with respect to the site. Furthermore, the agree-
ment to date is limited to such matters as relocation of residents
and conduct of technical activities; it does not in any way
address the remedy to be adopted at the site.
Yours truly,
Barry L. Malter
BLM/lc
cc: Ms. Linda Biagioni
Mr. Paul Duff
John Parker, Esq.
Mr. William Steele
Daniel Squire, Esq.
William Kalsh-Rogalski, Esq.
Mr. David Webster
Jerome C. Muys, Jr., Esq.
-------
ATTACHMENT B OF RESPONSIVENESS SUMMARY
BREED, ABBOTT & MORGAN
INTERNATIONAL SOUAHC
1675 EYE STREET. N.W.
WASHINGTON. O. C. 2OOO6-547I
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kwiCt»«»t«»« J»»lt B. H»i«
August 23, 1988
VIA FEDERAL EXPRESS ' H E C EI V E i>
Ms. Paula Lia Fitzsimmons
Remedial Project Manager "^ ^ A. 8^
U.S. Environmental Protection Agency
Hazardous Waste Division (HPS-1) ME&VTWASTE
|JFK Federal Building MANAGEMENT BRANCH
Boston, MA G2203
Re: Old Springfield Landfill CERCLA Site,
Springfield, Veritont
Dear Ms. Fitzsimmons:
The enclosed document, together with the accompanying
report by REMCOR, Inc., constitutes the comments of Emhart Corpor-
ation, Textron Inc., and the Town of Springfield on the Draft
Final E/idangerment Assessment, the Draft Final Supplemental
Remedial Investigation Report, the Draft Final Feasibility Study
Report, and the Preferred Remedial Alternative for the Old Spring-
field Landfill site in Springfield, Vermont. We'ask that these
comments be included in the administrative record for the site.
Yours truly.
Barry L. Malter
BLM/lc
Enclosure
cc: William WalsW-Rogalski, Esq.
Mr. David Webster
-------
COMMENTS OF EMHART CORPORATION, TEXTRON INC., AND THE
TOWN OF SPRINGFIELD ON THE DRAFT FINAL ENDANGERMENT
ASSESSMENT, THE DRAFT FINAL SUPPLEMENTAL REMEDIAL
INVESTIGATION REPORT, THE DRAFT FINAL FEASIBILITY STUDY
REPORT, AND THE PREFERRED REMEDIAL ALTERNATIVE FOR THE OLD
SPRINGFIELD LANDFILL SITE, SPRINGFIELD, VERMONT
This document and the accompanying report by
Remcor, Inc. (which is incorporated herein by reference)
constitute the comments of Emhart Corporation, Textron Inc.,
and the Town of Springfield on the Draft Final Endangerment
Assessment ("EA"), the Draft Final Supplemental Remedial
Investigation Report ("RI"), the Draft Final Feasibility
Study Report ("FS"), and the "Preferred Remedial Alternative"
for the Old Springfield Landfill Site in Springfield,
Vermont. We ask that these comments, together with our
June 8, 1988 submission regarding proposed remedial action at
the site, all of our previous correspondence regarding this
site, and transcripts and videotapes of all public hearings
and meetings be included in the administrative record.
Emhart, Textron, and the Town of Springfield are
concerned about site conditions and the welfare of community
residents. We have repeatedly demonstrated this concern,
even prior to the time that the Environmental Protection
Agency ("EPA") designated us potentially responsible parties
("PRPs"), and even prior to EPA's issuance of requests for
information under the Comprehensive Environmental Response,
Compensation, and Liability Act ("CERCLA" or "Superfund").
RECEIVED
WJ 2 4 ^
ME & VT WASTE
timGEUENT BRANCH
-------
In 1984, we voluntarily extended the municipal
water supply to the Murphy residence and, about the cane
tine, we voluntarily offered to perform site studies (the
"RI/FS"). More recently, we voluntarily implemented a
permanent relocation program, establishing a trust fund to
purchase from the residents of Springfield Mobile Home
Estates mobile homes at prices suggested by the residents or
at fair market value established by independent appraisers.
When EPA announced its recommendation for a permanent reloca-
tion on June 23, 1988, we had already assisted in the reloca-
tion of 12 families and vere well under way in providing
relocation assistance to an additional 16 families.
On June 8, 1988, prior to EFA's announcement of its
preferred remedial alternative, we submitted a proposal to
perform remedial work at the site. Our proposal included
collection and treatment of contaminated seeps on the eastern
and western portions of the site, in a manner similar (though
not identical) to the seep collection and treatment proposals
announced by EPA on June 23. Our proposal also included
measures to prevent direct contact with contaminated soils,
including access restrictions and covering those areas of the
site which, according to our technical consultants, could
pose risks of direct contact.
We strongly support EPA's recommendation for seep
collection and treatment, and believe such measures should be
undertaken without undue delay. However, the Record of
-2-
-------
Decision ("ROD") should provide for collection of contar.i-
nated seeps only, with provision for periodic monitoring of
additional seeps and expansion of the collection system, if •
warranted by monitoring data. Moreover, collection system
design details should not be specified in the ROD, but should
be left to the remedial design phase of the project. Our
primary concern is that the collection system design proposed
by ZPA nay not be practical or constructive and say be
unnecessarily difficult to maintain in light of the histori-
cal instability on the eastern slopes of the site. In
addition, community residents are concerned about aesthetic
values, and the construction of the collection system pro-
posed by EPA will result in the loss of more forested areas
than the system we proposed. These considerations can be
taken into account during remedial design activities.
Similarly, the details of the seep treatment system
need not be specified in the ROD. To provide maximum flexi-
bility, the ROD should require treatment either at the Town
of Springfield's Municipal Treatment Plant (with appropriate
pretreatment, if necessary), or on the site, ituelf.
Although we proposed on-site pretreatment systems similar to
the on-site system recommended by EPA, we believe that
attempts should be made to accommodate the community's
concern for aesthetic considerations. It may be possible to
locate the treatment system on land adjacent to the Municipal
Treatment Plant, and Emhart, Textron, and the Town of Spring-
-3-
-------
field have begun to explore that possibility. The ROD should
not foreclose a desirable result.
With respect to other remedial measures, we take '
issue with the proposed eight-acre, multi-layer, low permea-
bility cap (including synthetic membranes) and the proposed
excavation of approximately 25,000 cubic yards of materials
for placement under the cap (19,000 cubic yards from outsiope
areas prefatory to cap placement on the outslopes and 6,000
cubic yards from other areas of the cite). These measures,
according to the Agency, are proposed to protect against
risks of ingestion of bedrock groundvater east of the land-
fill, consumption of Black Fiver fish, and inhalation of
landfill gases. These risks, however, are unsubstantiated.
Despite the passage of 40 years since waste was first deposi-
ted on the site, the bedrock aquifer to the east of the site
is uncontaminated and fish tissue studies revealed no site-
related contamination in Black River fish. Additionally, EPA
was unable to document contaminants of concern in landfill
gases.
The risk assessments allegedly supporting EPA's
proposed $12.5 million remedial program, including excavation
and capping, are based on a number of erroneous assumptions,
incorrect calculations, and highly unrealistic exposure
scenarios. For example, EPA's calculation of target soil
•
cleanup levels to mitigate against risks of groundwater
ingestion is based on an overstatement of the amount of
-4-
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contaminants predicted to leach from the wastes into the
shallow groundvater, an overstatement of the amount of
contaminants expected to reach bedrock groundwater, and a
failure to consider fundamental environmental transport and
fate processes including dilution/ dispersion and adsorption.
Similarly, the Agency's calculation of coil cleanup target
levels to mitigate the risXs of inhalation of landfill gases
fails to consider the characteristics of the municipal solid
vaste/soil mixtures on the site, overstates the emission
source area by a factor of seven (using maximum contaminant
concentrations found anywhere on the site as representative
of the entire site), and assumes an emission rate which, if
accurate, would result in the depletion of contaminants of
concern in the source area within a matter of hours.
The exposure scenarios in EPA's risk assessments do
not reflect reality. For example, the inhalation exposure
assumed by EPA is based on site residents remaining outside
and breathing every breath from birth to age 70 in the
vicinity of the highest contaminant levels found at the site.
Vith respect to consumption of Black River fish, EPA assumes
that the exposed population consumes contaminated fish from
the Black River (which the data show to be uncontaminated)
every day over a 70-year lifetime.
Finally, EPA uses as the target risk level a value
•_.•.
of 10 ( i.e.. one additional case of cancer in an exposed
population of ten million) to calculate cleanup levels in
-5-
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soils. However, according to EPA policy, risks within a
range of 10* to 10* are considered acceptable (one excess
cancer in an exposed population of 10,000 to one excess
cancer in an exposed population of 10,000,000.) The Office
of Technology Assessment of the Congress of the United States
has cited with approval the fact that the target level most
frequently used by EPA is 10 (one excess cancer in an
exposed population of 1,000,000). We are not aware of any
other sites where EPA Region I has selected target risk
levels other than lo"5 or 10~6.
EPA's calculations, assumptions, and exposure
scenarios result in target soil cleanup levels which are far
below the limits of analytical detection. In addition, as
EPA itself recognizes, almost all of the target cleanup
levels for soils at the site are within the natural back-
ground levels for forest soils. For example, the natural
background level of polynuclear aromatic hydrocarbons in
forest soils is 550 times greater than the target cleanup
level selected by EPA. And the PCS soil target level
selected by EPA for the Old Springfield Landfill is 1,800,000
times lower than the level selected by EPA Region I five
months ago for a site in Massachusetts. A risk assessment
which calls for remediation of contamination at any location
where a contaminant of concern is detected, regardless of
•
background levels, is one that has gone grossly awry.
-6-
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The flaws discussed above are found throughout the
various documents produced by EPA. Rather than commenting on
the documents separately, we have organized our comments in
the following Banner:
I. Comments on Calculation of Target Cleanup
Levels in Soil
ZI. Comments on Cap as Component of Preferred
Alternative
III. Comments on Collection and Treatment of
Contaminated Seeps
IV. Comments on Groundwater Pumping and Treating
V. Comments on Slurry Wall as Possible Component
of Remedy
VI. Conclusion
I. CALCULATION OF TARGET CLEANUP LEVELS IN SOIL
X. EPA's Calculations Regarding Contaminant Migration
Into The Bedrock Aquifer Are Erroneous
As a component of its "preferred remedial alterna-
tive" for the Old Springfield Landfill Site, EPA proposes to
install a low permeability cap over approximately eight
acres, and to excavate approximately 25,000 cubic yards of
materials from elsewhere on the site for placement under the
cap. The primary purpose* of these measures, according to the
Agency, is to mitigate the potential for migration of site
contaminants into the bedrock aquifer.
In determining that there is a potential for
migration of cite contamination to the bedrock aquifer
•
sufficient to require the proposed excavation and capping,
EPA calculat&d, through modeling, the amount of contaminants
-7-
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that could be expected to leach from waste areas into the
shallow groundwater at the site. The Agency then assumed,
without empirical data, that the deeper bedrock aquifer would
become equally contaminated due to a hydrogeologic connection
between the two systems. Finally, EPA assumed a range of
exposure scenarios, such as ingestion of bedrock groundwater,
determined the level of protection it wished to maintain in
the bedrock aquifer, and back-calculated from the protective
levels in the bedrock aquifer to determine target cleanup
levels for soils at the site. These calculations and assump-
tions resulted in the unprecedented determination that "any
location where a contaminant of concern was detected" would
have to be remediated. TS at 3-52 (emphasis added). For the
following reasons, EPA's calculations and assumptions are in
error and do not support the target cleanup levels for soil.
First, EPA miscalculated the amount of contaminants
that can be expected to leach from waste areas into the
shallow groundwater system. The miscalculation resulted from
an error in EPA's determination of how much organic carbon is
present in the contaminated wastes and soils. This value is
referred to as the fraction of organic carbon (or "FOC").
As a general principle, the higher the organic
carbon content of a contaminated material, the less likely it
is that contaminants vill leach from it. In Appendix A to
the FS, EPA utilised an FOC value of 0.0023% to represent the
organic carbon content of site materials. The figure used by
-8-
-------
EPA reportedly is the geometric near, of five soil (i.e.,
non-waste material) samples collected at the site during the
remedial investigation. Although derivation of the FOC value
is critical to EPA's entire analysis, the administrative
record (i.e.. the documents made public by EPA) does not
identify the locations from which the five samples were taken
or explain EPA's rationale for selecting those locations.-i/
The overriding factor, however, is that EPA's
derivation of the FOC value is based solely on soil samples.
But, as would be expected at a municipal landfill, contami-
nants at the Old Springfield Landfill exist not in soil
alone, but within a matrix of municipal solid waste and soil.
Municipal solid wastes have been shown to contain much higher
levels of organic carbon than soils. See DeMarco, et al.
(1969) and Tchebanoglous, et al. (1977) (municipal solid
waste may contain from 15% to 801 organic carbon). Thus, it
is clear that the FOC value utilized by EPA is not repre-
sentative of the actual FOC of the municipal solid waste/soil
mixtures at the cite. Had EPA used even a conservative FOC
value of 5%, its prediction of the amount of contaminants
Without this information, we are hindered in our ability
to comment on EPA's study. EPA's failure to disclose this
information violates the Administrative Procedure Act, 5
U.S.C. 551 et seq., and Section 117 of the Comprehensive
Environmental Response, Compensation and Liability Act
("CERCLA" or~"Superfund").
-9-
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expected to leach from the wastes into shallow groundvater
would have been significantly reduced.£/
The fact that EPA's leach model does not accurately
reflect site conditions is apparent from a review of the
actual shallow groundwater data. The actual maximum shallow
groundvater concentrations of the contaminants of concern are
generally an order of magnitude (factor of 10) less than
those predicted by EPA through its leach model calculations.
See EA Tables 3-4 and 3-5.
Second, EPA has miscalculated the potential for
contaminant migration from the shallow groundwater system to
the bedrock system. The Agency performed water balance
calculations and concluded that approximately 50% of the
precipitation (and septic system flows) infiltrates to the
bedrock aquifer. RI at 110, Table 4-8. The water balance
calculations contain a number of errors that vastly overstate
the amount of infiltration to the bedrock aquifer. For
example, the data presented in Table 4-7 of the RI indicate
that percolation to the bedrock aquifer was modeled assuming
a single, fine sandy loam layer, ten feet in thickness.
However, EPA's data show that a layer of low permeability
till, with an average thickness of 60 feet, overlies bedrock
at the site. XI at 89. The till layer, which exhibits an
average permeability of 1 x 10 centimeters per second (RI
EPA Region Z has assumed a 5% FOC value at other sites
which did not contain municipal solid waste. See, e.g.,
Record of Decision, Keefe Environmental Services, Epping, Hew
Hampshire, March 21, 1988.
-10-
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Table 4-4), represents a significant barrier to infiltration,
but was ignored in EPA's calculations.
Zn addition, the vater balance calculations assume.
that seepage flow from the eastern seeps is 8.5 gallons per
minute (gpm) (RI Table 4-8). Yet, this is the minimum
reported value of six seep discharge measurements. See RI
Table 4-6. Actual site data show that, with 95% confidence,
the average flow from the eastern seeps is 24 gpm (and much
greater if the arithmetic mean is used). Using minimum seep
flow is arbitrary and irrational when the rest of the values
used by EPA in the analysis are annual averages (e.g.,
precipitation, runoff, and evapotranspiration). This error
resulted in a gross exaggeration of the amount of vater
infiltrating to the bedrock aquifer.
A final flaw in EPA's infiltration calculations is
that they ignore site data which indicate that vertical
•upward gradients exist (i.e., water flows upward) in the
bedrock underlying the till in the eastern portion of the
cite. Water level data from monitoring veils Ho. 6, 20, and
20D suggest that, at least 'in part of the site, deep ground-
vater is flowing upward into the shallow aquifer, therefore
reducing the amount of infiltration predicted from the
shallow system into the deep aquifer.
E*PA's confusion about the vater balance is shown by
inconsistencies vithin its own documents. For example, the
RI states that 501 of the recharge to the site discharges to
the seeps (RI at 108) while the FS states that 78% of the
recharge discharges to the seeps (FS at 1-14).
-11-
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Beyond the overstatement of the amount of infiltra-
tion reaching the bedrock aquifer is the fact that EPA
apparently disregarded vater balance calculations and other
cite data in evaluating the impact of site contaminants on
the quality of the bedrock aquifer. Although site data show
no contamination in the bedrock aquifer on the eastern
portion of the site, EPA assumes, in what is called a
"steady-state model," that eventually the bedrock aquifer to
the «ast of the site will contain the same concentration of
contaminants predicted to leach from the wastes into the
shallow aquifer (which is an order of magnitude greater than
the concentrations currently found in the shallow aquifer).
Had EPA carried forward the water balance approach and
scrutinized other site data, it would have realized that its
theory is untenable because it ignores fundamental environ-
mental transport and fate processes including dilution,
dispersion and adsorption. As explained in detail in the
Rescor comments, recharge through the waste areas contributes
only a small percentage (maximum 12%) of the total flow in
the bedrock aquifer to the east of the site. Attenuation of
contaminants in this flow reduces the concentrations of those
contaminants migrating to the bedrock aquifer by factors
ranging from 50 to more than 10,000,000, depending en the
specific contaminant. Thus, even if contaminants do reach
the bedrock aquifer east of the site, dilution and attenua-
-12-
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tion would substantially reduce the concentrations predicted
by EPA's model.
The effects of attenuation, ignored at this site, •
are often recognized by EPA. For example, EPA frequently has
observed that PCBs are largely immobile in soil and generally
do not migrate in groundvater. This determination was set
forth very clearly in the March 31, 1988 ROD for the Cannons
Engineering Corporation site in Bridgevater, Massachusetts,
in which EPA Region I concluded that:
The cleanup for PCBs is based on a direct
contact threat and not a threat of
leaching to ground water. Due to the
chemical nature of the PCS compound, they
are very immobile in soil and do not
migrate in ground water. Therefore, it
was concluded that the PCBs do not pose a
threat to ground water. This conclusion
is supported by site data which showed no
PCS contamination in the ground water.
The "steady-state model" predicting severe contami-
nation of the bedrock aquifer is contradicted by site data.
The eastern portion of "Waste Area 3" has been in existence
for more than 40 years, and lies within 400 feet of bedrock
monitoring wells 20 and 20D. Data in the RI suggest that the
water in the bedrock aquifer to the east of the site is
flowing at rates in the range of 80 to 140 feet per year. If
the "steady-state modal" were correct, veils 20 and 20D would
have been contaminated more than 20 years ago. Yet, actual
site c\ata show no contamination in these veils. (RI Table
4-10).
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B. EPA's Calculations Of Contaminant Migration via Air
Emissions Are Erroneous
The threat of migration of cite contaminants in
landfill gases apparently is a secondary rationale for EPA's
proposal to install a low-permeability synthetic membrane cap
(and accompanying gas venting system) over an 8-acre area at
the site. However, it is clear that EPA's calculations of
inhalation risk are based on unrealistic and unwarranted
assumptions concerning the levels of volatile organic com-
pounds ("VOCs") in the soil, the area of the emission source,
the frequency of exposure, the amount of organic carbon in
the landfilled materials, and the rate at which chemicals are
emitted in the landfill gas. In fact, a number of EPA's
assumptions are directly contradicted by site data.
EPA's calculations regarding air emissions are
based on the assumption that the maximum soil VOC levels are
"representative of the entire site." EA at 4-12. (Emphasis
added.) Without defining the "entire site", the EA identi-
fies an area of 12,040 square meters as the emission source
for purposes of modeling inhalation risks. EA Appendix C at
C-16. The EA states that an area-wide emissions source was
used as a basis for the calculations because "the
data ... are not sufficient to isolate hot spots of
volatile contamination that would allow a more accurate
determination of source areas." EA at 4-12. However,
Figures 3-12 through 3-14 of the RI specifically define the
VOC "hot spo£s" at the site. Thus, closer scrutiny of the
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data reveals that EPA has identified an area of only about
1,700 square meters as associated with the higher VOC levels
on site. The area of the emission cource used by EPA is,
therefore, more than seven times larger than the VOC "hot
spot" area identified by cite data.
Moreover, the EA assumes continual exposure to
ambient air at the site for a 70-year lifetime. Any resi-
dents of the site vould have to remain outside and breathe
every breath from birth in the vicinity of the highest VOC
levels found at the site to achieve such an exposure. This
assumption is obviously unrealistic, particularly in view of
the fact that site residents currently are being relocated,
EPA has recommended permanent relocation of all residents,
and the Tovn of Springfield has enacted a municipal ordinance
authorizing restrictions on future site development.
Also, as discussed above with respect to contami-
nant migration to the bedrock aquifer, EPA's calculations
underestimate the organic carbon content of the waste
materials on site, thereby overstating the flux rate of vocs
from coil to air. EPA has recognized this fact in Appendix
A-ll to the FS which states that TiU additional organic
matter is present in the' form of paper and other municipal
waste co-disposed with the chemical wastes, then the actual
vapor density may be lower." (Emphasis added.) In calcu-
lating organic carbon content in disregard of the fact that
municipal waste was co-disposed with industrial waste, EPA
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has grossly overestimated the amount of contaminant migration
through landfill gases.^
Although EPA's calculations cannot be replicated in
the absence of certain critical inputs utilized by EPA which
do not appear in the EA, Rancor has performed a simple mass
balance calculation using the "box model" set forth in the EA
at Appendix C. Remcor's calculations show that, under EPA's
model, the contaminants of concern would be exhausted in a
matter of hours (and obviously could not contribute to the
lifetime exposure risX postulated by EPA). It is apparent
that the emission rates assumed by EPA in modelling the
migration of contaminants in landfill gases at the site are
much too high.
Finally, EPA's calculations regarding air emissions
are based on the occurrence in surface soils of two contami-
nants, chloroform and benzene. EPA's calculations assume
that the maximum concentrations of chloroform (380 microgra&s
per kilogram} and benzene (5,600 micrograms per kilogram) are
present over a three acre area. This assumption might be
warranted if additional site data were unavailable. In
reality, however, the levels used by EPA were found only at
The administrative record does not contain flux rate
calculations or data that would enable us to determine how
EPA performed those calculations. In this respect, EPA has
violated the Administrative Procedure Act, 5 U.S.C. 551 et
egg.. «end Section 117 of CERCLA. Our comments on the
overstatement of flux rates are based on the relationship
between flux rates and fraction of organic carbon, which is
disclosed in the record. As noted above, however, the
location of soil samples from which FOC was calculated is not
disclosed in the administrative reord.
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bcring SO-10 (chloroform) and boring 60-001 (benzene).
Chloroform was detected in only four other surface soil
canples (range: 4 to 95 micrograms per kilogram) and two
sub-surface soil camples (2 and 4 micrograms per kilogram).
Benzene was detected in four other surface coil camples
(range: 2 to 40 micrograas per kilogram) and one sub-surface
coil cample (1 microgram per kilogram). Therefore, the
maximum levels are not representative of cite-wide contamina-
tion, and do not represent average case or "plausible"
maximum case scenarios. Redefinition of the emission source
area, based on actual data and realistic exposure assump-
tions, would result in a finding that the cap proposed by EPA
is not necessary to mitigate inhalation risks.
C. ZPA's Calculations Concerning Contaminant Exposure
Through Consumption Of Fish From The Black River
Are Erroneous
A third exposure route addressed in the FS (and a
secondary rationale for the target cleanup levels for soils)
ic the ingestion of contaminants through the consumption of
fish from the Black River. The EA concludes that there is a
present risk to persons consuming fish from the Black River,
due to assumed PCB concentrations in such fish. FS at 1-43,
Table 1*8. Clearly, this is erroneous because campling of
fish from the Black River in 1986 found no evidence of PCBs.
See Summary Report, KUS Corporation at 4-39 (September,
1986)* EPA acknowledges that PCBs were not detected during
the 1986 campling, but failc to explain how this fact is
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consistent with its determination that there is a present
risk to persons consuming Black River fish. See EA at 4-15.
The EA also concludes that consumption of fish from
the Black River presents a future risk through ingestion of
PCBs. The EA assumes through modeling that PCBs leach from
the landfilled wastes into the shallow groundvater, that they
migrate into the bedrock groundwater in the same concentra-
tions as modeled in the shallow groundwater, and that they
are then carried by bedrock groundwater to Black River
sediments where they may be subject to uptake by the fish.
EPA's assumptions and calculations in this regard are in
error.
By factoring in the effects of dilution and attenu-
ation, Remcor calculated that the actual concentrations of
PCBs in bedrock groundwater would be 1/10,000,000th of that
assumed by EPA. See Table 3 of Remcor comments. The actual
site data confirm that EPA's calculations are flawed, in that
no PCBs have been detected in bedrock monitoring wells east
of the landfill. Moreover, the fish tissue concentrations
of PCBs modeled from EPA's erroneous groundwater values and
based on a bioconcentration factor of 1,000 are 0.0005
micrograms per gram and 0.03 micrograms per gram for the
average and plausible maximum cases. As stated on page 4-5
of the EA, these concentrations are at least two orders of
magnitude (100 times) lower than the national background
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level and Food and Drug Administration acceptable level of
two micrograms per gran.
The errors in the leach model are exacerbated by •
EPA's exposure scenario, which assumes consumption of 6.5
grams of fish per day over a 70-year lifetime. This exposure
scenario is unrealistic in that it assumes that the entire
lifetime diet of fish for the exposed population comes from
the Black River.
In addition to using a flawed leach model and
unrealistic exposure assumptions, the Agency failed to
correctly calculate the impact of infiltration through the
wastes on the bedrock aquifer. For the reasons discussed
above, PCB concentrations in bedrock groundvater will not be
equal to the modeled concentration in the shallow aquifer.
EPA's assumptions regarding the migration of PCBs
are inconsistent with its findings in prior cases, such as
the Cannons Engineering site in Bridgevater, Massachusetts,
that M[d]ue to the chemical nature of the PCB compound, they
are very immobile in coil and do not migrate in groundwater
{and] do not pose a threat to ground water."
If EPA bad properly calculated potential PCB
concentrations in bedrock groundwater, it would have
determined that the future risk due to ingestion of fish in
the Black River is far less than 1 x 10~7 (i.e.. one addi-
tional cancer in an exposed population of ten Billion
people), the target risk level used by EPA. Finally, even
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accepting all of EPA's incorrect calculations and assumptions
and unrealistic exposure scenarios, the maximum future risk
identified in the EA is 6 x 10~6 (six additional cancer cases
in an exposed population of one Billion persons), which is
veil within EPA's accepted range of 1 x 10~4 to 1 x 10"7 (one
excess cancer in ten thousand population to one excess cancer
in ten million population). This risk does not justify the
capping proposed by EPA.
D. The-Selection of Target Clean-up Levels Based On
10- Incremental Cancer Risk Is Unsupported By Site
Characteristics
Zn developing target cleanup levels for soils at
the Old Springfield Landfill Site, EPA utilized erroneous
assumptions concerning contaminant migration into the bedrock
aquifer and through landfill gases, and back-calculated
target cleanup levels in soils to determine which soils
should be excavated and/or capped. As noted above, the
contaminant migration "models" used by EPA are not defensible
and do not accurately reflect site conditions.
To further compound these errors, EPA adopted a
carcinogenic risk level of 10~ (i.e., one additional case of
cancer in an exposed population of 10,000,000 people) to
derive the target cleanup levels in soils. This results in
cleanup levels which, to our knowledge, are unprecedented in
application to cleanup of a municipal landfill.
• EPA has failed to explain its rationale for adopt-
ing 10~7 as the target risk level for the site. As stated in
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EPA's Superfund Public Health Evaluation Manual, ZPA/540/1-
86/060 (October 1566), "[ajccording to Agency policy, the
target total individual carcinogenic risk resulting from
exposures at a Superfund site nay range anywhere between 10~
to 10~7." £d. at 91-93. See also 52 Fed Reg. 32496, 32499
(1987) ("Cleanup levels should be selected such that the
total risk of all contaminants fallc within the acceptable
risk range of lo"4 to 10~7.") In fact, EPA has drafted and
widely disseminated suggested revisions to the National
Contingency Plan (the regulations governing Superfund clean-
ups) which provide that site cleanups should address a risk
level of 10"6.
The Office of Technology Assessment of the Congress
of the United States has cited with approval the fact that
the target level most frequently used by EPA is 10 (one
excess cancer in an exposed population of 1,000,000). See
Are We Cleaning Up? 10 Superfund Case Studies (June 20,
1988). This is borne out by our review of the Records of
Decision issued by EPA Region I in the last several years.
The Region selected a target level of 10 at the Auburn Road
cite in Londonderry, New Hampshire, the Baird and McCuire
site in Holbrook, Massachusetts, and the Cannons Engineering
Corporation sit* in Bridgewater, Massachusetts; and a less
stringent target level of 10* at the Keefe Environmental
Services site in Epping, New Hampshire. We are not aware of
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any sites where EPA Region I (or any other ZPA Region) has
selected the most stringent target level of 10* .
Even if EPA has, on occasion, used a 10* target '
level, application of that risk level to cleanup of the Old
Springfield Landfill Site is unwarranted because of site-
specific characteristics. First, there is no current use of
bedrock groundwater at or downgradient of the site, and no
likelihood that it vill serve as a potable supply in the
future. Second, the Town of Springfield has enacted
Ordinance No. 88-2 to preclude development in the future of
any contaminated bedrock groundwater as a potable supply.
Third, there are no bedrock groundwater veils presently
located between the former landfill and the Black River, and
the potential for future development of this area is severely
constrained by topography. Fourth, a municipal water supply
is already available as an alternative to use of bedrock
groundwater. Finally, all residents of the mobile home park
are being relocated, and Springfield Ordinance Mo. 88-2
authorizes restrictions on future site development. EPA has
considered less dramatic site specific factors at other
sites.^/
As EPA has itself recognized, the use of a 10 "7
carcinogenic risk level for all media and exposure scenarios
For example, at the Cannons Engineering Corporation site
in Bridgewater, Massachusetts, EPA considered the low
probability of residential development and the availability
of a municipal water supply as significant factors in
deciding upon the scope of cleanup.
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at the Old Springfield Landfill Kite results in target soil
cleanup levels which are far below the limits of analytical
detection, requiring remediation of any area demonstrating
detectable contaminants of concern. See 7S at 3-31 and 3-52.
In fact, the natural background level of polynuclear aromatic
hydrocarbons ("PAH's") in forest soils is 555 times greater
than the target cleanup level selected by EPA. FS at 3-19.
Moreover, n[a]lmost all of the soil target levels calculated
based on a total carcinogenic target risk of 10 . . . were
within the range for forest soils.*1 Id. And the PCS soil
cleanup target level selected by EPA for this site is
1,800,000 times lower than the level selected by EPA five
months ago for the Cannons Engineering Corporation site in
Bridgewater, Massachusetts. See Record of Decision, Cannons
Engineering Corporation Site, Bridgewater, Massachusetts
(March 31, 1988). In sum, it is clear that a risk assessment
which calls for remediation of contamination at "any location
where a contaminant of concern was detected," regardless of
background levels, is one that has gone grossly awry.
II. COMMENTS ON CAP AS COMPONENT OF PREFERRED ALTERNATIVE
A. The Data Do Not Support The Need For The Cap
Proposed By EPA
The preferred remedial alternative proposed by EPA
provide* for installation of a multi-layer cap on the approx-
imately eight acres of the Old Springfield Landfill site
vhich are associated with past landfilling activities. EPA's
determination that an 8-acre low permeability cap is needed
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fit th« site is based on its conclusion that the site presents
unacceptable risks of ingestion of bedrock groundvater,
ingestion of fish from the Black River, and inhalation of
landfill gases. According to the Agency's reasoning, the
proposed cap (together vith a gas collection and venting
system) will mitigate air risks and minimize rainfall infil-
tration to prevent leaching of the landfilled wastes into the
•hallow groundwater and ultimately into the bedrock aquifer.
As discussed above and documented more extensively
in the attached comments prepared by Remcor, it is clear that
the site data do not support the need for such a cap. The
calculations in the RI regarding the migration of contami-
nants froa waste materials to shallow groundwater overesti-
mate contaminant levels, largely dut to an inappropriately
low TOO value. Zn addition, EPA's infiltration modeling
overstates the recharge to bedrock from vertical infiltration
and fails to take into account dilution and attenuation. For
these and the other reasons set forth above, EPA's data do
not demonstrate an unacceptable risk through ingestion of
bedrock groundwater or consumption of fish from the Black
River.
Moreover, as set forth above and in the attached
Remcor comments, EPA overstated the risks associated vith
inhalation of landfill gases. Among other errors, the Agency
used all inappropriate FOC value, unwarranted exposure assump-
tions, and unsupported source area and maximum contaminant
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values. The data do not show an unacceptable risk associated
with inhalation of landfill gases.
The only exposure pathways meriting remediation
based on EPA's data are those associated with contaminated
seeps and with direct contact with contaminated surface
soils. The risks of direct contact with contaminated surface
soils can and should be eliminated by placement of a soil
cover over approximately two acres on the eastern portion of
the site. Any risks posed by exposure to contaminated seeps
can and should be addressed by seep collection and treatment.
B. The Steep Outslepe Areas Should Not Be Capped
As set forth above, EPA has no data justifying
construction of a low permeability cap over approximately
eight acres of the site. This is particularly evident with
respect to the steep outslopes along the eastern periphery of
the waste disposal areas. EPA has no site data documenting
the presence of hazardous substances in these areas. In
addition, even if it is assumed that hazardous substances are
present in these areas, the overall benefits of capping the
outslopes are outweighed by construction risks, implementa-
tion problems, aesthetic considerations, and costs.
The Agency has failed to document the presence of
hazardous substances in the outslope areas. Apparently
because of the steep topography, drilling and sampling were
not performed in these areas. Proposed capping, therefore,
is based on an assumption that these areas contain hazardous
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substances and that the concentrations of such substances
exceed modeled risk-based cleanup levels.
Moreover, site data suggest that the contribution
of the outslope areas to recharge of the bedrock aquifer is
minimal. As discussed in the attached comments by Remcor,
the steepness of the landfill outslopes promotes run-off of
surface water and the devatering of the slopes through
seepage. Surface water runoff is not considered to be a
significant transport mechanism on the outslope areas. RI at
157. Remcor's calculations indicate that bedrock recharge
from water infiltrating through the slope areas proposed for
capping is, at a maximum, 3% of the total recharge into the
bedrock aquifer underlying the eastern portion of the site.
Attenuation of the contaminants flowing through the till
would further reduce the impacts of this recharge. Thus, any
benefits from construction of a low permeability cap on the
slopes are negligible.
In addition, EPA has not adequately considered the
"constructibility" problems associated with capping the
outslope areas. Remcor has reviewed relevant literature
which Indicates that the friction angle (i.e.. the maximum
angle at which frictional forces will impart resistance to
sliding between a high-density polyethylene membrane and sand
materials) is 17 to 18 degrees. According to the literature,
a grade of approximately four to one, as opposed to EFA's
suggested three to one, would be required to achieve mass
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stability and to prevent liner failure. Achieving such
grades vould require excavation and relocation of about
47,000 cubic yards of material, as opposed to the approxi-
mately 19,000 cubic yards estimated by EPA, to achieve an
overall grade of three to one. See TS, Table 7-4.
Also, the heterogeneous nature of the municipal
solid waste within these outslopes would present significant
difficulties in the handling of materials and compacting the
graded slopes to allow placement of the cap. The outslopes
are presently at or near the angle of repose of the materi-
als, the wastes having been dumped into place in the existing
ravines. These slopes are prone to landslides that would
create an ongoing maintenance problem and would generally
reduce the effectiveness of the cap. Beyond that, there are
a number of potential hazards associated with the large scale
excavation that would be required, including the volatiliza-
tion of organics. The impacts and costs associated with
excavating and capping the outslope areas are far greater
than those assumed by EPA.
Finally, the residents of the Springfield area have
expressed concerns about aesthetic considerations associated
with EPA's preferred remedial alternative. The eastern
outslopes presently comprise approximately five to seven
acres of heavily wooded terrain. Excavation and capping of
the outslopes would involve the loss of approximately two
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acres of forest, in addition to that which would be lost
through EPA's proposed seep collection system.
In view of the lack of data concerning hazardous
substances in the eastern outslopes, the instability of the
slopes, the difficulties, risks and costs associated with
capping, and the minimal impact of infiltration passing
through these areas, the eastern outslopes should not be
capped. However, the contaminated seep discharges on the
eastern outslopes can and should be collected and treated.
C. If The Selected Remedy Includes A Low Permeability
Cap, The ROD Should Specify Performance Standards
Rather Than Detailed Cap Configuration
The TS and Preferred Alternative specify a detailed
cap configuration consisting of a vegetative cover over
twelve inches of topsoil over twelve inches of clean fill
over a filter fabric over a drainage layer over a synthetic
membrane over two feet of compacted glacial till over a six
inch gas collection layer bounded by filter fabric. Contrary
to statement* made by EPA employees and consultants at
several public meetings, this specific design is not required
by the Resource Conservation and Recovery Act ("RCRA") or by
EPA regulations under ftCRA or Superfund. Rather, £PA regula-
tion* at 40 C.T.R. f 264.310 set forth performance standards
which specify that a landfill cover must be designed and
constructed to
(1) provide long-term minimization of migration of
• liquids through the closed landfill;
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(2) function with minimum maintenance;
(3) promote drainage and minimize erosion or
abrasion of the cover;
(4) accommodate settling and subsidence so that
the cover's integrity is maintained; and
(5) have a permeability less than or equal to the
permeability of any bottom liner system or
natural subsoils present.
Because these performance standards can be met, and
because, protection equivalent to the cap proposed by EPA can
be achieved, with a less complex cap, the ROD should specify
performance standards, including, perhaps, a permeability
target such as 10~7. Actual cap configuration should be
determined during the remedial design phase of the project.
Provision for flexibility in cap design may accommodate the
concerns of area residents that aesthetic considerations be
taken into account and that the cap be as close to grade as
possible.
In addition to the foregoing reasons for flexibili-
ty in design, it appears that EPA's preference for a syn-
thetic membrane cap is inappropriate at this site given that
it is a former municipal solid waste landfill and also given
the steep slopes on the eastern portion of the site. As
evidenced by continuing methane emissions, degradation of the
wastes is ongoing, and will create differential settlement.
In such a situation, a cap consisting of natural materials is
preferable to one containing synthetic membranes, which have
•
a tendency to tear. Moreover, as noted above, construction
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of a synthetic membrane cap over the outslope areas would
require that the slopes be reduced to a grade of 4 to 1 or
less. This would require the excavation of approximately
47,000 cubic yards of waste, with their redeposition on the
surface of the plateau.
Based on the considerations discussed above, a cap
consisting of different materials and in a different config-
uration nay prove more reliable and acceptable to the
community than the synthetic membrane cap proposed by EPA.
Such an evaluation should be performed during remedial
design.
III. COMMENTS ON COLLECTION AND TREATMENT OF CONTAMINATED
SEEPS
A. The Seep Collection System Should Be Designed
During The Design Phase Of The Project, Following
Issuance Of The ROD
Seep collection and treatment was proposed by us on
June 8, 1988, and we urge the implementation of appropriate
measures without undue delay. As discussed in the attached
document, however, we have a number of questions and concerns
about the seep collection system proposed by EPA. For
example, EPA proposes to collect all ten seeps identified on
the eastern outslopes of the plateau, despite the fact that
site-related contaminants have been detected in leachate in
only three of these seeps. The ROD should provide for
collection of only those seeps which EPA has determined are
•
contaminated, with provision for monitoring the remaining
seeps periodically. The seep collection system could be
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designed to allow for modification to accommodate collection
of any additional seeps which may become contar.ir.ated.
In addition, as explained in the Peracor comments,
there nay be other seep collection designs vhich provide a
greater degree of safety vis-a-vis the stability of the slope
areas. Also, other designs Bay have lesser negative
aesthetic impacts, which are of concern to the community.
For example, the seep collection system proposed by EPA would
require the clear-cutting of several acres of woodlands on
the outslope areas. The alternative design proposed by us on
June 8, 1988, would entail clearing of only those areas in
the immediate vicinity of the seeps to be collected and
immediately adjacent to the main collection line. Thus, the
ROD should specify the seeps to be collected, but provide for
design of the seep collection system during implementation of
the remedial action.
B. The Treatment Plant Should Be Designed During The
Design Phase Of The Project, Following Issuance Of
The ROD
All parties seem to agree that treatment of the
collected seeps and leachate at the Town of Springfield's
publicly operated treatment works is preferable to the EPA
proposal for on-site treatment and discharge directly to
surface waters. Although all of the issues pertaining to
treatment at the Town's treatment works have not been finally
resolved, these details are more appropriately addressed
through design studies during implementation of the ROD. The
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ROD need only specify the level of treatment required, either
cm-site or at the Town treatment works.
In addition, there are a number of components of
the treatment plant proposed in the preferred alternative
that may not be necessary to accomplish the level of treat-
ment desired by EPA. For example, there may be no need for
an oil/water separator, or for the degree of metals precipi-
tation proposed by EPA, to satisfy treatment standards.
These issues are best resolved through treatability studies
conducted after the ROD.
Finally, deferring a decision on the location of
treatment may allow full consideration of the aesthetic
concerns raised by the local residents. Although our June 8,
1558 submission contemplated on-site pretreatment facilities
similar to the on-site system proposed by EPA, after hearing
the residents' aesthetic concerns, we have begun to explore
other alternatives. It may be possible to locate the treat-
ment plant adjacent to the Town's existing treatment works.
The ROD should be flexible enough to allow this desirable
result.
IV. COMMENTS ON GROUNDWATER PUMPING AND TREATING
As explained in more detail in the Remcor comments,
the data defining the sand and gravel aquifer and its role
with respect to contamination of the western leachate seeps
are nqt sufficient at this time to provide the basis for
installation of groundwater interceptor veils in the area
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east of Will Dean Road. In addition, Remcor believes that
characterization of the hydrogeologic regime in the vicinity
of the sand and gravel zone is not adequate to permit design
and implementation of the proposed interception system.
Accordingly, the number, location and depth of any ground-
vater interceptor veils in this zone should be determined
through design studies during implementation of the ROD,
rather than specified in the ROD.
V. COMMENTS ON SLURRY WALL AS POSSIBLE COMPONENT OF THE
REMEDY
Although not adopted as part of EPA's "preferred
remedial alternative," Alternative SC-2 of the FS includes
reference to an optional slurry vail vhich vould enclose the
capped vaste areas on the north, vest and south. The stated
purpose for the possible inclusion of a slurry vail as a
component of the remedy vould be to restrict lateral flov of
groundvater fron upgradient areas through the vastes. FS at
p. 5-12.
We see no reason for further consideration of a
slurry vail in viev of the statements made by EPA employees
and consultants during the public meetings and hearings in
June and July of 1988. For example, an EPA employee stated
that the Agency could not find a vay to cut off lateral flov
and that aost water contacting the vaste comes from the
vertical (precipitation) and not from subsurface flov. The
project manager for EPA's consulting firm stated that very
little vaterJfloving from the upgradient areas actually comes
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into contact with the landfilled wastes, and concluded that
there is "no scientific reason to try to put in a Blurry wall
that is not implementable."
VI. CONCLUSION
The data provided by EPA show that the risks posed
by the Old Springfield Landfill are associated with the seeps
and with direct contact with contaminated surface soils in a
two acre area to the east of the site. These risks are
addressed by the proposal submitted by Emhart, Textron, and
the Town of Springfield on June 8, 1988. We remain willing
and ready to implement remedial measures along the lines we
proposed, as modified by these comments. Zn addition, we
believe that continued discussions among the interested
parties can bring about a mutually satisfactory approach to
site remediation.
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ATTACHMENT u ur K.tarOiSaiV£.i\i.3i
(COR. Inc • 701 Alph* Orm • P.O Bos 3&310 • Prtuourgh. f A 15236-6313 * 412-8S3-110S
August 23, 1953
Project No. 88530.9 '
Ms. Paula Fitzsimmons
Regional Project Manager
U.S. Environmental Protection
Agency, Region I
Waste Management Division 4J3 218'
90 Canal Street (HPS-1) - 2nd Floor
Boston, Massachusetts 02114 , VE&YTWASTE
Technical Comment. . IUNA6EMBH BRANCH
Draft Final Project Documents
and Preferred Remedial Alternative
Old Springfield Landfill Site
Springfield, Vermont
Dear Ms. Titzsimons:
On behalf of Emhart Corporation (Emhart), Textron Inc. (Textron), and the
Town of Springfield (Springfield), Remcor, Inc. (Remcor) has performed a
technical review of the draft final project documents relative to the
remedial investigation/feasibility study (RI/FS) at the Old Springfield
Landfill (Old Springfield) site. We have also evaluated the preferred
remedial action publicly announced by the U.S. Environmental Protection
Agency (EPA). Documents reviewed included the following:
• Draft Final Supplemental Remedial Investigation Report (RI)
• Draft Final Endangerment Assessment (EA)
• Draft Final Feasibility Study Report (FS).
This letter presents technical cements to be Bade part of the Adminis-
trative Record for this site.
INTRODUCTION
OVERVIEW OF EPA SITE CHARACTERIZATION AND PREFERRED ALTERNATIVE
The Old Springfield site is a former aunicipal and industrial waste land-
fill situated on a plateau overlooking the Black River and Seaver's Brook
south of the coosnercial center of Springfield, Vermont. Co-disposal of
Kunicipal solid waste (KSV) and industrial wastes reportedly occurred at
this former landfill from about 19D7 until 1968. A mobile home park has
occupied the more northern and central portions of the plateau since
1970.
tlALttTlC SOLISTIOHS PD* KAZAA00US
-------
Ks. Paula Fitzs lemons 2 August 23, 19BS
Through remedial investigations initiated in 198H, the EPA has identified
three Areas of landfilled waste disposal on the eastern portion of the
plateau, comprising a total of approximately eight acres. The EPA con*
eludes in the FS that contaminant migration from these wastes is occur*
ring via leaching of contaminants into ground water and through landfill
gas emissions, and that contaminated soils are accessible for residents
to be exposed via direct contact (FS Table 1-6).
In establishing objectives for cleanup at the Old Springfield site, the
EPA defined a target risk level for carcinogenic substances of 10"' (one
additional case of cancer attributable to lifetime exposure in a popula-
tion of 10,000,000, or a 1/10,000,000 additional chance of a single indi-
vidual in that population contracting cancer) (FS, page 3-1). Risks es-
timated in the EA are considered unacceptable (i.e., requiring remedial
action) if they exceed the 10*7 level. .
Current and future estimated risks are sunrnarized in FS Tables 1-7
through 1-10. Current unacceptable risks were attributed by the EPA to
the following:
* On-Site Bisks;
- Direct contact with soils
- Inhalation of chemicals in landfill gas
• Off-Site Risks:
- Inhalation of landfill gas
- Ingestion of fish from the Black River
• Inhalation of volatile organic compounds (VOCs) emitted
from the western Jeachate seeps.
Future unacceptable risks estimated by the EPA are the following:
• On-Site Risks;
- Direct contact with soils
• Inhalation of chemicals in landfill gas
- Ingestion of bedrock ground water in areas cast of the
landfill
• Off-Site Risks;
• Ingestion of fish from the Black River
- Ingestion of bedrock ground water in areas west of the
site.
-ACALISTIC SOLUTIONS POM MAZAftDOUS WASTf MO«t«W
-------
Us. Paula Fitzsimmons 3 August 23, 1956
The EPA's preferred alternative contains a number of elements. To ad-
dress future risks associated with ingestion of bedrock ground water east
' of the former landfill, the EPA has concluded that all soils at the site
exhibiting any detectable levels of contaminants of concern must be reme-
diated (FS, page 3-52). The EPA's preferred alternative provides for
capping of these soils with a low-permeability cap over an area of ap-
proximately eight acres in the eastern portion of the site, generally en-
cotnpassing the former landfill area. In addition, approximately 6,000
cubic yards (yd3) of "waste" beyond the limits of the proposed cap would
require excavation and consolidation under the cap. According to the
EPA, capping of the outslopes of the former landfill would require exca-
vation and relocation of about 19,000 yd^ of the landfill.
The EPA's preferred alternative includes installation of interceptor
wells into a sand and gravel water-bearing zone, lying between the glacial
till and bedrock in the western portion of the plateau. The objective of
these wells is to intercept contaminants prior to their discharge at the
western seeps and ultimate entry into the bedrock aquifer. The EPA pos-
tulates that the sand and gravel zone trends to the northwest from the
former landfill area and acts as a "drain" for both till and bedrock in
this area due to its much higher hydraulic conductivity (estimated to be
approximately two orders of cagnitude greater than either the till or
bedrock [HI, page 9*0)• This zone is said to provide a conduit for
migration of contaminants to the western leachate seeps (RI, page 97).
The EPA's preferred remedial alternative also proposes continuous leach-
ate collection for 10 leachate seeps identified on the eastern outslopes
of the plfeieau and 4 seeps identified in the western leachate seep area.
Following conveyance to an on-site treatment unit, the treated leachate
(and ground water drawn from the sand and gravel zone) would be dis-
charged directly to an "eastern slope surface drainage course" (FS, page
6-19).
Control of site access would be provided by a security fence following
pennaneat relocation of the residents of the mobile home park.
OVERVIEW OF TECHNICAL COMMENTS
Selection of Target Risk Level
The EPA's selection of the 10*7 incremental cancer risk as the target
risk level at the Old Springfield site for all media and exposure path-
ways is without precedent as reflected in recent records of decision
(RODs) at other sites in EPA Region I and does not reflect site charac-
teristic* in the current instance that mitigate potential risk. The.tar-
get risk level typically employed in recent EPA Region I RODs is 10"6;
this level is appropriate at the Old Springfield site.
•UtALISTlC SOLUTIONS TO« MA2AADOI/S WASTf MOftltMS*
-------
Ms. Paula Fitisinraons 4 August 23, 1958
The data presented in the HI do not support the presence of current risks
associated with inhalation of landfill gases or ingestion of fish. Even
ignoring the technical Justification for EPA's risk calculations, all
current unacceptable risks postulated by the EPA can be mitigated by con-
trolling access to the landfill and the western leachate seeps and by re-
stricting fishing in the Black River.
Apart from selection of an inappropriate target risk level, the EPA's
analysis of specific risk pathways is lacking. According to the EPA, the
prinary contaminant migration pathway of concern at this site is ground
water. The EPA relied heavily on conceptual models to evaluate hydrogeo-
logic conditions and to examine the anticipated extent of contamination
in ground water (and other media, as well). In the absence of empirical
data, a number of the assumptions made by the EPA as input to these mod-
els were unrealistic or in error, leading to overstatement of the actual
exposure point concentrations and risks.
For example, based on a modeled future potential risk associated with
ingestion of bedrock ground water east of the landfill, the EPA has es-
tablished soil cleanup levels very much below the limits of analytical
detection (FS Table 3-18). In recognition of this, the EPA ultimately
established the analytical detection limits (i.e., the lowest concentra-
tions that can be measured by standard analytical methods and instrumen-
tation) for the contaminants of concern as the target cleanup standards
for soils (FS, page 3-52). Implementation of these standards leads to
the proposed capping of the entire eight-acre former landfill. The data,
however, do not support the need for such capping to protect bedrock
(round water east of the former landfill.
\
The EPA employs an organic leaching model to predict contaminant concen-
trations in the shallow aquifer as a result of leaching of wastes by in-
filtrating surface water. This model falls to account for the capacity
of the KSW to retard leaching of organic contaminants into the ground
water. In addition, the EPA assumes (in the absence of empirical data)
that concentrations of contaminants in the bedrock aquifer east of the
landfill will eventually equal those found in the shallow aquifer under
"steady-state*1 conditions. This approach does not consider the relative
contribution of infiltration through the waste materials to the total
bedrock ground water flow toward the Black River. It also does not re-
flect the rolt of other processes such as dispersion within the aquifer
and adsorption in the till between the wastes and the bedrock aquifer in
reducing the concentrations of contaminants in bedrock ground water. If
the "steady-state" model correctly predicted bedrock aquifer contamina-
tion, nearly bedrock wells would evidence contamination. In fact, con-
tamination has not been detected in bedrock wells less than 400 feet east
of the landfill (Monitoring Wells 20 and 20D, RI Table 4-10) more than 40
years after wastes were disposed. The fact that eastern leachate seeps
do cot evidence the levels of contamination found in shallow eastern
monitoring wells (RI Tables 4-10 and 4-13) indicates that attenuative
ntCAiiSTic SOLUTIONS roii MMANDOVS
-------
Ms. Paula Fitzsinroons 5 August 23, 19E3
processes are operative within the landfilled wastes and cannot be ig-
nored in modeling leaching of contaminants from the wastes.
The EPA also utilizes the leaching model and "steady-state" model to pre-
dict concentrations of polychlorinated biphenyls (PCEs) in eastern bed-
rock ground water discharging to the Black River. PCBs are generally not
oobile in ground water because of their extremely low solubility. Tne
EPA acknowledges this fact in its initial screening of remedial technol-
ogies (FS Table 4-3), stating that "PCBs are not a major concern in water
at the site.*1 Notwithstanding this statement, the EPA considered PCBs of
concern in evaluating the potential for bioaccumulation of site contami-
nants in fish within the Black River. By appropriately correcting for
the retention of PCBs in the KSW/soil matrix, however, and correctly ap-
plying a dilution factor to account for the actual contribution of infil-
tration through the waste areas to bedrock ground water discharging to
the Black River, it is apparent that the concentrations of PCBs that may
reach the Black River from the site are not sufficient to produce concen-
trations of PCBs in fish tissue that would pose a health risk.
Estimation of Risks from Inhalation of Landfill Gas
The second risk-based factor driving the proposed capping is the protec-
tion of residents froa inhalation of chemicals stripped from the wastes
by landfill gas (predominantly methane). In the absence of empirical
data, the EPA utilized an e&issions model to simulate concentrations of
chemicals in air on site, and, again, failed to reflect the capacity of
the KSW to retard the migration of contaminants into air. In addition,
EPA's current-use exposure scenarios are unrealistic, assuming that resi-
dents on-site would breathe air containing the highest levels of contami-
nants continually for an entire lifetime (i.e., 70 years), and not con-
sidering that these residents will be relocated as part of the preferred
alternative. The risk to the closest off-site residents along Will Dean
Road was assumed to be the same as that for those living on the site,
neglecting the dispersion of contaminants from the former landfill to
Will Dean Road, a distance of over 700 feet.
Host importantly, the EPA emissions model so overestimates airborne con-
centrations that, on a mass-balance basis, the EPA model would result in
the emission source becoming exhausted in about three days. In reality,
chemicals are not emitted in landfill gases at levels sufficient to pose
any unacceptable current or potential future risk to local residents and
do not require remedial action at the Old Springfield site.
Capping pf Steep Outslopes of the Former Landfill
The EPA preferred alternative includes capping of the steep outslopes of
the former landfill areas. Not only would significant difficulties be
encountered in constructing and maintaining a cap on these outslopes, but
•WCAIUT7C SOLUTIONS PDA HAZARDOUS WAST? MOIUEBrS*
-------
hs. Paula Fltrsirasr.s 6 August 23, 1955
the realized benefit in reducing infiltration to bedrock ground water
would be insignificant.
KSV was dumped in ravines along the eastern portion of the plateau, and
currently rests at its approximate angle of repose (i.e., the maximum
stable slope). Degradation of KSW in the former landfill is an ongoing
process, resulting in differential settlement and instability, particu-
larly evident in the outslope areas (FS, page 1-14). The steep outslopes
of the foraer landfill would require significant regrading and slope re-
duction to achieve grades suitable for capping. After installation, the
maintenance of an effective cap on the regraded outslopes would be con-
plicated by the inherent instability of this area.
Besides the engineering difficulties, the outslope areas were not sampled
in the RJ and there are no empirical data to indicate that capping of
these areas is required to protect bedrock ground water. The steepness
of the outslopes encourages runoff of surface water, and their proximity
to springs and seeps (i.e., points at which infiltrating surface water
would return to the ground surface) indicates that nearly all of the
infiltration into the outslope* would emerge at these points.
Excavation cf Areas Beyond the Proposed Cap
In addition to capping the former landfill, the EPA's preferred alterna-
tive includes excavation of itout 6,000 yd3 of "waste" presently lying
beyond the limits of the proposed cap. These satellite areas are identi-
fied in Exhibit 3 of the EPA's Proposed Cleanup Plan for the Old Spring-
field Site (June 1988) in the northeasters and northwestern portions of
the plateau. The northeastern area has also been identified as Waste
Area 1 in RI Figure 3-**. These materials would be relocated under the
cap to prevent surfact water infiltration and emanation of chemicals to
the air via landfill gas emissions.
The current RI data do not support remediation at either of these two
satellite areas to mitigate infiltration of contaminants to the bedrock
aquifer. Analytical data from Waste Area 1 are inconclusive in identify-
ing the presence of chloroform as the single volatile organic compound
(VOC) of concern relative to degradation of ground water quality. Boring
No. 7 encountered minor amounts of octal, wood, and plastic mixed with
sand in this area, more typical of construction debris than industrial
waste (RI Table 3-4). The northwestern area is defined by Surface Soil
Sample OSS-2, which encountered only three polynuclear aromatic hydrocar-
bons (PAHs) near the surface at the limit of analytical detection (RI
Table 3-5). The postulated current and future risks via inhalation of
chemicals "released to the air are negligible. EPA's use of an unrealis-
tlcally low measure of retention of hazardous substances by the KSW/soil
matrix, and its overestimation of the rate at which hazardous substances
are evolved from the wastes resulted in a significant overstatement of
itiALBTic toitmoMS nn HAZAHDOU*
-------
Ks. Paula Fitzsimmons 7 August 23, 19SB
inhalation risk. Therefore, no basis exists for excavation and reloca-
tion of these materials. The presence of a soil contact risk driven by
the PAHs at the northwestern area is based on the finding of contaminants
at the limit of analytical detection. This, alone, is an inadequate
basis for remedial action.
Design of the Proposed Cap
Even if a low-permeability cap would be justified to remediate the former
landfill, the cap configuration specified by the EPA is unwarranted. The
cap design defined in the EPA's preferred alternative is a multi-layer
system incorporating a basal gas collection layer and a hydraulic barrier
consisting of a JJO-rr.il flexible membrane liner over two feet of compacted
glacial till (FS Figure 4-1). Alternative cap designs may be implemented
to achieve the objectives of restricting infiltration of surface water
and controlling landfill gas emissions on portions of the former landfill
as required to mitigate any postulated risk. It is preferable to specify
perforsance requirements for the cap, if any, in the ROD, and to leave
cap design specifications to remedial design to maximize implementability
and cost-effectiveness,
Collection of Leaehate Seeps
The EPA proposes to provide a continuous leachate collection trench along
the eastern outslopes at the approximate elevation of the current springs
and seeps. This collection trench cannot be constructed according to the
EPA design, given th« steepness of the outslopes and their inherent in-
stability. In addition, not all springs along the outslope have evi-
denced contamination, instead, the collector for the seeps should be
installed along an existing bench at the foot of the slope. Those seeps
exhibiting site-related contamination would then be collected via french
drains at their point of emanation with flow conveyed downslope to the
main collector and to a treatment system prior to discharge. This ap-
proach would provide an equivalent degree of collection without the at-
tendant problems of maintaining the collection trench on the steep out-
slopes. Disturbance of established vegetation would be minimized and the
present aesthetics of the eastern outslopes of the plateau would be
preserved.
Interceptor Wells en the Western Portion of the Plateau
The EPA believes that contamination is migrating in ground water to the
northwest via a sand and gravel water-bearing zone, possibly a buried
stream valley (RI, page 9*<; FS, page 1-9). The sand and gravel zone is
believed to act as a "drain" for ground water within both the till and
bedrock on the western portion of the plateau. According to the EPA,
this drain encourages migration of ground water from the former landfill
in the southeastern portion of the site toward the northwest, which then
discharges in the western leachate seep area. RI analytical data from
nuAuxne soiimowi ro* MAZANOOUS WASTY MOILEMS*
-------
Ms. Fault Filzsiascns 6 August 23, 1966
Monitoring Well 290 have confirmed that the ground water within this zone
is contaminated (RI Table 4-12). The preferred alternative anticipates
installing interceptor wells into this water-bearing zone to capture con-
taminants before they migrate to the western leachate seeps. The sand
and gravel zone is poorly defined at present, and its role in ground wa-
ter and contaminant movement is not well understood. Implementation of
any ground water interception action should be preceded by the necessary
predesign studies following finalization of the ROD.
Leachate and Ground Water Treatment and Discharge
The preferred alternative anticipates collection of the western leachate
seeps via a single french drain in this area, with conveyance to a cen-
tral treatment facility prior to discharge. Treated leachate collected
from eastern and western leachate seeps (as welj. as from the interceptor
wells) would be discharged directly to a surface drainage on the eastern
outslope. It would be preferable to pretreat the leachate with discharge
to the Springfield publicly owned treatment works (POTW). As an alter-
native to the central treatment facility, the treatment facility may be
constructed immediately adjacent to the POTW. Several residents have ex-
pressed a concern regarding the aesthetic impacts of on-site treatment
and direct discharge, as proposed by the EPA. Discharge through the POTW
would provide an added measure of safety to avoid discharge of untreated
leachate in the event of failure of the on-site treatment system.
Optional Slurry Vail
The EPA is presently considering placement of a slurry wall around three
sides of the proposed cap area. The intent of the wall would be to di-
vert shallow, upgradient ground water flow around the wastes, thereby
reducing the potential for ground water flushing of the wastes. The Rl
indicates that the water table lies below the elevation of the deltaic
sands (the uppermost stratum at the site) and that lateral ground water
movement in the underlying till zone is limited, probably occurring via
interconnected zones of higher permeability (e.g., sand stringers) within
the till (RI, pages 91 to 100). In accordance with EPA's conceptual nod-
el of ground water flow (RI Figure 4-9)t the sand and gravel zone direct-
ly overlying bedrock and underlying the till in the western portion of
the plateau may create a strong hydraulic gradient away from the land-
filled vutts. This gradient would limit the potential for uneontami-
nated upgradient ground water to contact the wastes. Accordingly, the
data provided in the RI do not demonstrate that a slurry wall is neces-
sary to divert upgradient ground water around the wastes on the outslope
areas that lie below the water table. Based on current data relative to
the location of the wastes and ground water movement, a slurry wall would
have limited value and should not be constructed.
•HiALtvne soiuriowt ran HAZARDOUS
-------
Ms. Paula FiUsimmons 9 August 23, 1955
DETAILED DISCUSSION OF TECHNICAL COMMENTS
Comments discussed in the preceding overview are amplified in this sec-
tion. Following each stated comment, the necessary background and de-
tailed technical basis are presented.
COMMENT NO. 1; THE SELECTION OF THE 10'7 INCREMENTAL CANCER RISK AS THE
TARGET RISK LEVEL DOES NOT APPROPRIATELY REFLECT SITE CHARACTERISTICS AKD
IS NOT CONSISTENT WITH RECENT EPA REGION I POLICY AT OTHER SITES
The FS Appendix fc (page A-2) references the Superfund Public Health
Kanual in noting that "site remedies should reduce ar.bient chemical con-
centrations to levels associated with a total carcinogenic risk range of
10"^ to 10"', where possible UFA, 19B6)." Selection of the target risk
level is to be based on site-specific considerations. The approach fol-
lowed by the EPA at the Old Springfield site in adopting a 10"' target
risk level for all media and exposure scenarios is not consistent with
either site-specific characteristics that mitigate public health risk or
recent precedents within EPA Region I.
Site-specific factors that mitigate risks include the following:
• There is no current risk through use of bedrock ground
water in the site vicinity.
• Springfield has enacted Ordinance No. 88-2 to preclude de-
velopment of any contaminated bedrock ground water in the
future as a potable supply.
*
• The EPA has classified the aquifer as Class IIB (FS, page
2-1) (potential future use [no current use] as a potable
supply), in accordance with the EPA Ground Water Protection
Strategy.
• There are no bedrock ground water wells located between the
former landfill and the Black River, and the potential for
future development of this area is severely constrained by
topography.
• A municipal water supply is readily available as an alter-
native to use of bedrock ground water.
• Permanent relocation of mobile home park residents is a
component of the preferred alternative.
•
Recent EPA Region 1 RODs involving similar hazardous substance concentra-
tions and geologic environments are summarized as follows:
ntEAtisnc coLimoMS FOA MAZAADOUS WASH mounts*
-------
Ms. Paula Fitzsinwons 10 August 23, 1958
• Auburn Road Site. Londonderry, New Hampshire
Final ROD Date: September 17, 1986
Contaminants of concern at this former municipal landfill
include VOCs, semi-volatile organics, and inorganics.
Contamination in on-site bedrock wells immediately across
Auburn Road from currently used domestic bedrock wells evi-
denced total VOCs at 3,400 micrograss per liter (ug/l).
The current risk through ingestion of bedrock ground water
in the domestic wells was found to be acceptable at a 10"b
level. Maximum total VOC levels in ground water on site
were reported to be in excess of 300,000 yg/t. In select-
ing remedial action at this site, the EPA considered provi-
sion of an alternative water supply adequate to protect
residents along Auburn Road from potential future risk
through ingestion of water from the wells.
• Eaird 4 MeCuire Site. Holbrook, Massachusetts
Final RO& Date: September 30, 1986
Residual VOC and PAH concentrations at this former ehexieal
mixing and batching facility were defined to achieve a car-
cinogenic risk level of I0~b.
• Cannons Engineering Cerssration. Bridgeuater, Massachusetts
Final ROD Date: Karen 31, 1958
Target cleanup levels established for VOCs and PCBs in
soils were based on a residual risk level of 10'6. The'EPA
considered the low probability of residential development
and the availability of a municipal water supply as signif-
icant factors in deciding upon acceptable residual risks
and in defining the preferred alternative. Natural renova-
tion of the aquifer was considered appropriate in the ab-
sence of a current risk to ground water users.
• Keefe Environmental Services Waste Site. Epping,
New Hampshire
Final ROD Date: March 21, 1988
Ground water target cleanup goals at this site were defined
to achieve a target risk level of 10'5 (ROD, page 55).
Based on *ite characteristics and recent precedents within EPA Region 2,
a target risk level of tO"6 provides ample, protection of public health
and is consistent with recent EPA policy.
'nuiane •OH/TOMS ran MAJAXDOUS WASTI MOILCMS •
-------
Ms. Paula Fitzsiraraons 11 August 23, 19SB
COMMENT KO. 2; THE REMEDIAL INVESTIGATION DOES NOT SUPPORT THE NEED FOR
THE CAPPING OF THE LAKDFILLED WASTES TO PROTECT AGAINST FUTURE 1NGEST10N
OF BEDROCK GROUND WATER TO THE EAST OF THE FORMER LANDFILL
BACKGROUND
The preferred remedial alternative publicly announced by the EPA calls
for placement of a multi-layer, low-permeability cap over approximately
eight acres of the Old Springfield site. The proposed cap area corre-
sponds to locations associated with past landfilling activities on the
eastern side of the site (i.e., designated Waste Areas 2, 3, and 4 in RI
Figure 3-1). The cap is based on an assumed need to minimize the infil-
tration of precipitation falling directly on the waste areas. According
to the EPA, percolation of the water through the landfilled wastes
leaches contaminants from the wastes and thereby contributes to shallow
ground water contamination. By the EPA's model, the shallow ground water
contamination will then infiltrate into bedrock and degrade the quality
of the bedrock aquifer such that bedrock ground water would eventually
assume the sane levels of contaminants found in the shallow aquifer.
According to the EPA, persons who would use the bedrock aquifer in the
future for domestic water supply would be subjected to an unacceptable
health risk. The EPA estimates plausible maximum incremental lifetime
cancer risk to be 2 x 10"2 for ingestion of ground water from wells
drilled into the bedrock aquifer to the east of the landfill in the fu-
ture (FS, page 1-37). The potential future ingestion of bedrock ground
water east of the landfill is identified as the most significant exposure
pathway requiring reaedial action (FS, page 1-37).
The EPA then used the sane models employed in estimating risk to back-
calculate acceptable contaainant levels in soils, assuming reduction of
risk via use of bedrock ground water to the 10"' criterion. This evalu-
ation procedure led to the following conclusion by the EPA (FS, page
3-52):
The target cleanup levels specified in Table 3-10 [3-18?]
(relative to protection of persons ingesting bedrock ground
water east of the landfill in the future] are relatively low.
Considering these low target cleanup levels, it is apparent
that any location where a contaminant of concern was detected
fi.e.. in soil), as indicated in the supplemental RI. should
be remediated to reduce the future risk due to ground water
ingestion to an acceptable level. (Emphasis and parenthetical
notes added.)
The models and assumptions used by the EPA in this evaluation do not ac-
curately represent site conditions. Accordingly, the postulated risk is
overstated, and the resulting need to address all detectable contamina-
tion in soils via capping is not Justified. Selection of more accurate
•HU1JSTIC SOLUTIONS fOK MAZAftDOl/S WAStE MtOtLtMS'
-------
Hs. Paula Fitzsinmons 12 August 23. 1966
Input data for modeling and establishment of a more appropriate target
risk level at 10"b would lead to the conclusion that capping of the
eight-acre former landfill is not needed to protect future bedrock ground
water users.
BASIS FOR COMMENT
Specific concerns regarding EPA's modeling of ground water contamination
and attendant risk to'future ground water users east of the landfill are
as follows:
1. The leach model used to derive contaminant concentrations
in shallow ground water overestimates contaminant levels
by using input data that are not representative of site
conditions. ,
2. The infiltration nodel (i.e., Bigration of infiltrating
surface water to the bedrock aquifer) overestimates poten-
tial infiltration by using unrepresentative data for flow
from the springs and seeps along the eastern outslopes
of the plateau, by ignoring the fact that infiltration
through the site area nay contribute a much smaller volume
of water to bedrock flow than infiltration through the up-
lands to the south, and by ignoring the potential for up-
ward hydraulic gradients from the bedrock into the till
that would reduce or preclude flow to the bedrock aquifer
in the vicinity of the former landfill.
3. Contaminant concentrations assumed In bedrock ground water
ignore the important physicochemical processes of dilution
and chemical attenuation.
These factors are discussed in the following paragraphs.
Leach Model
The EPA employed a standard equilibrium partitioning model (leach model)
to estimate concentrations of contaminants of concern in shallow ground
water in the immediate vicinity of the waste deposits. The model was '
also used in reverse to derive target cleanup levels in soil (waste) that
will result in acceptable levels of contaminants in the bedrock ground
water.
*
The leach model is sensitive to the fraction of organic carbon (foe) in
the medium leached; organic carbon acts to retard leaching by adsorbing
organic contaminants and making them unavailable to the leachate. The
EPA modeling used an foe of 0.0023 percent to represent the solids being
leached (FS Appendix A, page A-22). This value was taken from the geo-
metric mean of five soil (i.e., non-waste) samples analyzed in the RI (FS
•KtALlSTlC SOLUriOMS fOU HAZARDOUS WAST? MtOflLCVS*
-------
Ks. Paula Fitzsimmons 13 August 23, 19oo
Appendix A, page A-22). The locations of these five soil samples were
not identified in the FI and specific foe results uere not reported apart
from the geometric mean value. The EPA indicated during discussions on
August 9, 1988, that one sample was of a "sediment" and two were from the
glacial till materials. There is no indication that these samples are
representative of the KSW/soil matrix from which the hazardous substances
are leached.
K5W figures prominently in the list of wastes encountered in the waste
areas at the site (Rl Table 3-4), and KSW would be expected to contain
tnuch higher levels of organic carbon than that used by EPA in the leach
model. DeKarco, et al. (1969), indicate that KSW may contain 15 to 30
percent carbon, much of which would be in the organic form. Tchobanog-
lous, et al. (1977), indicate that many KSW components contain 25 to 60
percent organic carbon. c
The foe determined froa analysis of soil samples is not representative of
the actual foe of the KSW/soil matrix in the waste disposal areas. The
EPA recognizes this in its discussion of risk due to inhalation of land-
fill gas (FS Appendix A, page A-11):
"The relatively low fraction of organic carbon in the soil at
the Old Springfield site (2.3 x 10~D g/g), therefore results
in high estimates of equilibrium vapor density. If additional
organic natter is present in the fora of paper and other rau-
r.icipal waste disposed with the chemical wastes, then the
actual vapor density nay be lower. "
The incorrect application of this foe value results in the overestioation
of ground water contamination and the development of unrealistically low
soil cleanup criteria. The fact that actual maximum shallow ground water
concentrations of the contaminants of concern are generally an order of
magnitude lower than those derived from the leach model further demon-
strates that the leach model does not accurately represent site condi-
tions (Efc Tables 3-4 and 3-5; RI Table 4-
Femcor analyzed the effect of using the more representative (albeit con-
servative) foe value of five percent. It was noted that the EPA's analy-
sis of organic leaching from wastes at the Keefe Environmental Services
site used an assumed foe value of five percent as representative of
"glacial till" without the presence of KSW (which would increase the foe
value). Using the conservative average foe of five percent for the KSW
and soil from which contaminants could leach, calculated risks associated
with contaminants of concern are significantly reduced by factors ranging
from 6.9 for methylene chloride (the most mobile contaminant of concern)
to 2,200 for bis(2-ethylhexyl)phthalate, PCBs, and PAHS (the least mo-
bile) (Table 1). These corrections suggest that further evaluation of
the leach model by the EPA is warranted prior to accepting the soil
cleanup levels reported in the FS. Additional corrections to EPA's
•HIAtUTJC SOUTTJOMS FDft MA2A*DOLtt WASH MO«L£«f J-
-------
Hs. Paula Fitzsimmons 1* August 23, 1953
assumptions in modeling potential contaminant transport to the bedrock
aquifer are discussed in the following sections. In aggregate, these
corrections have a significant effect on soil cleanup levels and must be
considered.
Infiltration Hodel
In the EPA analysis, contaminants are transmitted to the bedrock aquifer
through infiltration of contaminated shallow ground water. The bedrock
aquifer is of importance because future domestic wells east of the land-
fill, if any, would extract their supply from this zone, rather than from
the till ("lg]round water above the bedrock in the glacial till is not
typically used as a water source" [FS, page 1-391). The impact of the
former landfill on water quality in the bedrock aquifer is a function of
the degree to which water infiltrating through the wastes contributes to
the flow in bedrock in this area (i.e., the eastern portion of the bed-
rock aquifer flowing toward the Black River).
The EPA apparently attempted to analyze the contribution of infiltration
through the wastes to bedrock flow through water balance calculations
which incorporated the Hydrologic Evaluation of Landfill Performance
(HELP) model. The EPA water balance analyzed the 130-acre watershed con-
tributing recharge to bedrock. Using the HELP model to predict infiltra-
tion through the deltaic sands to the water table, the EPA then sub-
tracted the seep flow to arrive at the volume of infiltration that would
pass through the till and into bedrock. On this basis, the EPA concluded
the following IRI, page 108):
"If 50) of the recharge exits the system at springs and seeps,
then approximately 50f oust discharge as subsurface flow to
surface water discharge zones. Since the site is underlain by
bedrock, this quantity is the amount that enters bedrock by
downward flow.*
The EPA assumed that recharge to the shallow aquifer occurs predominantly
via surface water infiltration to the uppermost deltaic sands. Much of
this recharge exits the ground water system as seepage along the out-
slopes of the plateau at the site, and the remainder migrates vertically
downward into bedrock. The EPA used the HELP model in an attempt to de-
velop the water balance relating precipitation, infiltration, outslope
seepage, and recharge to bedrock at the aite. This water balance is
presented in RX Tables 4-7 and 4-8.
The EPA oade a number of assumptions in its water balance calculations
that resulted in an overstatement of the amount of infiltration reaching
bedrock. Furthermore, although the EPA recognizes that "in the immediate
vicinity of the stte where waste deposits are located, the volume [of in-
filtrating water] flowing downward to bedrock is ouch less" (Rl, page
108), the contribution of such infiltration to bedrock ground water flow
^RCAtnnc tou/Tion TO* MAZMTOOUS WACTT Moatrws-
-------
Ms. Paula Fitzsinnons 15 August 23, -.953
was never quantified. Had the EPA performed more representative water
balance calculations, it would have determined that only a very small
amount of the precipitation falling on the former landfill actually per-
colates through the till and reaches the bedrock.
Moreover, the results of the water balance were never used in evaluating
the impact of the former landfill on bedrock water quality. Rather, EPA
assumed that, under a "steady-state model," the concentrations of contam-
inants in the bedrock aquifer would eventually be the sane as those found
in the shallow aquifer (FS Appendix A, page A-21). This assumption is
erroneous.
The EPA water balance analysis contains two basic flaws:
• The analysis ignored the presence of the approximately 60
feet of low-permeability till that overlies bedrock at the
site
• An inappropriate value for discharge from the eastern
springs and seeps was assumed.
The till layer that underlies the deltaic sands at the site is on the
order of 60 feet thick and exhibits an average permeability of 1 x 10~5
centimeter per second (cm/see) (RI Table il-Jl). This till layer, which
was ignored in the EPA modeling, represents a significant barrier to
Infiltration to the bedrock aquifer.
Rigorous analysis of infiltrating flows (and contaminant transport) re-
quires sophisticated computer modeling, but the relative rates of infil-
tration per unit area can be approximated by comparing the permeabilities
of the layers through which infiltration occurs. The vertical permeabil-
ity of "loamy fine sand" that was used in EPA's HELP model to represent
all materials overlying bedrock within the plateau and outslopes is 3 x
10" 3 ca/sec (standard default value from the HELP model). The permeabil-
ity of the till that actually overlies bedrock at the site is 1 x 10*5
cm/sec. Had the EPA considered the effect of the till, the calculated
infiltration rate on a unit area basis would have been reduced by a fac-
tor of 300 (3 x !0'3/1 x 10'5).
The EPA modeled upland areas as a.layer of "fine sandy loan*1 (HELP model
default permeability of 1.9 x 10"3 cm/sec). This assumption for upland
areas nay be reasonable considering that till is absent over at least
portions of the uplands, and bedrock is exposed in these uplands (Doll,
1970). Where present in the uplands, the till would be thinner; for e»
aaple, at the well for the Bond residence along Will Dean Road south of
the site (in the "uplands"), the total depth to competent rock (i.e.,
"ledge") was reported as 20 feet.
•REALISTIC SOlimOMS PON MAZAADOLTS WASTf MOILCMS*
-------
Ms. Paula Fitisimnons 16 August 23, 1938
The permeability of the infiltration layer used in the EPA modeling for
upland areas is 190 times the permeability of the till within the plateau
(1.9 x 10~3/1 x 10'5). By comparing these relative permeabilities, the
infiltration in upland areas on a unit area basis would then be 190 times
that at the plateau and outslopes. Considering that approximately half
of the ISO-acre surface watershed (K5 acres of uplands and 20 acres of
plateau and outslopes) may contribute recharge to the bedrock on the
eastern side of the former landfill, the total infiltration contributed
by the plateau and outslope areas would be 0.23 percent ([20 acres/190 x
45 acres]) of that contributed by the uplands. Waste areas on the east-
ern side of the site total approximately 8 acres. The waste area would
then be calculated to contribute 0.093 percent ([8 acres/20 acres) x 0.23
percent) of the total potential infiltration to bedrock on the eastern
portion of the site (or total bedrock flow toward the Black River at this
point). 4
Even adopting the very unrealistic position that no adjustment is to be
made for the relative permeabilities of the upland and plateau areas, the
infiltration through waste areas would be diluted by infiltration from
the remainder of the watershed. By simply comparing areas contributing
infiltration, the infiltration through the waste would contribute no more
than 12 percent (6 acres/[05 acres * 20 acres]) of the total bedrock
ground water flow toward the Black River. Consequently, the contribution
of infiltration through the waste to bedrock ground water flow is ouch
less than that predicted by the EPA.
Predicted contaminant contributions from infiltration through the waste
would be significantly less than that calculated by relative flows (dilu-
tion) because of chemical attenuation (partitioning). As the water car*
rying contaminants migrates through the till, the contaminants would be
adsorbed onto the till and would be retarded to varying degrees along the
entire pathway through the till to the bedrock aquifer. The degree of
such attenuation can be calculated for each contaminant of concern using
basically the sase checical partitioning model used in the leaching anal-
ysis (FS Appendix A, page A-21). Table 2 presents retardation/attenua-
tion factors for each of the contaminants of concern, reported as the
velocity of water flow compared to the velocity of contaminant transport.
The dilution of the infiltration through waste by the total infiltration
to the eastern portion of the bedrock aquifer (minimum factor of 8.1
(1/12 percent]) and attenuation (as measured by the retardation factors
given in Table 2) can then be combined to illustrate a more realistic re-
lationship* between contaminant levels in the shallow and bedrock aqui-
fers. For the contaminants of concern, these relationships (shallow con-
centration/bedrock concentration) are given in Table 3. As seen from
these ratios, effectively none of the less mobile phthalates, PAHs, and
PCBs would be expected in bedrock, and significant reductions in the con-
centrations of the more mobile VOCs would also be expected to occur. By
reference to Table 3, for example, it is evident that the concentration
•HtALItTtC SOLUTfOMS POft MAZAADOl/S WA«TK MOftlCMS*
-------
Ms. Paula Fitzsitmons 17 August 23, 1958
of benzene in the bedrock ground water would be 0.3 percent (1/370) of
that predicted by EPA's "steady-state" model.
The relatively small contribution of infiltration through the waste to
bedrock flow negates the EPA's assumption that a "steady-state" condition
would be achieved and that the concentrations of contaminants of concern
in the bedrock aquifer to the east of the former landfill would, under
"steady-state" conditions, equal those in the shallow ground water. In
fact, the concentrations in the bedrock aquifer would be reduced by at
least the factors given in Tables 1 and 3. The EPA's ground water flow
and contaminant transport analyses leading to the calculated risk for
bedrock ground water must be re-evaluated. Correction of errors and
omissions in these analyses and use of a more-appropriate target risk
level to derive soil cleanup levels for contaminants of concern would
lead to the conclusion that capping of the eight-acre landfill area is
not needed.
In the water balance, the quantity of infiltration to bedrock is the re-
mainder after subtracting runoff, evapotranspiration, and seep flow from
total rainfall. Septic tank flows from mobile home residents are also
added to potential infiltration. The EPA water balance calculation anal-
ysis assumed that seepage flou from the eastern seeps was B.5 gallons per
minute (gpiO (Rl Table 4-B). This flow corresponds to the minimum ob-
served in the six seep discharge measurements taken at the site from
September 19S7 through April 1938 (RI Table 4-6). Using a minimum value
is inappropriate; the HELP model is based on annual average conditions
(i.e., precipitation, runoff, evapotranspiration), not minimum values.
The EPA recognizes this fact at the western seeps where the "arithmetic
mean of west slope discharge" was used (HI Table 4-8); the EPA also
states that "it is recognized that this [8.5 gpa] is likely to be a low
estimate" (RI, page 107). In fact, the minimum discharge from the east-
ern seeps is so low that it is not representative and results in an er-
rant calculation of recharge tc bedrock (by subtraction). Table 4 pre-
sents a statistical evaluation of the actual seep flow measurement data
presented in the RI. Actual site data show that, with 95 percent confi-
dence, the true average flows of the eastern and western seeps are at
least 24.0 and 31*5 gpm, respectively.
As noted in Table 4, the arithmetic mean eastern slope seep discharge is
71.7 gpo. Using this value, the water balance calculation would indicate
that there would be no infiltration to bedrock and, in fact, there would
be a water deficit. This deficit suggests that the flow of the seeps
cannot be*accounted for simply by rainwater infiltration and septic flow
and that another source of water oust be present. This other source
could be the bedrock aquifer that discharges water upward. The possibil-
ity of such upward flow is supported by the fact that certain monitoring
wells screened in bedrock (i.e., Wells KW-6 and HW-20/20D) show a higher
potentiooetric head than is present in the overlying till. Remcor
••CAUSTIC SQiUriOHt PQH MAZAADOlft WASTZ PftO«LEVS*
-------
Ms. Paul* Fitzsinoons 18 August 23, 1955
recognizes that site data are inconclusive relative to the extent to
which the bedrock discharges upward.
The EPA contractor notes in its August 2, 1988 cover letter transmitting
Appendix A to the FS Report that "since no contaminants have been de-
tected in bedrock wells along the (Black) river, a steady-state transport
model was developed and used to estimate the maximum bedrock concentra-
tions along the river." The Rl data do not support the assumption that
steady-state conditions will be achieved in "several years" (FS Appendix
A, page A-21).
The easternmost portion of Waste Area 3 has been in existence for over 40
years, and lies within 400 feet of bedrock Monitoring Wells 20 and 20D.
Rencor's analysis of P.! data indicates a flow velocity in bedrock on the
order of 80 to 140 feet per year (ft/yr) (Table. 5). If the EPA's steady-
state model was correct, Wells 20 and 20D would have been contaminated
for more than 20 years. Yet, the actual site data given in the RI demon-
strate that these wells evidence no contamination (Rl Table 4-10).
The alternative interpretation, as discussed previously, is that contam-
inant loading to bedrock from the site is such that no detectable contam-
ination will occur in bedrock wells along the Black River. The EPA's
disregard for environmental fate processes (e.g., dilution, dispersion,
adsorption) has overstated the exposure point concentrations in bedrock
ground water.
SUMMARY
The EPA's postulated risk for ingestion of bedrock ground water is the
driving foret in its establishment of the limits of analytical detection
for contaminants of concern as target soil cleanup levels. These cleanup
levels led to the proposed capping of the eight-acre former landfill in
the eastern portion of the site. This exposure scenario also drives cap
design to the extent that a low-permeability cap material is considered
necessary to reduce infiltration. The RI data do not support the need
for capping the former landfill to protect future potential users of bed-
rock ground water cast of the former landfill:
• The equilibrium partitioning of contaminants from waste
materials to ground water overestimates contaminant levels
by the factors given in Table 1 due to an inappropriately
low foe value employed in the EPA leach model
• Water balance calculations overestimate the recharge to
bedrock froa vertical infiltration
• Consideration of dilution and attenuation results in sig-
nificantly lower predictions of contaminant concentrations
in bedrock (Table 3)
TOAIISTIC SOLUTIONS POM MAZANOOUt
-------
Ms. Paula Fitzsinnans 19 August 23, 195S
• Site data indicate that vertical upward gradients may exist
(Monitoring Wells 6, 20, and SOD) in the bedrock underlying
till in the eastern portion of the site, but Rl data are
not adequate to quantify the extent of such upward movement
• There are no data showing bedrock contamination on the
eastern portion of the site after wastes have been in place
for over 40 years.
EPA's conclusion that bedrock ground water will evidence contamination
similar to that found in the shallow aquifer under impending "steady-
state" conditions is erroneous. A more plausible explanation is that,
due to dilution and chesical attenuation, bedrock ground water will never
evidence detectable levels of contamination, and the "steady-state model"
is wrong. 4
COKMZKT NO. 3t THE REMEDIAL INVESTIGATION DOES NOT SUPPORT THE NEED FOR
CAPPING OF LAKDFILLED WASTES TO PROTECT AGAINST OFF-SITE EXPOSURE VIA 1N-
HALATIOK OF CHEMICALS IN LANDFILL CAS
BACKCEDUKT)
According to the EPA, risks associated with inhalation of landfill gases
represent the second driving force for installation of the low-permeabil-
ity synthetic membrane cap (and accompanying gas venting system). Again,
however, the EPA model of gas emissions from the landfilled wastes is er-
roneous. In addition, the inaccuracy of the emissions model is then com-
pounded by unrealistic assumptions relative to soil VOC levels, area of
the emission source, frequency of exposure, and presence of organic car-
bon in landfilled soils retarding partitioning of VOCs into the air.
EPA's postulated (although undocumented) current on-site risk will be
curtailed with relocation of the residents of the mobile home park. The
EPA also BfeSce* no distinction between residents living on the site and
the nearest off-site residents along Will Dean Road, even though the off-
site residents live at least 700 feet from the former landfill.
BASIS FOR COMMENT
The EPA model to determine potential risks associated with inhalation of
landfill gases is flawed, leading to overestimation of such risks. The
EA (Appendix C, Section C.4) and FS (Appendix A) do not provide all of
the input data used by the EPA in its calculations of the rates at which
potentially hazardous chemicals could escape from the landfilled waste in
the landfill gas. In particular, EPA did not provide the data necessary
to compute the flux rates of the contaminants of concern from the MSA/
soil matrix. Accordingly, Remcor was not able to recreate the EPA calcu-
lations in examining the EPA analysis, but a simple mass-balance calcula-
tion was performed to evaluate the EPA model.
n»r AJ.UTJC toiimowj n* HAZARDOUS WASTZ MOILCMS-
-------
Ks. Paula Fitzsinmons 20 August 23, 1955
Remcor's sass balance calculation was based on the EPA "box model" de-
scribed in the EA (Appendix C, page C-16). In the box model, gases are
evolved from the landfilled wastes and are dispersed into an assumed vol-
ume of air (i.e., the "box"). The air moves through the box at a rate
determined by the average wind speed. Using the airborne concentrations
of contaminants developed in the EPA risk analysis (EA Table 4-4) and the
flow through the box, the mass flow rates of contaminants dispersed in
the air were calculated. The masses of contaminants dispersed in the
air, and therefore leaving the site, were then compared to the masses of
contaminants in the landfilled wastes that are the source of the airborne
contamination.
Using the data presented in the EA and very conservative assumptions
where the EA failed to provide needed data, Remeor has determined that
the EPA model significantly overestimates the rates at which chemicals
are emitted in landfill gas and, therefore, overstates the resulting air*
borne concentrations (see Attachment 1). As an example, Remeor's mass
balance calculation for chloroform (a contaminant of concern that con-
tributes significantly to IPl'js .postulated risk) showed that, at the
evolution rates given in tte "E?fc-model, all of the chloroform in the
landfilled waste (i.e., the source of the airborne concentrations) would
be evolved in 5 hours and 6 minutes, and all of the contaminants con-
tributing significantly to the postulated risk (i.e., benzene, chloro-
form, and trichloroethylene) would be depleted within three days (see
page 6 of 6, Attachment 1). It is evident from these straightforward
mass balance calculations alone that the EPA's risk evaluation, which is
based on a 70-year duration of exposure to the airborne gases, is seri-
ously flawed.
Errors in emission rates notwithstanding, the EA uses the maximum soil
VOC levels as "representative of the entire site." Without defining the
"entire site," an area of 12,040 square meters (ar) is identified as the
emission source (EA, page C-21). In reality, the EPA has identified an
area of only about 1,700 sr associated with the higher VOC levels on
site. The EA indicates that an area-wide emission source was used as a
basis for risk because "the data ... are not sufficient to isolate hot
spots of volatile contamination that would allow a more accurate determi-
nation of source areas." Yet, RI Figures 3-12 through 3-14 specifically
define the VOC "hot spots."
With regard to exposure, the EA also unrealistically assumes continual
exposure to ambient air at the site for a 70-year lifetime. Residents
would have to remain outside from birth in the vicinity of the highest
VOC levels found at the site to achieve such an exposure. In view of the
permanent relocation of residents from the mobile home park and the in-
stitutional controls afforded by Springfield Ordinance Ho. 88-2 regarding
future development, there appears to be insufficient basis for an expo-
sure scenario that places the receptor on site continually for an entire
lifetime.
^CAUSTIC soumoMt n* NAZAMDOUS WASTE mounts-
-------
Ms. Paula Fltzsiranons 21 August 23, 1958
Finally, the EA underestimates the probable organic carbon content or the
soil and waste (see Comment No. 2). The use of an foe value that is un-
representatively low overestimates the flux rate of VOCs from soil to
air.
Even using EPA's erroneous assumptions and unrealistic exposure scenari-
os, the average case, upper bound excess lifetime cancer risk for inhala-
tion of landfill gases is 9 x TO'5, which is within the EPA's acceptable
range (10*^ to 10*'). EPA's theoretical "plausible" maximum case risk
(5 x 10'3), however, is not plausible. The plausible maximum risk calcu-
lations are driven by the occurrence of two contaminants, chloroform and
benzene. The EA assumes that the maximum concentrations of chloroform
(380 micrograms per kilogram lug/kg]) and benzene (5,600 vg/kg) are prev-
alent over the "entire site." In reality, these levels were found only
at SO-10 (chloroform) and 60-001 (benzene). Chloroform was detected in
only- four other surface soil samples (range: 4 to 95 vg/kg) and two-sub-
surface soils (2 and H vg/kg). In addition, sampling of soils in the
same vicinity as Sample 50-10 (Sample OSS-10) one year earlier (19B5) did
not show any detectable contaminants (RI Tables 3-5, 3-6, and 3-7). Ben-
zene was detected in four other surface soil samples (range: 2 to 40
vg/kg) and one subsurface soil (1 vg/kg). Use of maximum levels are
clearly not representative of site-wide contamination and are not appro-
priate for estimation of inhalation risk.
Attachment 1 deaonstrates that the EPA emission model substantially over-
states concentrations of chloroform and benzene in landfill gas and ambi-
ent air. The EA does not document a potential risk through inhalation of
landfill gas sufficient to support any remedial action at this site.
COHMSKT KO. *; THE OUTSLOPES OF THE FORMER LANDFILL SHOULD NOT BE CAPPED
BACKGROUND
The preferred remedial action announced by the EPA anticipates capping a
total of approximately eight acres, reflecting areas of landfilled waste
disposal in the eastern portion of the site. This proposed cap area in-
cludes approximately two acres of steep outslopes along the eastern
periphery of the waste disposal areas.
According to the FS, such capping has been proposed to protect the qual-
ity of the bedrock aquifer and its construction "should not prove to be
difficult" (FS, page 7-23). In fact, the need for capping of the out-
slopes has not been established, and the feasibility evaluation of the
capping has not addressed serious issues of short-term adverse impacts,
constructibility, and cost.
•W&U.IST7C tOiVTl&Kt FOH MA2AADOUS
-------
Ms. Paula Fitzsimroons 22 August 23, 195S
BASIS FOR COKMEKT
Need for Capping
As discussed in Comment No. 2, site data do not support the need for the
capping proposed by the EPA at the Old Springfield site. This is par-
ticularly relevant to the steep outslope areas. The RI has developed no
empirical data that indicate hazardous substances are present in the
waste materials on the steep outslope areas. The steepness of the land-
fill outslopes proaotes runoff of surface water, and infiltration on such
slopes would emerge quickly at the nearby seeps.
The relative contribution of infiltration of surface water through the
waste to total infiltration to bedrock (i.e., bedrock flow) was discussed
in Comment No. 2. Using the permeability of "loamy fine sand" (1.9 x
10~3 cm/sec from HELP model) selected by the EPA to model infiltration to
bedrock in the upland areas (RI Table 4-7) and the permeability of the
till materials mantling bedrock in the vicinity of the former landfill
(10~5 ca/sec), it was demonstrated that infiltration in the upland is 190
times that through the plateau and outslope areas, as defined by the EPA.
On this basis, infiltration through the former landfill may be considered
to contribute 0.093 percent of bedrock flow toward the Black River in
this area. Similarly, the two acres of landfill outslopes would contrib-
ute only 0.024 percent ([2 acres/8 acres] x 0.093) of the total bedrock
flow. Based simply on a ratio of areas, the defined cap areas on the
outslopes, as noted in RI Figure 5*1 (2 acres), contribute only about
three percent (2 acres/65 acres) of the total infiltration to the bedrock
aquifer flowing toward the Black River in this area. In reality, the
contribution would be much less because of the higher potential 'for run-
off, and the tendency for infiltration to emerge quickly as seep flow.
Even if differential permeabilities are not considered, based on the data
presented in the RI, capping of the outslope areas is not needed to miti-
gate contaminant migration in surface water runoff. The EPA concurs with
this assessment, stating that surface water runoff is not considered to
be a significant contaminant transport mechanism on the outslope areas
(RI, page 157).
Cap Constructibilitv and Construction Risk
The desirability and cost-effectiveness of capping the slopes is ques-
tionable |iven the problems of constructibility, risk associated with
construction, and the minimal benefit attributable to reduction in re*
charge tfi the bedrock aquifer.
Conventional capping techniques are well suited for areas of mild or gen-
tle slopes, but are generally very difficult to apply to steeply sloping
areas. In the FS (page 5-12), the EPA has partially recognized this con-
dition and has stated that areas to be capped oust first be regraded to
POft MAZAftDOt/S
-------
Ms. Paula Fit2siimons 23 August 23, 1988
three horizontal to one vertical (3:1) slopes. This slope modification
would, according to the FS (page 7-19), involve the excavation and relo
cation of approximately 19,000 yd^ of wastes at the site.
The stability of the cap on the slopes is imparted by friction, in the
fora of a resistance to sliding, between the layers of the various cap
materials and the internal friction of the soil materials used. The
"friction angle11 is used in geotechnical analysis to quantify the resis-
tance to sliding. In the EPA design (FS Figure 4-1), the critical sur-
face (i.e., least friction) Is that between the flexible membrane liner
and the overlying drainage blanket of sand and drainage net. hartin, et
al. (1985), report that the friction angle between a high-density poly-
ethylene (HDPE) membrane, like that specified in the EPA design (FS Sec-
tion 4.4.2, page 4-15), and sand materials ranges from 17 to 18 degrees.
At a 3:1 slope (18.1) degrees), the factor of safety against sliding at
the critical surface is less than 1.0, and failure is predicted. There-
fore, to provide the appropriate factor of safety against sliding, the
overall grade of the outslopes would have to be reduced to approximately
4:1. Achieving such grades would require excavation and relocation of
about 47,000 yd^ of the waste, as opposed to approximately 19,000 yd^ es-
timated by the EPA to achieve an overall grade of 3:1. The impacts asso-
ciated with waste handling, as well as the costs of such movement would
b* correspondingly amplified.
The heterogeneous nature of the K5U within these outslopes also would
present significant difficulties in handling of materials and compacting
the graded slopes to receive the cap. The possibility of encountering
hospital waste materials likewise cannot be discounted. Excavation and
capping of the outslope areas would also require clearing any existing
vegetation seriously affecting the current aesthetics of the outslopes.
In addition, the existing outslope areas at the Old Springfield site are
prone to instability problems manifested as landslides. The outslopes
are presently at or near the angle of repose of the materials, the KSW
having been dumped into place in the existing ravines. In fact, the FS
discusses recent landslide activity on both eastern and western outslopes
on page 1-14. Disturbance of the outslopes would be likely to exacerbate
this unstable condition.
Given the instability of the outslopes and the other risks of construc-
tion, the difficulties ind costs associated with construction and the
minimal benefits associated with capping of the outslopes, these areas
should not; be capped.
•HtAumc tourriotn nn HAZAAOOVS
-------
Ms. Paula Fitzslsoons 24 August 23, 1966
COMMENT NO. 5; THE POTENTIAL RISK ASSOCIATED WITH CONTACT WITH COKTAMI-
MATED SURFACE SOILS SUGGESTS COVERING AND FENCING APPROXIMATELY 1.5 ACRES
OF THE FORMER LANDFILL TO ADDRESS A TARGET RISK LEVEL OF 10-b
BACKGROUND
Contact with contaminated surface soils has been estimated by the EPA to
present a current risk to residents living on the site. The on-site ex-
posure period Tor children is assumed by the EPA to be 5 years, while
that for adults is assumed to be 52 years.
Relocation of the mobile home park rejidcrtv and control of future site
access will mitigate on-sit* risk. Umtar the assumption that site secur-
ity nay not be fully mainiiiT>«6, it is prudent to cover.the source areas
and to provide security fencing specific to these areas. Remcor consid-
ers the plausible caxinun case, current on-sit* use to be an adequately
cor.servaxive ba&i& xo.define the areas to be covered and fenced at a tar-
get risk level of 10"*, as presented in « Table 3-1.
BASIS FDR COMMENT
Because permanent relocation of the twbile hose park residents is a com-
ponent of the preferred alternative, current risk will be mitigated. The
plausible saxicua exposure point calculation for current on-site contact
with soils by children assumes an "awafe exposure period between ages 6
and 11* and children playing en the lite four days per week, six months
out of the year (EA, page C-2). Given the relaeation of current resi-
dents and the presence of institutional controls to control future devel-
opment, this represents a vtrj tsnswativ* future exposure scenario.
PAK and PCB concentrations drive tfce Tiaic. Therefore, covering and fenc-
ing an area of 1.5 acres, encoopass'mg faring* 05S-3, SO-04, 46, 60, 71,
77, 83, fi8,,MW-21f and OSS-6 will protect against the plausible maximum
risk of 10 . The target soil cleanup levels derived to protect against
dersa.1 contact with soils at a target risk level of 10"b are reported in
Table 3-1 of the FS.
COMMENT MO. 6: SELECTION UF CAP CCKFIGDltlOTOI SHOULD BE MADE ON THE
BASIS OF STUDIES PERFORMED DURING REMEDIAL DESIGN
BACKGROUND
The preferred alternative publicly announced by the EPA includes a very
specific design for capping at the site. A single-layer soil cap is
eliminated from consideration because of anticipated problems with crack-
ing (FS, page -4-14 and Exhibit 2, EPA Proposed Cleanup Plan) in favor of
a multi-layer cap relying on a jingle 40-mil flexible membrane to provide
an additional hydraulic barrier. Differential settlement is ongoing
within the KSW landfill as the wastes degrade. A flexible membrane liner
say not possess adequate tensile strength and elasticity to withstand
to* ttufinrrun
-------
Ks. Paula Fitzsimmons 25 August 23, *958
such subsidence over the life of the cap. Moreover, the cap design iden-
tified in the preferred alternative was taken from the EPA guidance docu-
ments for the design of new hazardous waste landfills. The conditions at
the Old Springfield site (e.g., manner of waste placement, compaction,
and cover; site preparation prior to waste placement; current stability
of the landfill surface) are quite different than those for a new hazard-
ous waste landfill. The EPA's specification of this design may be inap-
propriate to address site conditions. If a low-permeability cap config-
uration is required at this site, the cap design should not be defined in
the ROD. Rather, cap design should be specified only after remedial
design studies have been -completed.
EftSIS FOR COKKEKT
If a low-permeability cap design is deemed necessary for this site, it is
inappropriate to specify a particular cap design in the ROD if such spec-
ification eliminates the possibility to develop an equivalent cap config-
uration during remedial design. The pertinent Resource Conservation and
Recovery Act (RCRA) performance standards that provide guidance in design
of the cap for this site are those established at 40 Code of Federal
Regulations (CFR) 26^.310 for landfills. Such standards specify the fol-
lowing [40 CFR 26U.310U)]:
(a) At final closure of the landfill or upon closure of any
cell, the owner or operator oust cover the landfill or
cell with a final cover designed and constructed to:
(1) Provide long-term minimization of migration of
liquids through the closed landfill;
(2) Function with minimum maintenance;
(3) Promote drainage and sinicize erosion or abrasion of
the cover;
(U) Accommodate settling and subsidence so that the
cover's integrity is maintained; and
(5) Have a permeability less than or equal to the perme-
ability of any bottom liner system or natural sub-
soils present.
As a former MSW landfill, the Old Springfield site is susceptible to set-
tlement as the KSW materials degrade. The EPA recognizes that waste de-
gradation is continuing as evidenced by its incorporation of methane gas
collection and venting system in the preferred alternative. In addition,
residents have reported evidence of ongoing settlement within the
landfill.
tHAianc SOLUTIONS PON HAZARDOUS «*m mounts-
-------
Ms. Paula Fitzsimwons 26 August 23, 1955
Surface settlement is a particular concern in cap design in that such
settlement can lead to the mechanical failure of the cap system. Mechan-
ical failure leads, in turn, to failure of the hydraulic barriers to in-
filtration. The EPA technical handbook for cap design at uncontrolled
hazardous waste sites (McAneny, 1985) states the following:
"A thick barrier of compacted soil, while not completely im-
pervious, will be much more inherently durable and resistant
to mechanical failure than a barrier consisting of a single
thin membrane or member.*1
The cap design to be employed at the Old Springfield site, if any, will
have to consider the potential for differential settlement within the
MSW. A soil cap may prove more reliable than a flexible membrane. Such
an evaluation should be performed in the remedial design phase.
COMDTT HO. 7: THE DATA DEVELOPED IN THE REMEDIAL INVESTIGATION DO NOT
SUPPORT THE NEED FOR EXCAVATION OF AREAS BEYOND THE LIMITS OF THE FORMER
LANDFILL AND CONSOLIDATION OF THESE MATERIALS UKDER THE PROPOSED CAP
BACKGROUND
The draft final FS Report anticipates the need to excavate approximately
£,000 yd* of "waste" from Waste Area 1 and a second area in the north-
western portion of the site (Boring OSS-2) on the basis of the leaching
to ground water scenario (FS Figure 3-5). Based on the reasons set forth
in Comment No. 2 (e.g., erroneous foe value and water balance calcula-
tions), EPA's data do not show unacceptable risks in these areas result-
ing from ingestion of bedrock ground water. Risks due to inhalation of
chemicals in landfill gas (most notably chloroform) have been grossly
overstated in EPA's emission model, as discussed in Comment No. 3.
BASIS FOR COKKEKT
As discussed in Cement No. 2 concerning the waste areas on the eastern
side of the site, current site data do not support the need for remedial
action (source control) to address the satellite areas to protect bedrock
ground water. The low levels of PCBs and PAHs found at Boring OSS-2 (RI
Tables 3-5, 3-6, and 3-7) certainly will not migrate to and degrade bed-
rock ground water quality (see Tables 1 and 2). The 380 vg/kg of chloro-
form found in Surface Soil Sample 50-10 in Waste Area 1 (RI Table 3-5) is
also of questionable reliability in that previous sampling in this area
(Saaple OSS-10) revealed no detectable contamination.
• ~"~™™""
In addition, air emissions from Waste Area 1 were determined by the EPA
to pose an unacceptable on-site risk based on an inappropriately low foe
value for waste materials and the assumption that persons remain on site
for 70 years. Current site residents will be permanently relocated as
part of the preferred alternative. As discussed in Comment No. 3, EPA's
^CAUSTIC •eu/rioMS fo* MAZANOOVS WASTE MOIU«*•
-------
Ms. Paula Fitzsimmons 27 August 23, 1988
emission model grossly overestimates airborne concentrations. The calcu-
lations are appended to this comment letter (Attachment 1) to demonstrate
that the EPA emission model significantly overstates air concentrations
of contaminants. There is no basis for excavation and relocation of
"wastes" from Waste Area 1 or the vicinity of Boring OSS-2 to protect
against an unacceptable inhalation risk.
The risk of contacting contaminated surface soils, based on a target risk
level of 10 , suggests remedial action may be appropriate only at the
northwestern area in the vicinity of Boring OSS-2. This risk is driven
by the presence of three PAHs, each at the limit of analytical detection
(330 ug/kg) (RI Table 3-5). The finding of these contaminants in a
single sample at the limit of analytical detection is insufficient basis
for remedial action.
Therefore, the only action that may be warranted for the two outlying
areas identified by the EPA is covering and fencing of the area immedi-
ately surrounding Boring OSS-2. There is clearly no basis in risk for_
excavation of these areas.
COMMENT NO. 6: THE DESIGN OF THE LDOATE COLLECTION SYSTEM ON THE EAST-
ERN SIDE OF THE SITE SHOULD BE MODIFIED TO ADDRESS COLLECTION OF THOSE
SEEPS EVIDENCING CONTAMINATION, AND THE INSTABILITY OF THE EASTERN OUT-
SLOPES SHOULD BE CONSIDERED IN LOCATING THE COLLECTION SYSTEM
BACKGROUND
The preferred alternative incorporates installation of a continuous,
2,600-foot leachate collection trench at the approximate outcrop of
springs and seeps along the eastern outslopes of the plateau. The col-
lected leachate would then be conveyed to a central treatment unit
located on the plateau. The trench is shown in cross section in FS Fig-
ure 5-11. The constructibility of this trench is severely limited by
topography. In addition, documented slope instability on these steep
outslopes (FS, page 1-14) would constitute an ongoing threat to the in-
tegrity of the collection system. There is currently no justification on
the basis of risk or evidence of contamination to collect all eastern
springs and seeps.
An alternative design for the eastern leachate collection system should
be considered to alleviate potential problems associated with slope sta-
bility and difficulties in construction and maintenance of the system
resulting from placement of the collection trench on the outslope. In
addition, only those seeps evidencing contamination should be collected
at thi* time. Periodic monitoring of the remaining springs and seeps
will provide an indication of the need for collection of additional seeps
in the future. Accordingly, the ROD should specify the seeps to be col-
lected but provide the necessary flexibility for design of the collection
system during the remedial design phase of the project.
-*CALtSTlC SOLUTIONS fOH HAZARDOUS
-------
Hs. Paula fitisisror.s 28 August 23, 1953
BASIS FOR COMMENT
To be constructed to drain properly to a single catchment at the northern
extremity of the collection trench, as shown in FS Figure 5-1"t the
trench would have to follow the topography along the eastern outslopes of
the plateau. The extremely steep outslopes in the areas of Seeps LSE-1,
LSE-2, and LSE-3, and the ongoing degradation of the HSU and the inherent
instability of the outslopes of the landfill in these areas (FS, page
1-Hl) would present severe problems for construction and maintenance of
the systea. Clearing and grubbing of established vegetation on these
outslopes, necessary for installation of the interceptor, would further
exacerbate problems associated with stability of the slopes and would
blight the landscape in this area.
An alternative that would be more readily constructed and maintained
would include installation of a continuous main collector on a bench at
the base of the outslope, with laterals ascending perpendicular to the
grade to specific seeps to be collected. The seepage could be drawn to a
corsaon point via a french drain at the outcrop of the seep and conveyed
Into the .lateral downdrain. The french drains would be located at the
preferential outcrop of the seep (in cost cases the intersection of the
downslope toe of fill material and a former ravine on the outslope), and
would, therefore, collect all seepage at that point. The french drains
and lateral downdrains would also permit collection and conveyance of the
Jeachate with cini&al potential for emission of VOCs.
The continuous collection system is favored in the preferred alternative
over the alternative of collecting only the previously identified contam-
inated seeps (i.e., LSE-2, LSE-3, and LSE-K) (Alternative HH-2, FS, page
5-28). There is no current basis for collection of all seeps along the
eastern outslopes. A more prudent use of resources would be collection
of only those seeps evidencing contamination, with periodic monitoring of
the seeps to determine whether the pattern of contamination changes dur-
ing seep collection. Any additional contaminated seeps could then be
collected at that time.
Locating the nain collection piping on the existing bench and collecting
only those seeps identified as being contaminated would also result in a
«uch smaller area of disturbance of established vegetation along the
•astern outslopes of the plateau.
COMMENT NO. 9t PLACEMENT OF IKTERCEPTOR VELLS ALONG WILL DEAN ROAD INTO
THE SAND AND GRAVEL WATER-BEARING ZONE SHOULD BE REEVALUATED
BACKCROUKft
The preferred alternative anticipates installation of ground water inter-
ceptor wells along Will Dean Road into the sand and gravel water-bearing
•ftCAiisnc soumows n» MAZAADOUS
-------
Ms. Paula Fitzsinmons 29 August 23, 1985
zone overlying bedrock in this area. EPA concludes that this zone repre-
sents a preferential pathway for migration of contaminants from the for-
cer landfill to western leachate seeps to the northwest. Additional data
are required relative to this water-bearing zone prior to dewatering the
zone by Interceptor wells.
BASIS FOR COMMENT
Based on the supplemental RI studies in April 1988, EPA identified a sand
and gravel zone underlying the glacial till and directly overlying bed-
rock in the western portion of the plateau. EPA concludes that this zone
represents a drain for the till and bedrock because the hydraulic conduc-
tivity of this zone is approximately two orders of magnitude greater than
that of either till or bedrock (RI, page 9*0. Analytical results from
the sampling of Monitoring Well 29D, screened in the sand and gravel
zone, evidence cor,tar;nation by VOCs (RI Table 4-12). The preferred al-
ternative anticipates installation of interceptor wells into the sand and
gravel zone for extraction of contaminated ground water.
The recent identification of this zone, the lack of definition of its
boundaries and overall role in site hydrogeology, and the lack of an un-
derstanding of the effects of dewatering this zone on the hydrogeologic
regime and on domestic wells in the site vicinity argue for further defi-
nition prior to initiation of ground water interception and treatment.
COKMSKT KO. 10; LUCHHt (AND EXTRACTED GROUND WATER) FROM THE SITE
SHOULD BE PRETREATED AND DISCHARGED TO THE SPRINGFIELD PUBLICLY OWED
TREATMENT WORKS, RATHER THAN DISCHARGED DIRECTLY TO A SURFACE DRAINAGE
FOLLOWING ON-SITE TREATMENT
BACKGROUND
The EPA rejects discharge of leachate and ground water from the site to
the local P07V because of "failure to receive approval to discharge from
the POTW operator, and uncertainty as to treatment capabilities of POTW"
(FS Table 4-31 page 4-37). However, it appears that all parties agree
that treatment of any collected seeps and ground water at the POTW is
preferable to EPA's proposal for on-site treatment and discharge directly
to a surface drainage. Although all of the issues pertaining to treat-
ment at the POTW have not been finally resolved, these details should be
addressed through design studies during implementation of the ROD.
BASIS FOR COMMENT
W—MW—••••••^^••MH^a^^^W
Discharge of pretreated effluent from the site directly to surface wa-
ters, as proposed by EPA in the preferred alternative may entail the need
for more extensive on-site treatment capacity and redundancy to avoid un-
controlled releases of untreated leachate or extracted ground water from
the site. In addition, EPA's proposal does not fully consider aesthetic
FOM MAZANOOUS
-------
Ks. Paula Fitzsiranons 30 August 23, 1966
concerns raised by the local residents. It nay be possible to locate the
treatment plant adjacent to the POTW. The ROD should be flexible enough
to allow this result and need only specify the level of treatment re-
quired, cither on site or at the POTW.
COMKSKT NO. 11; THE SLURRY MALL PROPOSED BY EPA AS AN OPTION WITHIN THE
PREFERRED ALTERNATIVE WOULD HAVE LIMITED EFFECTIVENESS
BACKGROUND
The FS development of Alternative SC-2 (FS Section 5.2.2) incorporates an
optional slurry wall enclosing the approximate eight-acre cap on the
north, west, and south, and open to the east along the landfill out-
slopes. The wall would be three feet in width and constructed of a soil/
bentonite slurry to a depth of approximately 50.feet. At this depth, the
wall would be keyed into the low-permeability till. The stated objective
of the wall Is to coopleiaent the cap in restricting lateral flow of
ground wattr Iron up&radient areas through the wastes (FS, page 5-12).
The proposed slurry wall is shown in plan in FS Figure 5-2.
BASIS FOR COKMiKT
The slurry wall considered by the EPA would have limited success in re-
ducing lateral migration of ground water through the till and into the
waste uterial* along the outslope. Based on EPA's conceptual model of
ground water flow shown in HI Figure 4-9 (page 96), the sand and gravel
water-bearing zone acts a drain to encourage lateral ground water move-
aent to the west, rather than toward the former landfill. The slurry
wall in its present location (FS Figure 5-2) would counteract the effects
of the sand and gravel zone. If the sand and gravel zone behaves as EPA
contends, then the slurry wall would not be required to divert lateral
ground water movement around the wastes.
Other concerns relative to the construction and design of a slurry wall
include the iapact that such a wall nay have on altering the hydrogeo-
loglc regint Vn tht local area. For example, the eastern outslopes of
the plateau arc characterized by Instability. The potential effects on
the stability of the outslopes of diverting ground water flow around the
former landfill and discharging it in a concentrated Banner along the
outslopes at the tcrainus of the wall must be considered in evaluating
the advisability of altering site hydrogeology with a slurry wall.
CLOSING
Again, we appreciate the opportunity to provide these technical cotaaents
on the draft final project documents and the preferred alternative. We
trust that you will find them of value in proceeding with remedy
^CAUSTIC soivriows «• WUMDOVS
-------
Ms. Paula Fitzsinmons
31
August 23, 1966
selection. In addition, you will note that we have included resumes of
principal contributors to this consent letter in Attachment 2 for your
reference.
Very truly yours,
John A. George
Project Manager
Leo M. Brausch
Vice President
JAG:LMB:rmv
Attachments
cc: Mr. David Webster, EPA Region I
Mr. Williac Walsh-Rogalski, EPA Region I
•HULISTIC SOLUTIONS WDft MAZAXDOl* WASTf HIOILtttS"
-------
TABLES
•MAiisnc *oiimows ron «AZA*OOU« wart wo«t£«r
-------
TABLE 1
CORRECTION FACTORS FOR LEACHED MEDIUM CARBON CONTENT
... ORGANIC CARBON CORRECTION
COKTAMINAKT OF CONCERN^1' PARTITION COEFFICIENT^2' FACTOR13'
Benzene 65 44
Chloroform 44 30
Methylene chloride 8.8 6.9
Tetrachloroethylene 36U 220
Trichloroethylene 126 83
Bis(2-ethylhexyl)phthalate 2.0 x 10* 2,200
PCBs^ 1.1 x 106 2,200
PAHs(5) 5.5 x 106 2,200
^Contaminant of concern are those identified in FS Table 3-18 as sig-
nificant for the ground water ingestion risk scenario.
^The organic carbon partition coefficient is an intrinsic chemical
property reflecting the tendency of the chemical to adsorb to organic
carbon in so.lids and not leach. Values were taken from Mabey, et al
(1952).
^Calculated using formula A-10 given in FS Appendix A, page A-21. All
EPA input data were used except foe * 5 percent.
PCBs. Organic carbon partition coefficient is for Aroclor 125*1.
carcinogenic PAHs. Organic carbon partition coefficient is for
benzo-(a)-pyrene.
-
•nt«ifjTJc toiimows nn MAIAKDOVS WASTC MOILCMS- (»*a
-------
TABLE 2
RETARDATION FACTORS FOR ATTENUATION
OF COKTAHJNAKTS FLOWKG THROUGH TILL
,,. ORGANIC CARBON ,_. RETARDATION
COK7AKINAVT OF CONCERN*1' PARTITION COEFFICIENT2' FACTOR(3)
Benzene 65 45
Chloroform 44 31
Methylene chloride 8.8 6.9
Tetrachloroethylene 364 250
Triohloroethylene 126 « 86
Bis(2-ethylhexyl)phthalate 2.0 x 109 1.4 x 109
PCBs(1J) 1.1 x 106 7.* x 105
5.5 x 106 3.7 x 106
'^Contaminant of concern are those identified in FS Table 3-18 as sig-
nificant for the ground water ingestion risk scenario.
t^The organic carbon partition coefficient is an intrinsic chemical
property reflecting the tendency of the chemical to adsorb to organic
carbon in solids and not leach. Values were taken from Habey, tt al.
(1982).
(^Calculated using formula for retardation (R) given in FS Appendix A,
page A-21; foe * 5 percent as typical value. The retardation factor
is the. ratio of ground water flow velocity to the apparent contaai-
nant migration velocity (Wilson, et al., 1981).
PCBs. Organic carbon partition coefficient is for Aroclor 1254.
carcinogenic FAHs. Organic carbon partition coefficient is for
benzo-(a)-pyrene.
•MCAianc * otimows ro» HAZAAOOVS
-------
TABLE 4
STATISTICAL SUKKAR* OF SEEP FLOW MEASUREMENTS*1
PARAMETER EASTERN SEEPS WESTERN SEEPS TOTAL
Nunber of neasurements
Arithmetic Bean (gpm)
Median (gpm)
Standard deviation (gpm)
Mininuo (gptc)
Kaxiaua (gptn)
True mean (t- interval)
6
71.7
66.5
U5.5
8.5
1U3.0
2H.O to 119.5
5
01.8
39.0
8.3
. 3«.2
55.1
31.5 to 52.1
11
113.5
105.5
-
H2.7
198.1
- 55.5 to 171.6
at 95 percent confidence
limits
taken from Rl Table 4-6.
nn MAZAXDOUS wtsrt
-------
wocm or ciorn u?n noi
IUID:I i;nm now; TO TIIiu:i urn
riuinn
mimic tomnnm
rnmic
(CILCtUTlOI 10. 1)
iedrock frond liter
tlevitioi IH-1
liver titer itrfiee
eleutloi
?otettioittrie lead
II-i to river
leriiotlil iiitiiee Iroi
ll-i U river
lltriBlic indieit
HITS
ei/iee
ieet
ieet
It/It
wn ;
iisis/iimici
S.8SI-0! ! lediu vilie froi
! (11, Trile 4-4, hie li).
ttiti
5i5 ; leu tlevitioi froi ituoreieiti
! l/21/n Un J/JO/J! *
! (11, Trile 4-3, file 12).
JCi ; t.S. Bepirtiett of tbt literior,
! 6eelo|ietl Serve!, U-Eitste
• lopoirpiUe Qoiirucle, Clireiott,
! It TI, dited »ST, icilt l:i2SOO.
2iC i PUftrttct ii ictd leteli it Ill-i
I ud river urliee elevitioi.
1.ICD ! Inured (roi 11 uppiif
! (11, fifire 4-1).
J.1JS ; Cilocslited iroi poteitioietrie
« keid differeiee ltd koriioitil
1 4iituee iroi ll-i U river.
•ftCAifsnc toiimows m* NAZAMOOUS WAJTI MOIUWS*
-------
lilll 5
CCHIIEU)
mums
mimic tmitiT
(C11C8L1110I 10. 2)
Bedrock froatd liter
tlentlot leir tetter of
.lite
Bedrock (rtut titer
cleutiot it BHt
Potettioictric ketd
tetter of lite to 11-20
loritottil diititce froi
tetter ef lite to 11-20
Irdraillc fradiett
Bedrock nsifer foroiltj
Bedrock iroud liter
flei telKilr
Bedrock freud liter
lloi telocitr
HITS
iMil
fMtl
feet
feet
ft/ft
ft/JT
ftm
HIM ; iisis/HHiuci
445 ! 11, riicrti 4-1 tkreajk 4-1
HO 1 1], Tillt 4-3, Put 92
115 I lifferetce ii lead Imli
1,425 ! lettered froi 11 u??i:j
! (11, Ilisre 4-1).
I.Dtl ! Cihcthted froi ptettioietrlc
J ktid dif(eret:e ud koriiotUl
! dittuee
1.15 ! Beit for *fri:ttred crritillite
! rock* (Freeie ud Ckeerj, ISIS;
! Iille 2.4, Fife IT).
140 J C&lcslited froi kydriellc eotdoctiritT,
! peroiltT, ud fridiett cilcohUoa 1.
10 I CilcBlited froi kydnclic totdoctiTity,
{ KrotitT, ud crtdiett tilcalitiot 2.
i
i
<*£ALIST7C SOitfTtOHS PON NAZMOOUS WUTt H>OfLtM5'
-------
REFERENCES
tonrriom ro* HAZARDOUS
-------
LIST OF REFERENCES
DeMarco, J., D.J. Keller, J. Leckman, and J.L. Newton, 1969, "Municipal-
Scale Incinerator Design and Operation," U.S. Department of Health, Edu-
cation, and Welfare, Public Health Service, Bureau of Solid Waste Manage-
ment, Washington, DC.
Doll, C.C. (ed.), 1970, "Surficial Geologic Map of Vermont," prepared by
D.P. Stewart and P. MacClintock, State of Vermont, Montpelier, Vermont.
Ebasco Services, Inc./ICF, Incorporated (1CF), June 19B8a, "Draft Final
Feasibility Study Report, Old Springfield Landfill Site, Windsor County,
Vermont," prepared for EPA Region I, Boston, Massachusetts.
Ebasco Services, Inc./ICF, Incorporated (1CF), June 1988b, "Draft Final
Supplemental Remedial Investigation Report, Old Springfield Landfill
Site, Windsor County, Vermont," prepared for EPA Region I, Boston,
Massachusetts. »
Ebasco Services, Inc./ ICF-Clement Associates, Inc. (Clement), June 1965,
"Draft Final Endangerwent Assessment, Old Springfield Landfill Site,
Windsor County, Vermont," prepared for EPA Region I, Boston,
Massachusetts.
Freeze, R.A. and J.A. Cherry, 1979, Crounduater. Prentice-Hall, Inc.,
Englewood Cliffs, New Jersey.
Mabey, V.R., J.H. Smith, R.T. Podoll, H.L. Johnson, T. Mill, T.W. Chou,
J. Gates, I. Wright Partridge, H. Jaber, and D. Kandenberg, 1982, "Aqua-
tic Fate Process Data for Organic Priority Pollutants,"
U.S. Environmental Protection Agency, Office of Water Regulations and
Standards, Washington, DC.
Martin, J.P., R.M. Koerner, and J.E. Whitty, 1985, "Experimental Friction
Evaluation of Slippage Between Gee-membranes, Geotextiles and Soils,"
International Conference of Geomeobranes , Denver, Colorado.
McAneny, C.C., P.O. Tucker, J.M. Morgan, C.R. Lee, M.F. Kelley, and R.C.
Hort, 1985, "Covers for Uncontrolled Hazardous Waste Sites," EPA/5MO/2-
65/002. U.S. Environmental Protection Agency, Hazardous Waste Engineering
Research Laboratory, Cincinnati, Ohio.
Tchobanoglous, G., H. Thiesen, and R. Eliassen, 1977, Solid Wastes. Engi-
neering Principles and Management Issues. McGraw-Hill Book Company, New
York, New Xork.
U.S. Environmental Protection Agency (EPA), June 1988, "EPA Proposes
Cleanup Plan for Old Springfield Landfill Site," EPA Region I, Boston,
Massachusetts.
Wilson, J.T., D.G., Enfield, W.J. Dunlap, R.L. Cosby, D.A. Foster, and
L.B. Baskin, 1981, "Transport and Fate of Selected Organic Pollutants in
a Sandy Soil," Journal of Environmental Quality. Vol. 10, No. kt pp.
501-506.
•nfcuianc sou/news rot HAZARDOUS
-------
ATTACHMENTS
•MCAirSftC SOLUTIONS POft MJJAXOOl/C WASTE MO»l«W*
-------
ATTACHKEWT 1
EVALUATION OF IKHALRTIOK RISK
ttALISTIC SOLUTION* fO* MAZAftDOl/S WASTE MOiLMM"
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ATTACHMENT 2
RESUMES
•HtAirjTJC lOUfTIQNS fOK HA2AKDOUS
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LEO M. BRAUSCH
VICE PRESIDENT
y
EDUCATION
M.S., 1976, Civil and Environmental Engineering, University of
Cincinnati
B.S.C.E., 1975, Civil and Environmental Engineering, University of
Cincinnati
REGISTRATION
Professional Engineer: Mississippi, New Mexico, Ohio, Pennsylvania,
South Carolina
Emergency Medical Technician: Pennsylvania
PROFESSIONAL EXPERIENCE
1985 to Present: Mr. Brausnfa is Viet President of Remcor in responsible
charge of the Engineering and Project Development Division. In this
role, he has served as the director and key technical contributor for
approximately 100 site investigation and site cleanup projects. Exam-
ples of key experiences follows:
• Investigation and subsequent cleanup of a 90-acre
industrial complex in western Pennsylvania. This
project involved the assessment of contamination
and design and implementation of remedial measures
associated with: polychlorinated biphenyl (PCB)
decontamination of plant feuildings, equipment, and
process sewers; closure of a former PCB waste dis-
posal area; decontamination and closure of elec-
troplating facilities; and plant-wide removal of
asbestos-containing materials.
• Subsurface investigations and design of cleanup
programs associated with petroleum hydrocarbon
(PHC) contamination at two sites in New Jersey.
Work involved assessing contamination from leaking
underground storage tanks, spills, and other
* sources. Remedial measures evaluated include free
product recovery, ground water treatment, tank re-
noval, tank closure, bioreclaaation, and slurry
vail containment.
«*r*i ftnp tf>i
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LEO M. BRAUSCH 2
• Remedial investigation/feasibility study (Rl/FS)
under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of a six-
acre landfill containing in estitrated 100,000 cubic
yards of PCB-contaninated materials. After exten-
sive site studies, three technically feasible,
cost-effective remedial alternatives were
developed.
• The Resource Conservation and Recovery Act (RCRA)
closure plan development and implementation for
five surface impoundments containing 8,000 cubic
yards of electroplating sludge at a site in Mis-
sissippi. The closure involves en-site deuatering
of the sludge, in-situ containment of contaminated
soils, and ground water recovery/treatment. In ad-
dition, potential continuing releases from other
on-site solid waste management units (SWMUs) are
being investigated.
• Subsurface investigations of volatile organic con-
tamination associated with former drummed and bulk
solvent disposal areas and underground solvent
storage tanks at five industrial plant sites. The
investigations included borings, soil and ground
water testing, and use of an organic vapor analyzer
to determine the presence of subsurface volatile
organic contamination.
Mr. Brausch has also served as an expert witness. For a major civil ac-
tion involving PCB contamination of five industrial facilities in three
states, Mr. Brausch testified relative to contamination assessment meth-
ods, decont*sination procedures and costs, and PCB transport mechanisms
and pathways In interior settings. In adjudicatory hearings for a pro-
posed hazardous waste landfill in Ohio, Mr. Brausch addressed design,
construction, operational, and closure issues.
1980 to 1985: Mr. Brauseh served as the Manager of Project Development
for IT Corporation in Pittsburgh, Pennsylvania (formerly D'Appolonia
Waste Management Services). His primary role was in the planning and
development of remedial response programs for formerly utilized waste
disposal sites. Representative experiences included the following:
• Project manager for the investigation of the degree
. and extent of PCB contamination at seven facility
locations in five states. These projects included
development and execution of investigation pro-
grams? evaluation of alternative decontamination
technologies, and preparation of detailed decontam-
ination plans and cost estimates.
IIAIJSTIC SOIVTJOMS POM HAZARDOUS
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JOHN A. GEORGE
PROJECT HAS'ACER
EDUCATION
M.S., 1976, Terrestrial Ecology, Clarion University of Pennsylvania
B.S., 1975, Biology, Clarion University of Pennsylvania
PROFESSIONAL EXPERIENCE
1987 to Present; Mr. George Joined Remeor in 1987 as a Senior Scientist
in the Engineering and Project Development Division. As Manager of the
Geosciences Group, Mr. George is responsible for project scheduling,
budgetary control, resource allocation, technical direction, review of
deliverable*, and. client liaison. The Geosciences Group'is primarily
responsible for site characterization, especially in the area of ground
water contamination issessaent. The Group also participates in remedial
alternative evaluation.
Mr. George is presently uanaging a remedial investigation/feasibility
study (RI/FS) focusing on volatile organic ground water contamination at
a National Priority List site near Allentown, Pennsylvania. This RI/FS
is being conducted by Remcor on behalf of the potentially responsible
party. Mr. George has participated in numerous site characterization
efforts. Included anong these are studies of waste management units at
electronics components manufacturing facilities and abandoned steelmak-
ing facilities, and wastewater settling lagoons at a primary aluminum
reduction facility. He was also one of the principal authors of a Rem-
cor study of potential effects of the U.S. Environmental Protection
Agency (EPA) Resource Conservation and Recovery Act (RCRA) Corrective
Action Program on the domestic steel industry. This in-depth study was
performed for the American Iron and Steel Institute (AISI).
1982 to 1987; Mr. George served as a Project Manager in the Waste Man-
agement Services Division of NUS Corporation in Pittsburgh, Pennsylvan-
ia. During much of this period NUS was the prime contractor to the EPA
for Remedial Planning and Field Investigation Team (FIT) support for the
Superfund Program. Mr. George participated In several RI/FSs at Compre-
hensive Environmental Response, Compensation, and Liability Act (CERCLA)
sites, both technically and in a managerial role. The following pro-
vides a representative listing of project experience:
*» Croveland Veils Site, Groveland, Massachusetts
Project Manager - RI/FS for 620-acre municipal
wellfield In northeastern Massachusetts contami-
nated, with volatile organics, principally tri-
chloroethylene (TCE).
i&unrnc SOLUTIONS PON MAZANDOVS WAIT* MtoaitMS*
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JOHN A. GEORGE 2
• Charles George Land Reclamation Trust Landfill
Site, Tyngsboro, Massachusetts
Project Manager - RI/FS for 70-acre municipal and
industrial waste landfill in northeastern Massa-
chusetts overlying contaminated fractured bedrock
aquifer tapped by domestic wells; total landfill
volume approximately four million cubic yards.
• Cannon Engineering/Plymouth Site, Plymouth,
Massachusetts
Technical Lead - Wetlands and Floodplain Assessment
In support of Feasibility Study.
• Drake Chemical Site, Lock Haven, Pennsylvania
Technical Lead - Assessment of vegetative stress
due to discharge of herbicides from a former manu-
facturing facility.
• Sullivan's Ledge Site, New Bedford, Massachusetts
Project Manager - RI/FS for volatile organic/poly-
chlorinated biphenyl (PCS)/metals disposal in aban-
doned quarry pits.
• Leetown Pesticide Site, Leetown, Vest Virginia
Project Manager - RI/FS for evaluation of 2.5-
square Bile watershed contaninated through indis-
crieinant disposal of pesticides and the use of
agri chemicals.
• Leetown Pesticide Site, Leetown, Vest Virginia
Project Manager - Bench Scale Treatability Study of
Microbial Degradation of Pesticides by Indigenous
Soil Microbes.
1980 to 1982; Mr. Ceorge served as Director of Mining Services with
Penn Environmental Consultants (acquired by KUS Corporation in 1981),
supervising a staff that provided complete engineering and permitting
services to several moderate-sized Appalachian surface mining interests.
1979 to 1980; Mr. Ceorge served as a principal investigator with
Michael Baker Corporation, Beaver, Pennsylvania. His responsibilities
involved •environmental assessments for utility line construction and de-
velopment of environmental baseline data for mining operations.
1977 to 1979; Mr. Ceorge served as Supervisor of the Land Stabilization
and Reclamation Program (Surface Mining Reclamation) at Belmont Techni-
cal College, St. Clairsville, Ohio.
^EALISTTC SOLimOMS PD* MAZAftDOVS WASTf MO«L0*S*
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LEO H. BRAUSCH 3
• Project manager for the preparation of a RCRA
closure plan for a formerly used secondary lead
smelter site in Florida. The project involved a
comprehensive contamination survey, subsurface
exploration, and ground water monitoring. Mr.
Brausch headed the design teas for waste removal,
facility decontamination, and ground water treat-
Bent aspects of the closure.
• Project director for the preparation of the RCRA
closure plan for two lagoons (containing nearly
100,000 cubic yards of nixed organic and inorganic
sludges) at a plant site in southern Ohio. The
closure plan calls for dewatering and physical
stabilization of sludges preparatory to on-site
containn*nt.
«
In addition to such assignments, ftr. Brauscb served as an in-house con-
sultant in health and safety programs; air quality monitoring during
waste site cleanup; and waste analysis, manifesting, transportation, and
disposal.
1976 to 19BO: Hr. Brausch served as the Lead Engineer, Environmental
Issues, for the environmental and safety analysis of the Waste Isolation
Pilot Plant (VIPP) proposed for a. site east of Carlsbad, New Mexico.
This position involved coordinating and leading investigations attendant
to all environmental permits, approvals, and compliances required for
this radioactive waste storage/disposal facility.
1976 to 1978: Mr. Brausch served as a project leader and technical con-
tributor on interdisciplinary environmental investigations and engineer-
ing designs. His principal involvement was in environmental peraitting
and the design of pollution control facilities. Representative techni-
cal taste aivd responsibilities included air quality and meteorological
monitoring, preparation of emission inventories, and evaluations of con-
trol technologies for new-source air quality permitting. Mr. Brausch
also prepared the process, hydraulic, and structural design of industri-
al wastewater treatment, facilities. Key issues in the treatment schemes
included the design and economic analysis of alternative treatment
schemes (e.g., precipitation/clarification, ion exchange, biological);
conveyance and disposal of metal hydroxide and organic sludges; and
plant start-up, operation, and maintenance.
1972 te 1976: Prior to receiving his degrees, Mr. Brauseh worked part
time as an engineering technician in wastewater treatment design, high-
way planning, and surveying.
•RCAia TIC soitmoNs ron HAZARDOUS
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LEO H. BRAUSCH H
PUBLICATION'S AND PRESENTATIONS
Husak, A. D., L. M. Brausch, and B. P. Bundy, 1985, "Recent Experiences
In Waste Site Remedial Action," Symposium Proceedings. American Insti-
tute of Chemical Engineers 1985 Soring National Meeting. March 25
through 28, Houston, Texas.
Brausch, L. M. and J. S. Lewis, Jr., 1984, "Case Study: Leachate Con-
tainment System Installation, Lipari Landfill, Pitman, New Jersey,"
Superfund Update: Cleanup Lessons Learned, symposium sponsored by
Center for Energy And Environmental Management, Hay 21 and 22, Denver,
Colorado.
Brausch, L. M., 1984, "Advances in Ground Water Treatment Technology,"
General Electric Environmental Protection Seminar. April 25 through 27,
Philadelphia, Pennsylvania.
4
Brausch, L. K., 1983, "Implementation of Remedial Action Program, Enter-
prist Avenue Site," Proceedings. Conference on the Disposal of Solid.
Lie-Jig, and Hazardous Wastes. American Society of Civil Engineers, April
26 and 29, Bethlehem, Pennsylvania.
Brausch, L. H., 1982, "Siting and Design of Hazardous Waste Landfills,"
Hazardous Wastes Generation and Management Conference. June 9 and 10,
1982, Pittsburgh, Pennsylvania.
Brausch, L. M., 1982, "Design and Construction of Landfills for Hazard-
ous Wastes," International Conference on Technology and Technology
Exchange. Kay 3 through 6, 1932, Pittsburgh, Pennsylvania.
Hohaann, G. L. and L. M. Brausch, 1981, "Environmental Impact and Pro-
tection for the Waste Isolation Pilot Plant (WIPP)," Waste Management
•61. American Nuclear Society Topical Meeting, Tuscon, Arizona.
Laushey, L. M. and L. M. Brausch, 1979, "The Geometries of Rill Forma-
tion on Hillsides," Proceedings of the XVIII Congress of the 1AHR.
International Associated for Hydraulic Research, Caligari, Italy.
Brausch, L. M., 1976, "Observations on Rill Pattern Development,"
Master1* Thesis, University of Cincinnati, Cincinnati, Ohio.
C02298
mcAtisnc SOLUTIONS ron HAZARDOUS WAJTC motif MS*
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JOHN A. GEORGE 3
PREVIOUS PROFESSIONAL AFFILIATIONS
American Chemistry Society
American Institute of Biological Sciences
Pennsylvania Mining Professionals (Vice President, 19B1/1982)
Soil Conservation Society of America
PUBLICATIONS
Hubbard, A. E., J. A. George, R. Hubbard, and V. Hagel, 1986, "Quantita-
tive Risk Assessment as the Basis for Definition of Extent of Remedial
Action at the Leetoun Pesticide Superfund Site," Presented at the HHCRI
Superfund '86 Conference, Washington, DC.
George, J. A., 19B2, "Erosion and Sedimentation Control Alternatives -
Surface Mining in Northern Appalachia," presented at the.Fifth Annual
Meeting of the Water Pollution Control Association of Pennsylvania,
Pittsburgh, Pennsylvania.
i
George, J. A.j 1976, Seasonal Weight and Activity Relationships in a
Free-Ranging Population of the Eastern _Chipr.-jnk (Ts-?.ias striatus) Roiien-
tia*. Sciuridae. tester's Thesis, Clarion State College.
E010U8
•»tAi.«T7C SOLtmONS to* KA2AADOUS
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WILLIAM E. RQSEKBAUM
PROJECT MANAGER
EDUCATION
M.S., 1983, Business Administration, Robert Morris College
B.S., 197U, Civil Engineering, University of Notre Dame
REGISTRATION
Professional Engineer: Pennsylvania
Certified Sewage Treatment Plant Operator: Pennsylvania
Certified Waterworks Operator: Pennsylvania
•
PROFESSIONAL EXPERIENCE
1987 to Present; Mr. Rosenbausi Joined Reacor as a Project Manager in
the Engineering Design Croup. His responsibilities include project man-
agement and key technical contributions related to remedial action de-
sign. His project experience at Reacor includes:
• Design of codifications to the closure of a series
of hazardous waste holding lagoons to optimize the
design, reduce construction costs, and expedite
completion of the closure.
• Development of a work plan for the site stabiliza-
tion of a former metals processing facility. The
site was contaminated with radioactive thorium and
heavy metals.
• Preparation of plans and specifications for the
upgrade of the hazardous waste landfill owned and
operated by a major chemical manufacturer. The
project included design of a double-lined leachate
basin, capping of a portion of the landfill, and
upgrade of the drainage and leachate collection
system.
• Preparation of remedial investigation/feasibility
studies (RI/FSs) for three manufacturing facilities
contaminated with polychlorinated biphenyls (PCBs).
Selected remediation activities included surface
cleaning, concrete Billing, and building subsoil
excavation.
•HtlUSTJC SOLUTIONS fOK HAZARDOUS
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WILLIAM E. ROSENSAUM 2
1981 to 1987; Mr. Rosenbaum served as t Senior Engineer and Assistant
Engineering Manager responsible for the Environmental Design Croup of
Baker/ISA Inc. As Assistant Engineering Manager, he managed a group of
18 engineers and technicians and was responsible for the following:
• Technical quality control.
• Personnel performance reviews.
• Preparation of proposals.
• Budgetary control of design projects.
His najor project experience at Baker/TSA Inc. included the following:
• Project Manager for grading and capping of a haz-
ardous waste landfill in New Jersey. The project
included regrading, installation of waterways,
leachate collection system, gas vents, and low-
permeability soil cap. Total construction cost of
the grading and capping project was $U.5 Billion.
• Design Manager for the preparation of plans, speci-
fications, operations and permitting for radiolog-
ical contamination removal in Essex County, New
Jersey. Project budget was $12 Billion and requir-
ed the preparation of detailed plans and specifica-
tions in six weeks. The project included contracts
for construction, transportation and disposal and
involved resident relocation, radiological health
and safety procedures, public relations, and util-
ity coordination.
• Project Engineer for the preparation of plans and
specifications for the closure of a hazardous waste
landfill owned and operated by a major steel com-
pany. The project included regrading, installation
of a clay cap, leachate, and runoff piping.
• Project Engineer for the preparation of plans and
specifications for the design of a fly ash disposal
landfill located on the banks of the Ohio River.
• Developed, for a major steel corporation, portions
of a Comprehensive Hazardous Waste Management Plan
dealing with wastewater treatment, storage, and
disposal. The plan reviewed options and developed
• alternatives to economically comply with hazardous
waste and National Pollution Discharge Elimination
System (NPDES) regulations. Alternatives reviewed
included recycle/reuse, operations and process mod-
ifications and waste reduction measures.
UAusnc soiimows nn MAZANOOVS VASTE Mo«it«r
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WILLIAM E. ROSEN8AUM 3
• Designed and supervised preparation of drawings and
specifications for a wastewater treatment facility
to store and treat runoff from a 35-acre coal han-
dling facility in Ashtabula, Ohio. The project in-
cluded an equalization lagoon constructed at lake
level using slurry wall technology.
1977 to 1981; Mr. Rosenbaun served as a Process Project Engineer for
The Chester Engineers, Inc., Coraopolis, Pennsylvania, where his duties
Included the following:
• Design Manager for the excavation and removal of a
sanitary landfill in New Jersey. The landfill
consisted of approximately 20,000 cubic yards of
municipal sanitary waste. Out-of-state disposal
was selected by the state for final disposition of
the waste. •
• Supervising facility design projects for various
industries, including the design and construction
of hazardous waste handling facilities in compli-
ance with Resource Conservation and Recovery Act
(RCRA) requirements.
• Obtaining permits from state and federal agencies.
• Preparation of itemized construction cost estimates
and in-house construction supervision.
Following is a summary of Mr. Rosenbaua's major project experience:
• Designed and provided general inspection services
for the construction of a double lined-hazardous
waste holding lagoon for a major electronics manu-
facturer. The facility included two, one-million
gallon compartments each equipped with a double
liner with intermediate leak detection and collec-
tion system. All piping to and from the facility
was installed in a casing pipe with a separate leak
collection system.
• Project manager for the $5 million addition to the
wastewater treatment facility owned by a heavy
equipment manufacturer in Illinois. The project
• included API separation, clarification, thickening,
vacuum filtration, shallow bed sand filtration, and
chrome treatment.
• Lead project engineer for the design of additions
to an existing treatment facility owned by a manu-
facturer of electronic components. The system,
^UAtanc soiuriows ro* HAZARDOUS
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WILLIAM E. ROSEKBAUM 4
designed for the treatment or ion exchange spent
regenerate, Including softening, reverse osmosis,
and double-lined solar evaporation ponds.
• Lead project engineer for the design of a batch
treatment system to remove arsenic and selenium
from rinse waters generated in the manufacture of
copy equipment. The system was designed around a
process utilizing activated alumina.
1976 to 1977! Mr. Rosenbaura served as a Resident Engineer for Black and
Veatch Consulting Engineers. His responsibilities included construction
supervision for the purpose of assuring compliance with plans and speci-
fications and surveying.
197<< to 1976: Mr. Rosenbaum served with U.S. Air Force, 351st Strategic
Missile Wing as a Missile Launch Officer. *.
PROFESSIONAL AFFILIATIONS
Aaerican Society of Civil Engineers
American Water Works Association
Kattr Pollution Control Federation
E01048
•HEAtisnc soitmows AM MAZ*DOUS
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ANDRZEJ NMAR
SENIOR HYDROGEOLOGIST
EDUCATION
M.S., 1962, Geology, Academy of Mining and Metallurgy, Cracow, Poland
Specialization: Kydrogeology and Engineering Geology
REGISTRATION
Certified Professional Geologist: North Carolina
Certified Professional Geological Scientist: United States
Professional Engineer: West Germany
Professional Engineer, Geotechnical Engineering: Poland
Professional Engineer, Hydrogeology: Poland
•
PROFESSIONAL EXPERIENCE
1?57 to Present; Mr. Nazar Joined Reaeor as a Senior Hydrogeologist.
In this position, he is responsible for project planning, senior techni-
cal review, development of field investigative procedures, and direction
of activities of staff geologists and hydrogeologists.
1981 to T987: Mr. Kazar served as a Principal Hydrogeologist and man-
ager of the Earth Science Group at NUS Corporation (KUS), Pittsburgh,
Pennsylvania. He served as a technical advisor to management for the
oversight and review of hydrogeological investigations at privately-
owned waste disposal facilities and at uncontrolled hazardous waste
sites and contaminated municipal wellfields under the U.S. Environmental
Protection Agency (EPA) Superfund Prograa. He was also involved in the
recommendation and review of geotechnical engineering feasibility stud-
ies for the remediation of surface and ground water contamination and
for the Resource Conservation and Recovery Act and Comprehensive Envi-
ronmental Response, Condensation, and Liability Act (RCRA/CERCLA) plan-
ning and management.
While at KUS, Mr. Kazar managed a staff of more than 20 geologists, hy-
drogeologists, geophysicists, geochemists, and geotechnical engineers,
performing subsurface investigations at hazardous waste sites, land-
fills, wellfields, surface and deep mines, fly ash and coal refuse
sites, and petroleum tank farms. He was ultimately responsible for
technical job quality, project budgeting, scheduling, and staffing, and
conducted on-site technical supervision and staff training at projects
in the field.
1978 to 1980: Mr. Kazar served as an engineer with Frankland and
Lienhard Consultants, New York, Kew York. He was principally involved
in the design of drainage systems for highways and roads and evaluated
geotechnical conditions for highway construction projects.
•REA1ISTTC SOLUTIONS fO* MAZAADOVS
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ANDRZEJ NAZAR 2
1967 to 1976; Mr. Nazar directed tnd supervised the technical and ad-
ministrative activities of the Mining Department at the Research Center
of Mining Technology, Cracow, Poland. He was responsible for project
management, budget control, client contact, and business development.
He directed programs in environmental geology and hydrogeology for pub-
lic work facilities, Industrial installations, and Bining operations,
and was responsible for conducting ground water exploration programs and
ground water studies for water supply and mining projects. He managed a
field office consisting of a technical staff of more than 100 personnel,
specializing in the area of sulfur recovery mines. Responsibilities in-
cluded drilling supervision, staff inspection, and development and coor-
dination of injection and production well sites for the maximum recovery
of sulfur from the deposit. He conducted research on the determination
of geothermal conditions of ground water reservoirs in sulfur deposits
and evaluated the environmental impact of mining on regional ground
water tlou and quality.
1962 to 1967: Mr. Nazar served as Senior Hydrogeologist/Hydrogeologist
for. Hydrogeological Engineering Consulting, Inc., Cracow, Poland. He
designed and supervised several projects for the dewatering of open pit
mines, and conducted supply projects to define aquifer characteristics
and ground water quality, and evaluated the impact of proposed with-
drawals on adjacent water supplies. He also designed water wells and
supervised well drilling and Installation, pumping tests, piezometer
tests, and pressure-bead tests. Mr. Kazar supervised geotechnical in-
vestigations for dans, power plants, and mining and performed surface
geologic mapping for reservoir siting studies.
PROFESSIONAL AFFILIATIONS
American Institute of Professional Geologists *
National Water Well Association
PATENTS
A New Mixture for Plugging the Hot Water Outflows from Sulfur Recovery
Wells, Nr. P. 158 398, Poland, 10, 20, 1972.
A New Technique for Plugging the Hot Water Outflows from Sulfur Recovery
Bells, *r. P. 1H6 772, Poland, 3, 9, 1971.
PUBLICATIONS AND PRESENTATIONS
Orient, J., A. Nazar, and R. Rice, 1986, "Vacuum and Pressure Test,
Methods for Estimating Hydraulic Conductivity," Monitoring Review.
•
Prieur, J., A. Nazar, and A. Reehnagel, 1986, "Performance of Aquifer
Evaluation Testing at Uncontrolled Hazardous Waste Sites,*1 presented at
the International Symposium on Management of Hazardous Chemical Waste
Sites, Winston-Saiem, North Carolina.
itXAurnc sotimoNS re* MATANDOUS
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JLKDRZEJ NAZAR 3
Nazar, A., D. Threlfall, and L. Casper, 1985, "Croundwater Protection,"
1985, Pennsylvania Natural Gas Producer.
Dowiak, M. and A. Nazar, 1984, "Assessment of Croundwater Contamination
and Remedial Action for a Hazardous Waste Facility in a Coal Mine Region
in Southwestern Pennsylvania", presented at the National Conference on
Management of Uncontrolled Hazardous Waste Sites, Washington, DC.
Nazar, A., J. Prieur, and D. Threlfall, 198U, "Use of Multi-level Gas
Driven Samplers and Conventional Monitoring Wells for Evaluation of
Croundwater Contamination at an Uncontrolled Hazardous Waste Site," pre-
sented at the Seventh Annual Madison Waste Conference sponsored by the
University of Wisconsin, Kadison, Wisconsin.
Kazar, A., J. Prieur, and D. Threlfall, 198U, "Integrated Groundwater
Monitoring Program Using Multi-Level Gas Driven Samplers and Convention-
al Monitoring Wells at an Uncontrolled Hazardous Waste Site," Monitoring
Review.
Dowiak, M. J., R. A. Lucas, A. Nazar, and D. Threlfall, 1982, "Selec-
tion, Installation, and Post-Closure Monitoring of a Low Permeability
Cover over a Hazardous Waste Disposal Facility," presented at the Na-
tional Conference on Management of Uncontrolled Hazardous Waste Sites,
Washington, DC.
Onderka, W. and A. Kazar, 1973, "Techniques of Prevention of Geysers and
Outflows of Not Intersediate Water from Sulfur Deposit to the Surface in
Sulfur Recovering Mines Using Modified Frasch Process," Bezpeiezenstwo
Pracy w Gornctwie, No. 1, Poland.
Nazar, A. and J. Wilk, 1970, "Decompression of Sulfur Deposit as a Fac-
tor for Increasing Production of Sulfur in Mines, Using Modified Frasch
Process," Gornicze Surowce Che&iczne, No. 4, Poland.
Nazar, A. and J. V11V, 1969, "Distribution of Temperatures in Sulfur De-
posit as the Result of Sulfur Recovering by Drilling Method Based on Hy-
drogeological Investigations," Gornicze Surowce Chemicze, No. 2, Poland.
Nazar, A., A. Nazarowa, and J. Vilk, 1969, "Biological Overgrowth of
Veil Screens," Technika Poszukiwan, No. 29, Poland.
I010U8
•W£A1*T7C «OtimOWS TO* MA2AADOUS W4STC MOIlMS*
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SCOTT J. McDOUGALL
PROJECT GEOLOGIST
EDUCATION
B.S., 1978, Environmental Science and Resource Management in Geology,
Lehigh University
Continuing Education, 1978 to present, in hazardous waste site investi-
gation and cleanup, ground water monitoring, computer modeling, RCRA,
CERCLA, SARA, and OSHA regulations, and underground storage tanks
REGISTRATION
Professional Geologist: North Carolina %
PROFESSIONAL EXPERIENCE
19S7 to Present: ttr. HcDougall is a Project Geologist for Remeor. To
date, he has been collecting and analyzing aquifer test data and is de-
signing a ground water recovery system as part of the closure of an
electroplating sludge disposal lagoon site in Mississippi.
Mr. McDougall Joined Rencor with nine years of environmental experience,
primarily in the technical evaluation and management of waste disposal
site investigations.
1983 to 1987; Mr. McDougall served as a Project Manager and Senior Hy-
drogeologist for KUS Corporation, where he conducted and managed remedi-
al investigations and feasibility studies (RI/FSs) at hazardous waste
sites listed on the U.S. Environmental Protection Agency (EPA) Superfund
list and at privately owned facilities. Representative experience in-
cluded the following:
• Project Manager and Senior Hydrogeologist for two
EPA Superfund enforcement support projects in
Puerto Rico in which responsible party site inves-
tigations were monitored and evaluated on a full-
time basis. One site is a municipal wellfield con-
taminated by solvents from a leaking lagoon; the
other is a residential area contaminated with mer-
cury from an adjacent landfill.
• Project manager for remedial activities conducted
• at an abandoned pesticide disposal lagoon site lo-
cated in western Tennessee consisting of nine la-
goons. Program involved fast-track drilling and
monitoring well installation; aquifer testing,
^REALISTIC COUmONS FOX NA2AMDOUS WASTE MOIlf M**
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SCOTT J. McDOUGALL
soil, sediment, ground water, surface water, and
drinking water stapling; tnd geophysics. Responsi-
ble for technical coordination, site risk assess-
•ent, and recommendation .of cleanup alternatives,
as well as schedule and budget control and client
coordination. The site was investigated for less
than the original budget and schedule estimates.
Served as Supervisor of the Geophysics and Engi-
neering Geology Department for one year and was re-
sponsible for field crews performing investigations
at Superfund sites.
Prepared a Resource Conservation and Recovery Act
(RCRA) ground water assessment report as part of
the closure of an electric arc furnace dust site
for a steel manufacturer in western.Pennsylvania.
Project geologist for first Superfund RI/FS con-
ducted In Puerto Rico. This involved a drilling
and sampling program to locate the source of munic-
ipal wellfield contamination in a densely industri-
alized area within a complex limestone hydrogeo-
logic setting. Because of careful planning, the
source was identified during the first phase of the
project, resulting in a cost savings.
Conducted detailed on-site hydrological and sam-
pling investigations at Superfund hazardous waste
sites in Delaware, Massachusetts, and Pennsylvania.
Served as lead author in the preparation of Remedi-
al Action Master Plans and performed technical site
Inspections and work plan preparation for hazardous
wuste sites in Delaware, Massachusetts, New Jersey,
New Sork, Pennsylvania, Puerto Rico, Rhode Island,
Tennessee, and Vermont. Managed engineering sub-
contractors performing site evaluations. Prepared
numerous well drilling contracts and selected and
managed drilling subcontractors.
Served as hydrogeologist for environmental assess-
ments at gasoline stations for a major oil company.
Specific activities conducted were test boring
drilling and subsurface soil sampling adjacent to
leaking underground storage tanks for stations lo-
cated in Florida, Georgia, and Tennessee.
•MALISnC SOO/riONC FOft MAZAADOlff
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SCOTT J. KcDOUCALL 3
1950 to 1983; Mr. McDougall held the position of Fegional Hydrogeolo-
gist with the Pennsylvania Department of Environmental Resources (PADER)
and perforned ground water and surface water investigations and recom-
mended pollution abatement methods at approximately 50 sites. These
sites Included hazardous waste facilities; municipal landfills; sewage
and septic sludge disposal sites; fly ash, coal refuse, and deep Dine
drainage sites; and private and municipal wellfields. Responsible for
the review of new landfill, sludge disposal, and hazardous waste site
(RCRA Part B) permit applications and remedial action designs and site
closure plans under Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA) regulations.
1978 to 19SO; Mr. McDougall was an Environmental Specialist with CAI
Consultants, Inc. where he assisted in the supervision of an extensive
river navigability study of the State of Michigan for the U.S. ftrwy
Corps of Engineers. Other projects included researching for and prepar-
ing of portions of a fly ash disposal guidance manual for' the Electric
Power Research Institute, preparing environmental impact statements for
Tennessee Valley Authority electric power station projects, and conduct-
Ing field permeability tests at a fly ash disposal site.
E01048
TtCAittTJC COlimOWS POft HAZARDOUS
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JOHN P. BLACK, P.E.
PROJECT ENGINEER
EDUCATION'
M.S., 1979, Civil Engineering, State University of New York at Buffalo
B.S., 1977, Civil Engineering, State University of New York at Buffalo
A.A.S., 1975, Engineering Science, Erie Community College
Transport of Immiscible Fluids in the Subsurface, by J.V. Mercer, NVWA,
Baltimore, Maryland
Special Topics in Ceotechnlcal Engineering, by D. Sangray, Carnegie-
Mellon University, Pittsburgh, Pennsylvania
Groundwater Transport Modeling, by G.F. Pinder, Princeton University,
Princeton, New Jersey *
Loss Prevention, ASFE, Washington, DC
REGISTRATION
Professional Engineer: Keu York, Pennsylvania
PROFESSIONAL EXPERIENCE
19S8 to Present; Mr. Black Joined Remcor as a Project Engineer in the
Engineering and Design Croup. His responsibilities in this role include
providing gecxechnical and civil engineering input to the design and
eonstructibility evaluation of remediation projects.
1980 to 1988: Prior to Joining Remcor, Mr. Black was employed by
D'Appolonia Consulting Engineers, Inc. (D'Appolonia) and had been in-
volved in projects ranging from slope stabilization projects to the de-
sign of a 500,000-cubic meter underground storage facility. The sain
areas of Mr. Black's expertise have been associated with the analysis
and design of structures that are related to the engineering behavior of
•oil and rock, hydrologic and hydraulic analysis of civil engineering
structure, and the design and utilization of underground space. Proj-
ects which Mr. Black had been involved with, under the following cate-
gories, while with D'Appolonia include:
• Water Resources:
• Planning and development of construction speci-
. fications for the excavation and closure of two
Dill sludge lagoons on the Ohio River.
- Ground water modeling for paper sludge lagoons
near Green Bay, Wisconsin. These models were
"*£AI*T)C SOIUTIOWS fOU HAZUtDOUl WAIT* MOltttW
-------
JOHN P. BLACK
used to design a slurry wall/gradient control
system to limit migration of chlorides.
• Layout and evaluation of conceptual hydroelectric
power facilities on the Betsiboka River, Ambodi-
roka, Madagascar. Mr. Black's responsibilities
on this project included evaluation of alternate
component layouts, conceptual design of the sedi-
nentation and diversion channels, and analysis of
river flow profiles for the extreme discharges.
- Evaluation of the seepage and deformation be-
havior of a 180-foot high arch-gravity daa near
Robbinsville, North Carolina.
• Preparation of permit application for the pro-
posed 15-megawatt hydroelectric .facility on the
Youghiogheny Lake Dam. Mr. Black's responsibili-
ties on this project included layout and evalua-
tion of the powerhouse and penstock. In addi-
tion, his responsibilities included coordination
of the environmental studies and all contacts and
responses with the regulatory agencies.
- Evaluation of the effects of long-term dewatering
on adjacent structures, of historical signifi-
cance, for the Theater District project in Mil-
waukee, Wisconsin.
• Evaluation of the consequences of failure of any
one, or a combination of, three dams in the
Hoosier National Forest, Indiana. Mr. Black's
responsibiltiies included daa inspection, evalua-
tion of the stream channels, collected and evalu-
ation of the hydrologic data, and all flood rout-
ings needed to assess the damage potential.
- Development of an inundation nap for the Voronoco
Daa near Westfield, Massachusetts. For this
project Mr. Black evaluated the limits of flood-
ing, which would result froa the failure of a
concrete gravity das. Mr. Black conducted all of
the field and office studies necessary for the
completion of this project.
Slooe Stabilization and Remediation
- Designed a slope stabilization system for a hill-
side, conveyor system that had moved out of its
proper alignment.
TUAtanc SOLUTIONS ro* MAZANDOUS WASTI motion*
-------
JOHN P. BLACK
- Design of cut-and-fill slopes for the development
of a nine haul road on an unstable hillside in
Greene County, Pennsylvania.
- Design of rock cut slopes and fill slopes for
development of the proposed SRC II Facility in
Morgantown, West Virginia.
- Subsurface exploration, design, and construction
document preparation for the remediation of a 20-
acre landslide, which moved 1,300 feet of the
Conrail Railroad tracks into the Ohio River.
- Evaluation and redesign of a nine spoil disposal
facility failure in Belcher, West Virginia, the
failure of this facility resulted in spoil mate-
rials "flowing" into homes more, than 2,500-feet
from the initial disposal site.
- Stabilization of a hillside with approximately
100 private residences in Wheeling, West Vir-
ginia. This project involved stabilizing the
hillside, four roadways, and approximately 100
houses with minimum disruption to normal
activities.
• Mine Waste Disposal
• Development and consultation during implementa-
tion of an alternative coal refuse disposal plan
for existing coal refuse disposal embankments,
which «ere operating inefficiently. The alterna-
tive plan, now in use, included the development
of a large dan built of coal refuse to impound a
slurry of fine coal processing waste.
- Evaluation of the mining sequence and resulting
spoil pile stabilization requirements for an oil
shale mining project in Queensland, Australia.
On thia project Mr. Black evaluated the proposed
mining sequence in relation to the resulting mine
tailings and spoil pile stability considerations.
- Development of reclamation plans, construction
specifications, and cost estimates for two aban-
doned mine sites in Indiana. Primary responsi-
bilities included planning for laboratory testing
of soil and water samples, hydrologic and geo-
technital designs, and report preparation.
nuAtanc soiirnows AM NAZAABOI/S
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JOHN P. BLACK H
- Design of surface drainage and sediment control
systems including dans and drainage channels for
several coal refuse disposal facilities in the
Appalachian region.
• Underground Space
• Layout and development of the excavation method
and sequence for a large underground storage fa-
cility in the Middle East. Mr. Black was in-
volved in the selection of the storage gallery
layout, gallery support system design, access
tunnel arrangements, construction methods and
equipment, and the development of the construc-
tion sequence and schedule.
- Development, supervision, and report preparation
for a rock testing program conducted within the
outlet tunnel of the John W. Flannagan Dam near
Haysi, Virginia.
• Subsurface exploration and evaluation of a pro-
posed sewage conveyance tunnel in Morgantown,
West Virginia. Mr. Black's responsibilities on
this project involved evaluation of the proposed
tunnel routes, development and execution of a
subsurface exploration program, and evaluation
and presentation of the data in reference to the
proposed construction. The evaluation of geo-
technical data included development of design
parameters for lining design and a presentation
of the impacts of the conditions on the proposed
construction.
- Analysis of a distressed raw coal reclaim tunnel
and compilation of alternative rehabilitation and
replacement schemes. Mr. Black's responsibili-
ties on this project included field evaluation of
the condition of the tunnel, development of six
alternative repair or replacement schemes, and
cost analyses of each alternative.
• Development of remediation plans for a site on
which leakage from underground storage tanks had
created the potential for off-site ground water
• contamination.
1979 to 1980; Prior to joining D'Appolonia, Mr. Black was employed by
Delon Hampton and Associates, Chartered of Silver Spring, Maryland.
Delon Hampton and Associates is a consulting engineering firm which is
involved mainly in transportation-related projects such as tunnels,
•fAiisne soiimows m* MA&MDOUS VASTT wrotuw
-------
JOHN P. BLACK 5
bridges, airports, and planning. Mr. Black was involved in geoteci-.nical
search, design, and recommendations in support of the structural design
group. The scope of this work included:
• Research into the use of geoteehnical instrumenta-
tion for design and construction of both soft
ground and rock tunnels. Mr. Black was involved in
the evaluation of the use of instrumentation to
provide real-time performance data for improvement
of urban tunneling.
• Research on the influence of geoteehnical parame-
ters in tunnel lining design. Various methods of
improving tunnel design and construction through
improved pre-constructien geoteehnical exploration.
• Site investigation, analysis, and design of three
projects at Washington National Airport. This in-
cluded layout of the geoteehnical site investiga-
tion, analysis of the data, and the design of taxi-
ways, aprons, and ramps for aircraft.
• Preliminary investigations into the causes of pre-
mature deterioration of reinforced concrete bridge
decks.
1977 to 1979: During the completion of his Master of Science Degree,
Kr. Black worked for Faculty Technical Consultants (FTC) in Buffalo, New
York. His responsibilities at FTC included the calibration, installa-
tion, and monitoring of approximately 100 instruments utilized to evalu-
ate the behavior of t long-span corrugated metal culvert in Bucks Coun-
ty, Pennsylvania. The field testing for this project included plate
load tests, deformation, ajid stress measurements.
PROFESSIONAL AFFILIATIONS
Chi Epsilon, National Honorary Civil Engineering Fraternity
Tau Beta Pi, National Engineering Honors Association
PUBLICATIONS
Hampton, D.( J.S. Jin, and J.P. Black, 1980, "Representative Ground
Parameters for Analysis of Tunnels: Vol. 3, Tunnel Design and Construc-
tion," Report FHVA/RD-80/0^.
E03318
•REALISTIC SOII/TIOMS POM MA2AAOOUS WASTE MOBLf MS*
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ROBERT S. HARKVZLL
ENVIRONMENTAL SCIEKTIST
EDUCATION
B.S., 198IJ, Environmental Resource Management, The Pennsylvania State
University
PROFESSIONS EXPERIENCE
1987 to Present: Mr. Markvell is an Environmental Scientist in the En-
gineering and Project Development Division of Reocor. In this position,
he coordinates field sampling activities and provides technical input on
project reports. Experience at Rencor includes the following:
• Assessment of polyehlorinated biphenyl (PCB) and
solvent contamination of soil and ground water at
an electrostatic capacitor manufacturer.
• Development of a sampling program and assessment of
chesical data for a remedial investigation (RI) of
a solvent-contaminated ground water site under the
Comprehensive Environmental Response, Compensation,
and Liability Act (CERCU) or Superfund.
T985 to 19B7: Mr. Markwell served as an Environmental Health Specialist
for KUS Corporation in Pittsburgh, Pennsylvania. Key contributions in-
cluded the following:
• Produced six Resource Conservation and Recovery Act
(RCM\ Facility Assessments that involved assessing
over 200 treatment, storage, and disposal units.
• Developed a report for RCRA Regulatory Assistance
on characterization of leachates from co-disposal
landfills using both field and published data.
• Completed three Environmental Risk Assessments for
Kational Priority List Superfund site Rls. Ana-
lyzed chemical data and physical site features to
assess occurrence, distribution, and migration of
contaminants and to formulate risks to potential
receptors.
196M to H65: Mr. Markwell served as a Field Operations Teaa Leader for
KUS Corporation. In this role he coordinated and led soil, water, and
waste sampling programs on 18 Superfund sites in four EPA regions and on
five RCRA industrial sites.
•wtAiisnc soiimowi ro» HAZARDOUS
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ROBERT S. KARKVELl 2
TRAINING
Mr. Harkwell successfully completed the following:
• Waste Site Supervisor Health and Safety Training
(December 1987)
• Superfund 40-Hour Health tnd Safety and Field In-
strunents Training (October 1934)
• EPA Organic tnd Inorganic Data QA/QC Validation
Seminar (January 1988)
£02018
•wmisnc soumoNS n* HAZARDOUS
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ATTACHMENT B OF RESPONSIVENESS SUMMARY
OLD SPRINGFIELD LANDFILL SITE
RESPONSIVENESS 8UXXARY
DETAILED RESPONSES
PRP COMMENTS
Comments on the Preferred Alternative
COMMENT NO. It The •election of the 10"7 incremental cancer risk
as the target risk level does not appropriately reflect site
characteristics and is not consistent with recent EPA Region Z
policy at other sites.
RESPONSE!
EPA did not select the 10~7 incremental cancer risk as the
target risk for this operable unit for seeps. EPA choose
target risk levels between 10"4 and 2 z 10~6 for groundvater
cleanup which are within the risk range of 10-4 to 10-7
Superfund remedies, and is consistent with recent EPA Region
I policy at other sites.
Because this remedy does not address source control EPA does
not think it is apprporiate to respond to this concern as it
relates to source contol.
COMMENT NO. 2: The remedial investigation does not support the
need for the capping of the landfilled wastes to protect against
future ingestion of bedrock ground water to the east of the
former landfill.
RESPONSE:
Because this remedy does not address source control, EPA
does not feel it is appropriate to respond to this comment
at this tine.
COMMENT NO. 3t The remedial investigation does not support the
need for capping of landfilled wastes to protect against offsite
exposure via inhalation of chemicals in landfill gas.
RESPONSE;
See EPA response to comment 2 above.
COMMENT*NQ. 4: The outslopes of the former landfill should not
be capped.
RESPONSE:
See EPA response to comment 2 above.
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COMMENT MO. Si The potential risk associated with contact with
contaminated surface soils suggests covering and fencing
approximately 1.5 acres of the former landfill to addrasa a
targat riak laval of 10"'.
RESPONSE:
8aa EPA rasponaa to comment 2 above.
COMMENT NO. €: Selection of cap configuration abould ba Bade on
the basis of studies performed during remedial design.
RESPONSE:
See EPA response to comment 2 above.
COMMENT NO. 7: The data developed in tbe remedial investigation
do not aupport tbe need for excavation of areas beyond tbe limita
of tbe former landfill and consolidation of tbase materials under
tbe proposed cap.
RESPONSE1
See EPA response to comment 2 above.
COMMENT MO. it Tbe design of tbe leacbata collection syatem on
tbe eastern side of tbe site sbould be modified to addreas
collection of tbose seeps evidencing contamination, and tba
instability of the eastern outslopes sbould be considered in
locating tbe collection system.
RESPONSE:
REMCOR appeara to take iasue vitb tbe propoaed design of tbe
eastern leacbate collection system for a number of reasons:
o Questionable atability of outalopea affecting
construction and aystem maintenance.
o Effect on aestbetics and alope stability cauaed by
required clearing and grubbing activities.
stability of outalopea: Zt is recognised tbat steep cuts
vfll be required to construct tbe collection system as
proposed. However, aa tbe excavations would be backfilled
as soon as- possible after construction of tbe drainage
system, only short-term stability of the excavation should
-------
be a Bftttsr of concern. Specific precautions required to
ensure short-term slope stability, such as bracing,
benching, or flattening of slopes, should be explored during
the Remedial Design. REMCOR also expresses concerns for
long-tern stability of the slopes (RZMCOR, Page 28). The •
ROD specifies performance standards which Bay allow for an
alternative collection system design. Slope regrading
operations to be performed in conjunction vith capping
operations should increase slope stability in areas of
marginal stability, thereby minimising these concerns.
Effect on Clearing and Grubbing on Aesthetics and Slope
Stability* REMCOR concludes that performing necessary
clearing and grubbing operations vould "exacerbate problems
associated vith stability of the slopes and vould blight the
landscape in the area.** (RZMCOR, Page 28).
The areas to be cleared and grubbed are not visible to a
large extent from either Route 11 or from the trailer park
due to topography and vegetative cover. Since visual
observation of these areas is obscured to a large extent, it
is uncertain hov operations "vould blight the landscape.*1
The proposed operations are very similar to those associated
vith a utility right-of-way.
They also express a concern that clearing and grubbing
operations vill "exacerbate problems associated vith
stability of the slopes." The vegetation currently present
on the slope adds little to the overall stability of the
•lope. As such, ve are of the opinion that removal of such
vegetation should not affect overall slope stability.
COMMENT NO. 9t Placement of interceptor veils along Will Dean
Road into the sand and gravel vater-bearing cone should be
reevaluated.
RESPONSE:
The EPA recognises data for the design of the veil
extraction system is currently not available. Further
evaluation is recommended in the 78 (TB 7*127). Specific
items to be designed include number of extraction veils,
veil placement, and extraction rates.
Placement of these veils along vill Dean Road vill permit
the vestern vaste management boundary to be placed along
WiXl Dean Road and closer to the source area, rather than at
the vestern leachate seeps. This vill allov the homes vest
of Will Dean Road to be excluded from the vaste management
unit.
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APPENDIX 2
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APPENDIX 3
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,-w^l
:nt^>f Vermon t /'X\ AGENCY OF NATURAL RESOURCES
f<£Sp3$Sf 103 SOUTH MAIN STREET
I mrv<». r
' """"" """"": **"• '- '"•" W^terbury, Vermont 05676
! t*l h 1IVWO"IUi;tH*|l ti'lt'tUt V»lH»ri Mtffc' **~*T**lii^ •% • M • —
ic Acuiunm DupMinwnl of Envtrooment*) Contervition
il Miaumuek Uomnt'
802-244-8755
September 21, 1988
Michael R. Deland
Regional Administrator
U.S. Environmental Protection Agency
Region Z
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Rex Old Springfield Landfill
Concurrence with ROD for
Operational Unit
Dear Mr. Deland:
The Agency of Natural Resources (Agency) has reviewed the
preferred remedial action alternative that EPA is recommending
for an operational unit at the Old Springfield Landfill Federal
Superfund site. The Agency concurs with the selection of the
preferred alternative for the unit.
The Agency has evaluated EPA'e preferred alternative for
consistency with state law and has determined that it is
consistent with state statutes and regulations currently in
effect. Please note, however, that the state Groundwater
Protection Rule and Strategy will take effect September 29* 1988.
Any additional remedial action for source control or migration of
groundwater will be evaluated for consistency with this rule.
The Agency looks forward to working with you in implementing
the preferred alternative. If you have any questions or require
additional information please contact Reginald (Tex) LaRosa at
802-244-8755.
, Sincerely,,
"^
Patrick A. Parenteau
Commissioner
PAP:arm
12
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COMMMTT HO. lit Tbe slurry vail proposed by IPX as an option
within the preferred alternative would have limited
effectiveness.
RESPONSEI
As part of this ROD, additional studies vill bs 4on« to
d«t«nin« th« feasibility of diverting groundvatar from
contact vitb tba vasta. Tba evaluation for tbe
effectiveness a slurry wall will be determined at tbat time,
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State of Vermont
I el fit* end WlldlUt
i oi FerMtt. P*fM >nd Atc^ttiio
C'»o»'tcw«m o' tnvi«o»"n«nt»l Conicrvc.ion
St»it G«ologin
NKurcl R**outc« CenMrvition Council
(.
AGENCY OF NATl
103 SOUTH
Witerbury, Vermont 05676
Department of Environmental Conservation
July 19, 1988
CORFIOENIIAl
Ms. Paula Fitzsimmons lUl 2 0
'U.S. EPA. Region I
Hazardous Waste Division (HPS-1) , . _, _
J.F. Kennedy Federal Building ** ""
Boston, Massachusetts 02203
Dear Ms. Fitzsimmons:
We have reviewed EPA's proposed cleanup plan for the Old Springfield
Landfill, and have the following comments.
We recognize the considerable efforts expended by EPA and EPA's contractors
on this site. The collection and analysis of an enormous amount of data has
resulted in a much better understanding of the nature and extent of the
contamination problem. However, we feel that some important information is still
lacking, and we question EPA's ability to design and implement an effective
remedy without this critical data.
Specifically, we feel that EPA's investigations should be expanded to
characterize the bedrock hydrogeology east of the site. We are concerned that
without an understanding of this potential pathway for contaminant movement,
there may still be an unidentified risk to public health and the environment.
Without an understanding of these risks, it is not possible to determine if
additional remedies such as extraction and treatment of groundwater from the
bedrock might be necessary.
Also. EPA's investigations should identify and define waste
disposal areas on the western side of the site. Risks associated with this
problem need to be characterized, and specific remedial actions proposed if
warranted.
The state of Vermont has brought these concerns to EPA's attention on
numerous occasions. Both the Vermont Department of Environmental Conservation
(DEC) and the Vermont Department of health (DOH) have repeated these concerns to
EPA upon review of virtually every major work plan and report produced by EPA's
contractors.
Reqional Offices • Barre/Euex Jct./Pimford/N. Springfield/Si. Johnsbury
-------
Ms. Fitzsimmons
July 19. 1988
Page 2
Following are comments on the major elements of EPA's proposed plan. Please
note that because detailed design specifications are not available, it is not
possible to provide detailed comments on the specifics of each component of the
proposed remedy.
Capping
While capping will reduce the amount of precipitation infiltrating through
the contaminated materials, it will do little to prevent the lateral movement of
groundwater through the wastes. This groundwater will continue to migrate,
emerging at the leachate seeps and/or traveling downward through the overburden
and into the bedrock. Because groundwater will continually leach through the
contaminated materials, the proposed leachate collection systems may need to be
operated and maintained virtually indefinitely. Also, because the bedrock
hydrogeology east of the site has not been adequately characterized, that portion
of the contaminated groundwater which reaches the bedrock may present a
continuing threat to public health and the environment.
This portion of the remedy includes removing some of the contaminated
materials from outlying waste areas and consolidating it within waste areas 2, 3,
and 4. Waste areas on the western side of the site have not been delineated, and
the volume of these materials which may need to be removed and consolidated is
unknown. The costs associated with that effort have not been included in the
estimated total costs.
Concerning the outlying waste areas which EPA has identified, the plan
proposes to remove contaminated materials from these areas down to a depth of
either 4.5 or 9.5 feet. The rationale for selecting these depths is unclear.
For example, contaminated materials from an area in the northwestern portion of
the site will be removed to a depth of 4.5 feet, yet only surface soil samples
were collected from this area. The depth of contaminated materials in this area
is unknown. Also contaminated materials from waste area 1 will be removed to a
maximum depth of 9.5 feet, yet samples collected from below this depth were not
analyzed. The depth of contaminated materials in this area also appears to be
unknown. The plan also proposes to remove contaminated materials from the steep
slopes of waste areas 2 and 3. and the depth to which these materials will be
removed is not specified. Since these areas will not be capped, any contaminated
materials remaining below the planned excavation depths will continue to leach
contaminants into the groundwater. These issues must be resolved in the remedial
design.
Continuous Leachate Seepage Collection and Treatment
EPA's "Draft Final Supplemental Remedial Investigation Report" concludes
that a portion of the contaminated groundwater from the eastern waste areas
travels through a deep sand and gravel deposit and discharges as leachate seeps
along the bese of the western slope. This component of the remedy includes both
groundwater extraction wells to remove contaminated groundwater from this sand
and gravel unit, and construction of a leachate collection system on the west
side. If, as EPA's report concludes, all of the contaminated groundwater moving
through the sand and gravel unit discharges to the western seeps, then it appears
that the extraction wells may not be necessary. Final determination of need
should be made in the remedial design.
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Ms. Fitzsinmons
July 19, 1988
Page 3
This portion of the remedy includes pumping collected leachate to a
treatment system to be constructed on the site. It is stated in the proposed
plan that "adequate information has not been received by EPA to evaluate whether
the Springfield town treatment plant has the capacity or ability to tr.eat the
contaminants associated with the site..." The DEC notified EPA that additional
specific information was necessary before the DEC could help determine if the
town treatment plant could accept and treat leachate from the site. That
information has not been provided to the DEC. It may be possible that with
proper pre-treatment , the collected leachate could be accepted by the town
treatment plant, thereby lowering the construction, operation, and
maintenance costs associated with this portion of the remedy.
Two issues are still under consideration by the state. As indicated in
Commissioner Parenteau's letter of June 28, 1988, we do not presently have
sufficient information to conclusively resolve the historic ownership and
operation issues and the resulting state cost exposures. Also, we are concerned
about the lack of permanence of EPA's proposed remedy. Section 121 (b) of the
Superfund Amendments and Reauthori ration Act of 1986 (SARA) requires that EPA
give preference to remedies that permanently reduce the toxicity, volume, or .
mobility of the hazardous substances at a site. Capping wastes, restricting
access, and collecting and treating leachate are not permanent remedies. These
remedies rely heavily on operation and maintenance activities that may have to
operate virtually indefinitely and which could place a large burden on the
already limited resources of the state of Vermont and the town of Springfield.
We have discussed' EPA's proposed plan with the DOH, and their concerns are
included in this letter. The DOH will also be sending written comments to EPA
after they have received and reviewed the final reports on which this proposed
plan is based.
Please contact me with any questions regarding these comments.
Sincerely,
Se-
Tom Moye
Hazardous Materials Management Division
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