EPA Superfund
Record of Decision:
Tansitor Electronics, Inc.,
Bennington, VT
9/29/1995
PB95-963717
EPA/ROD/R01-95/117
March 1996
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DECLARATION FOR THE RECORD OF DECISION
Tansitor Electronics, Inc. Superfund Site
Bannington, Vermont
STATEMENT OF PURPOSE
This Decision Document presents the selected remedial action for
the Tansitor Electronics, Inc. Superfund Site in Bennington,
Vermont, developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended, 42 U.S.C. §§ 9601 et. seq. and the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP) as
amended, 40 C.F.R. Part 300. The Director of EPA-New England
Waste Management Division has been delegated the authority to
approve this Record of Decision (ROD).
The State of Vermont has concurred with the selected remedy.
STATEMENT OF BASIS
This decision is based on the Administrative Record which has
been developed in accordance with Section 113(k) of CERCLA and
which is available for public review at the Bennington Free
Library, Bennington, Vermont, and at the EPA-New England Waste
Management Division Records Center in Boston, Massachusetts. The
Administrative Record Index (Appendix E to the ROD) identifies
each of the items comprising the Administrative Record upon which
the selection of the remedial action is based.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to the public health or welfare.
DESCRIPTION OF THE SELECTED REMEDY
This ROD sets forth the selected remedy for the Tansitor
Electronics, Inc. Superfund Site, which includes management of
migration components to obtain a comprehensive remedy. This ROD
does not include any source control component because EPA's risk
assessment concluded that the surface and subsurface soils did
not present an unacceptable risk either under current conditions
or under a potential future residential scenario.
The major components of the selected remedy include:
Institutional controls to prevent the use of
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contaminated groundwater and to inform future
purchasers of property of the groundwater restrictions
associated with the property.
Long-term monitoring of site groundwater on a regular
basis to evaluate changes in site conditions over time;
Contingencies for future additional investigation or
further action should the long-term monitoring reveal
that contaminants have migrated beyond their current
vertical or horizontal extent; and
A review of the Site every five years to ensure that
the remedy remains protective of human health and the
environment.
In addition, as part of the selected remedy, EPA is waiving the
attainment of federal drinking water standards which are
applicable or relevant and appropriate requirements (ARARs) at
this Site. EPA is waiving attainment of these ARARs on the basis
that it is technically impracticable from an engineering
perspective to restore groundwater to drinking water standards
within a reasonable timeframe.
DECLARATION
The selected remedy is protective of human health and the
environment, attains or provides the basis for a waiver of
federal and state requirements that are ARARs for this remedial
action, and is cost-effective. EPA has determined that it is
technically impracticable from an engineering perspective to
attain federal drinking water standards at this Site, and is thus
waiving attainment of these ARARs. Given the technical
impracticability of restoring the groundwater, and that no active
measures are necessary to contain the contaminated groundwater,
this remedy does not satisfy the statutory preference for
remedies that utilize treatment as a principal element to reduce
the toxicity, mobility, or volume of hazardous substances. In
addition, given these circumstances, EPA finds that this remedy
utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable.
As this remedy will result in hazardous substances remaining
onsite above health-based levels, a review will be conducted
within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
_.
"Bate Clhda M. Murphy, D±r«6tor
Waste Management Division
EPA-New England
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REGION I
RECORD OF DECISION SUMMARY
TANSITOR ELECTRONICS, INC.
SEPTEMBER 1995
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TANSITOR ELECTRONICS, INC. SUPERFUND SITE
TABLE OF CONTENTS
I. SITE NAME, LOCATION AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
A. Land Use and Response History 2
B. Enforcement History 3
III. COMMUNITY PARTICIPATION 3
IV. SCOPE AND ROLE OF RESPONSE ACTION 4
V. SUMMARY OF SITE CHARACTERISTICS 5
A. Geology and Hydrogeology 5
B. Soil 6
C. Groundwater 7
C. Stream Sediments and Surface Water 10
D. Air 11
E. Ecological Resources/Wetlands 12
VI. SUMMARY OF SITE RISKS 12
A. Human Health Risk Assessment . 13
B. Environmental Assessment 18
C. Conclusions 19
VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES 19
A. Statutory Requirements/Response Objectives .... 19
B. Technology and Alternative Development and
Screening 20
C. Technical Impracticability Evaluation .. 21
VIII. DESCRIPTION OF ALTERNATIVES 27
A. Management of Migration (MM) Alternatives
Analyzed 27
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES . . 29
A. Nine Evaluation Criteria 29
B. Comparison of Alternatives 31
X. THE SELECTED REMEDY 34
A. Institutional Controls 34
B. Monitoring 36
C. Contingencies for Future Action 37
D. Five-Year Review 39
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XI. STATUTORY DETERMINATIONS 39
A. The Selected Remedy is Protective of Human Health
and the Environment 40
B. The Selected Remedy Waives Attainment of MCLs, and
Attains All Other ARARs 40
C. The Selected Remedial Action is Cost-Effective . . 44
D. The Selected Remedy Utilizes Permanent Solutions
and Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable . . 45
XIII. STATE ROLE 47
11
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TABLES
1. SUMMARY OF CONTAMINANTS OF CONCERN IN OVERBURDEN GROUNDWATER
2. SUMMARY OF CONTAMINANTS OF CONCERN IN DISPOSAL AREA SURFACE
SOILS (0-2 ft.)
3. SUMMARY OF CONTAMINANTS OF CONCERN IN DISPOSAL AREA
SURFACE/SUBSURFACE SOILS (0-8 ft.)
4. SUMMARY OF CONTAMINANTS OF CONCERN IN SURFACE SOILS OUTSIDE
DISPOSAL AREA (0-2 ft.)
5. SUMMARY OF CONTAMINANTS OF CONCERN IN SURFACE/SUBSURFACE
SOILS OUTSIDE DISPOSAL AREA (0-17 ft.)
6. SUMMARY OF CONTAMINANTS OF CONCERN IN STREAM SURFACE WATER,
INTERMITTENT AND PERENNIAL STREAMS
7. SUMMARY OF CONTAMINANTS OF CONCERN IN FIRE POND SURFACE
WATER
8. SUMMARY OF CONTAMINANTS OF CONCERN IN STREAM SEDIMENTS,
INTERMITTENT AND PERENNIAL STREAMS
9. SUMMARY OF CONTAMINANTS OF CONCERN IN FIRE POND SEDIMENTS
10. FUTURE, CARCINOGENIC, RESIDENT RISK CALCULATIONS FOR
OVERBURDEN GROUNDWATER
11. FUTURE, NON-CARCINOGENIC, RESIDENT RISK CALCULATIONS FOR
OVERBURDEN GROUNDWATER
12. SUMMARY OF CARCINOGENIC RISKS
13. INITIAL SCREENING OF REMEDIAL TECHNOLOGIES AND PROCESS
OPTIONS
14. SUMMARY OF ANALYSIS - MANAGEMENT OF MIGRATION ALTERNATIVES
FIGURES
1. SITE LOCATION MAP
2. SITE PLAN
3. SUBSURFACE PROFILE, from MW-101R NORTH of the DISPOSAL AREA
to MW-10.9U NEAR ROUTE 9
4. HYDROGEOLOGIC CROSS SECTION
5. STATE OF VERMONT CLASS IV GROUNDWATER AREA
6. SOIL, SURFACE WATER and SEDIMENT SAMPLING LOCATIONS
7. GROUNDWATER SAMPLING LOCATIONS
8. DISPOSAL AREA PLUME
9. CONCRETE PAD AREA PLUME
10. HYDROGEOLOGIC CROSS SECTION and DISTRIBUTION OF 1,1,1-TCA
and 1,1-DCE in DISPOSAL AREA PLUME
11. HYDROGEOLOGIC CROSS SECTION and DISTRIBUTION OF 1,1,1-TCA
and 1,1-DCE in CONCRETE PAD AREA PLUME
12. WETLANDS and SURFACE WATER AREAS
13. CONTAMINANT PLUMES, TECHNICAL IMPRACTICABILITY ZONE, and
CLASS IV GROUNDWATER AREA
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APPENDICES
A. STATE OF VERMONT'S CONCURRENCE
B. ARARS TABLES
C. STATE OF VERMONT GROUNDWATER RECLASSIFICATION ORDER
D. RESPONSIVENESS SUMMARY
E. ADMINISTRATIVE RECORD INDEX
IV
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ROD DECISION SUMMARY
I. SITE NAME, LOCATION AND DESCRIPTION
The Tansitor Electronics, Inc. Superfund Site (Site) consists of
approximately 44 acres of land on West Road (Route 9) in the Town
of Bennington, Vermont, and is approximately 3.5 miles west of
Bennington Center (see Figure 1). Most of the Site (37.6 acres)
is located to the north of Route 9, with the remainder of the
Site (6.6 acres) located to the south of Route 9. The portion of
the Site located to the south of Route 9 consists of wetlands and
there are also wetlands on the property north of Route 9.
The Site is located in a predominantly rural residential area.
It is bounded to the north by privately owned woodland; to the
east by Houran Road and a commercial property; to the south by
wetlands; and to the west by agricultural/residential areas.
Pleasant Valley School is located approximately 1,200 feet east
and upgradient of the Site.
Tansitor Electronics, Inc. ("Tansitor" or the "facility")
currently manufactures electronic capacitors at the Site.
Approximately 100 workers are employed at the facility. Major
site features include Tansitor's operating manufacturing/office
building, an Etch House, a man-made pond (known as the Fire
Pond), parking areas, a Solid Waste Disposal Area, a Disposal
Area, a Concrete Pad Area, and a Borrow Area (see Figure 2).
Potable water supplies within the vicinity of the Site, including
the water supply on the Site, are provided by private bedrock
wells. Sanitary waste water from the Tansitor facility is
disposed of into two on-site leachfields.
The general topography surrounding the Site consists of rolling
hills oriented north-south between the Green and Taconic
Mountains. The Site lies at the southeastern portion of the base
of Whipstock Hill. Elevations at the Site and close vicinity
generally decrease to the south. Groundwater flow direction at
the Site generally mimics surface contours.
Surficial runoff from the Site (storm water, snow melt and from
groundwater seeps) drains into the Fire Pond, an intermittent
stream located on-site, and the facility storm drain system, and
ultimately into the wetland area south of Route 9. An unnamed
east-west flowing perennial stream, located south of Route 9,
enters the Site from the east and flows through these wetlands
into Browns Brook, a Class B surface water body located about
one-half mile off-site.
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A more complete description of the Site can be found in the
November 1994 Final Draft Phase 1A Characterization Report, on
pages 3 through 5.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Land Use and Response History
The Site is located in an area zoned rural residential with a
commercial -corridor overlay along Route 9. As a manufacturing
facility, Tansitor's industrial use of the Site represents a
grandfathered non-conforming use under the zoning laws. Because
the Site could be redeveloped and used for residential purposes
under the zoning laws, EPA considers the future land use of the
Site to be residential.
Since the 1950's, various owners have used the Site as a
manufacturing facility for electronic capacitors. In May 1981,
in compliance with Section 103(c) of the Comprehensive
Environmental Response, Compensation, and Liability Act, 42
U.S.C. § 9603 (c), the current Site owner, Tansitor, notified EPA
that organic solvents and acids had been disposed of on-site
between 1956 and 1979. Over that period, an estimated equivalent
of 117 drums of process waste were disposed in the Disposal Area,
a 900-square foot area to the north of the Tansitor manufacturing
building. During the period of 1975-1979, the process waste
disposed in the Disposal Area included 1,1,1-trichloroethane
which is the predominant volatile organic compound (VOC) present
in the groundwater. Tansitor has also reported that some waste
detergents and dilute acid solutions may have been discharged
into the two leach fields or directly into the intermittent
stream north of its manufacturing building. Finally, Tansitor
has reported that waste methanol had been burned periodically on
the Concrete Pad.
Subsequent to the notification, the Vermont Agency of Natural
Resources (VT ANR), then-named the Vermont Agency of
Environmental Conservation, performed site inspections and
requested that Tansitor initiate removal activities and implement
a soil sampling and analysis program in the Disposal Area.
Following these actions, VT ANR instructed Tansitor to restrict
access to the Fire Pond and disposal areas; define the areal and
vertical extent of contaminated soil at the Disposal Area; remove
the contaminated soil for proper disposal at a certified
hazardous waste facility; design and implement an evaluation'and
monitoring program to determine the magnitude and extent of
contamination resulting from the Site; and to determine potential
remedial actions.
Using all sampling data obtained through 1987, EPA calculated a
Hazard Ranking System (MRS) score for the Site. The Site was
listed as a proposed National Priorities List (NPL) site in June
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1988, based on an MRS score of 35.72, which exceeded the NPL
threshold value of 28.5. The listing became final on October 4,
1989.
In 1988, Tansitor hired a contractor to perform the site
investigation requested by VT ANR. During this investigation,
VOCs were detected in overburden groundwater samples from three
monitoring wells located between the Disposal Area and the Fire
Pond. No VOCs were detected in one monitoring well upgradient of
the Disposal Area or in two monitoring wells south of the Fire
Pond. However, surface water samples from the on-site
intermittent stream and the perennial stream south of Route 9 did
reveal VOC contamination.
A more detailed description of the Site history can be found in
the Final Draft Phase 1A Characterization Report, pages 6 through
10.
B. Enforcement History
Between March 1989 and May 1990, EPA notified seven parties,
current and formers owners of the Site, of their potential
liability with respect to the Site. Negotiations commenced with
these potentially responsible parties (PRPs) on May 11, 1990
regarding the settlement of the PRP's liability at the Site.
On September 12, 1990, EPA entered into an Administrative Order
by Consent (AOC) for the Remedial Investigation/Feasibility Study
with two of the PRPs. These two PRPs also agreed to reimburse
EPA for a portion of EPA's past costs through a Cost Recovery
Administrative Agreement. Pursuant to the AOC, the settling PRPs
retained a contractor and conducted the RI/FS under EPA
oversight.
The settling PRPs have been active in the remedy selection
process for this Site. Oral comments were given by the settling
PRPs during the public comment period at both a public meeting
and at a public hearing. In addition, the PRPs submitted written
comments during the public comment period. Their comments are
included in the Administrative Record and summarized in the
Responsiveness Summary.
III. COMMUNITY PARTICIPATION
Throughout the Site's history, community concern and involvement
has been fairly low. EPA has kept the community and other
interested parties apprised of the Site activities through
informational meetings, fact sheets, press releases and public
meetings.
During October 1990, EPA released a community relations plan
which outlined a program to address community concerns and keep
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citizens informed about and involved in activities during
remedial activities. In November 1990, EPA conducted interviews
with members of the public to ascertain the level of concern the
public held. EPA interviewed city officials, nearby residents
and interested parties.
A press release was sent out on July 29, 1991 announcing the
beginning of field work at the Site. A Fact Sheet was mailed in
December, 1991, to inform the public of the progress during the
first portion of field work. Another Fact Sheet was mailed in
September, 1993 to discuss the outcome of the Remedial
Investigation (RI) and Risk Assessment and to announce a public
meeting to discuss the RI and Risk Assessment. A press release
in the Bennington Banner also announced the public meeting
concerning these topics, which was held in the Bennington Free
Library on October 5, 1993.
EPA published a notice and brief analysis of the Proposed Plan in
the Bennington Banner on February 23, 1995 and made the plan
available to the public through a February 23, 1995 mailing as
well at the Bennington Free Library on March 8, 1995. Also on
March 8( 1995, EPA made the administrative record available for
public review at EPA's offices in Boston and at the Bennington
Free Library. A notice that EPA proposed to waive attainment of
Maximum Contaminant Levels (MCLs) was also included in the
Proposed Plan.
On March 8, 1995, EPA held an informational meeting to discuss
the results of the Remedial Investigation and the cleanup
alternatives presented in the Feasibility Study and to present
the Agency's Proposed Plan. During this meeting, the Agency
answered questions from the public. From March 9 to April 10,
1995, the Agency held a thirty-day public comment period to
accept public comment on the proposed waiver of MCLs, on the
alternatives presented in the Feasibility Study and the Proposed
Plan and on any other documents previously released to the
public. On March 22, 1995 the Agency held a public hearing to
discuss the Proposed Plan and to accept any oral comments. A
transcript of this hearing and the comments and the Agency's
response to comments are included in the attached responsiveness
summary.
IV. SCOPE AND ROLE OF RESPONSE ACTION
The selected remedy was chosen to obtaio a comprehensive approach
for site remediation. Evaluation of the RI data revealed that
the two areas identified as source areas, the Disposal Area and
the Concrete Pad Area, no longer posed current or potential
future risks to human health or the environment. Therefore, no
source control alternatives were evaluated in the Feasibility
Study.
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To address the identified risks associated with potential future
groundwater use, the selected management of migration remedy was
chosen by comparing the management of migration alternatives to
the nine criteria established by EPA to obtain a comprehensive
approach for site remediation. In summary, the remedy provides
for the following actions which will address the principal
threats to human health and the environment posed by the Site:
Implementation of institutional controls to prevent the
use of contaminated groundwater;
Long-term monitoring of site groundwater on a regular
basis to evaluate changes in site conditions over time;
Establishment of contingencies for future additional
investigation or further action should the long-term
monitoring reveal that contaminants have migrated
beyond their current vertical or horizontal extent; and
A review of the Site every five years to ensure that
the remedy remains protective of human health and the
environment.
V. SUMMARY OF SITE CHARACTERISTICS
Chapter One of the Feasibility Study contains an overview of the
Remedial Investigation. The significant findings of the Remedial
Investigation are summarized below.
A. Geology and Hydrogeology
Glacial activity has greatly influenced the geology and
hydrogeology in the vicinity of the Site. To the north is the
Whipstock Hill drumlin, which controls the surface water and
groundwater flow directions across and beneath the Site.
Underlying the Site is approximately 180 feet of glacial till, a
mixture of dense deposits of silty clay, clayey silt, silt, and
fine to coarse sand and gravel.
The till can be further divided into three units: ablation till,
present from the ground surface to about 35 feet; a silty sand
basal till about 15 feet thick; and a silty clay basal till
approximately 130 feet thick. The till overlies bedrock which is
comprised of variably fractured limestone under the southern
portion of the Site and phyllite under the northern portion. See
Figure 3 for a geologic cross section from MW-101R north of the
Disposal Area to MW-109U near Route 9.
The heterogeneous mixture of the till in turn influences
groundwater flow beneath the Site. Permeability of the till
generally decreases with depth, which contributes to the upward
direction of the vertical flow component in the vicinity of the
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Tansitor manufacturing building and Fire Pond.
A shallow water table exists at the Site with two general
horizontal groundwater flow directions. North of the Tansitor's
manufacturing building the flow is to the south-southeast. South
of this building, flow is to the south and southwest.
Groundwater flow paths are also shallow. Recharge to the water
table occurs primarily from the groundwater divide on Whipstock
Hill to the north of the Tansitor's manufacturing building. Just
north of this building, the land becomes more level, and this
marks the delineation from recharge to the water table to
discharge to the surface from the water table. This discharge
can be observed as seasonal seeps on the slope and by the flowing
artesian conditions in monitoring wells west and south of the
Fire Pond. Flow paths, constructed from water level elevations,
indicate that water flowing from the Disposal Area remains in the
shallow soils and discharges to the Fire Pond. Similarly, water
flowing from the Concrete Pad Area discharges, at least
seasonally, to the ground surface near the Tansitor manufacturing
building. Figure 4 presents a cross section of the Site showing
flow paths, recharge and discharge areas.
Generally, the aquifer beneath and in the vicinity of the Site
was classified by VT ANR as Class III, which is defined as
suitable as a source of water for individual domestic drinking
water supply, irrigation, agricultural use, and general
industrial and commercial use. However, in response to the data
obtained during the RI, on November 23, 1993, Vermont ANR
reclassified groundwater beneath a 9.6 acre area of the Site,
where groundwater contamination was detected, from Class III to
Class IV. Class IV groundwater is defined as not suitable as a
source of potable water but suitable'for some agricultural,
industrial and commercial use. See Figure 5 for the boundaries
of the Class IV zone.
A more complete description of the Site hydrogeology can be found
in the September 1994 Final Draft Phase IB Site Characterization
Report, pages 35-43.
B. Soil
There were two distinct source areas of VOCs detected at the
Site. These source areas, the Disposal Area and Concrete Pad,
were initially identified by soil gas analyses. Subsequent soil
gas surveys beyond the source areas determined that a soil gas
plume from the Disposal Area is moving toward the Fire Pond and a
soil gas plume from the Concrete Pad is moving southeasterly
toward the northeastern corner of the Tansitor manufacturing
building. Areal extent of the Disposal Area is approximately
5,000 square feet; areal extent of the Concrete Pad area is
approximately 2,5000 square feet.
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Disposal Area soils contain low levels of VOCs, and elevated
levels of silver and nickel. The highest concentrations of VOCs
were found in soils at a depth of seven to eight feet below the
ground surface. No dense non-aqueous phase liquids (DNAPLs) have
been found in the soils in this area, and the VOC concentrations
found in the unsaturated soils do not suggest the presence of
DNAPLs.
Beyond the Disposal Area, toward the Fire Pond, VOCs were
concentrated in the upper 30 to 35 feet of soil. Low
concentrations (close to the detection limit of the analysis)
were detected in soil samples collected from thirty-two to fifty-
two feet below the ground surface.
Based on soil gas and soil analyses, it is estimated that there
are approximately 6,000 cubic yards of soil between the Disposal
Area and the Fire Pond with VOC concentrations greater than 10
ppmv (part per million in a unit volume, m3) . The volume of soil
with greater than 10 ppmv and above the water table ranges from
550 yards (high water table) to 2,400 yards (low water table).
Concrete Pad soils also contain low levels of VOCs. The highest
concentrations of VOCs were detected in soils at a depth of 10 to
15 feet below the ground surface. No evidence of DNAPLs was
observed in these soils.
Beyond the Concrete Pad, toward the Tansitor manufacturing
building, VOCs were concentrated in the upper 10 feet of soil.
Based on soil gas and soil analyses, it is estimated that
approximately 1,800 cubic yards of soils containing VOCs
exceeding 10 ppmv exist between the Concrete Pad and the
manufacturing building. The volume of soil greater than 10 ppmv
and above the water table ranges from 550 yards (high water
table) to 1,000 yards (low water table).
Semi-volatile organics were sporadically detected in samples from
the Site. The occurrence of these compounds is mainly attributed
to the combustion by-products of fossil fuels and runoff from
road surfaces. These compounds do not appear to be related .to
past or current production or wastewater disposal processes at
the facility.
Nickel and silver were detected sporadically above background
concentrations in soils. A clear distribution pattern or source
of these metals is not indicated. Figure 6 shows the locations
of soil samples collected during the RI.
C. Groundwater
1. Contaminant Levels
The RI identified two significant plumes or zones of VOC
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contamination in shallow groundwater. Figure 7 shows the
groundwater sampling locations and Figures 8 and 9 show the
extent of the two plumes. The first plume originates from the
Disposal Area and extends to the Fire Pond, impacting an area
approximately 170 feet by 260 feet. Based on soil gas analyses
and groundwater analytical data, the plume does not exceed the
width of the Fire Pond.
Contaminants detected throughout the Disposal Area plume above
Federal drinking water standards, Maximum Contaminant Levels
(MCLs), include 1,1,1-TCA and 1,1-dichloroethylene (1,1-DCE).
The highest concentration of 1,1,1-TCA detected was 470,000 parts
per billion (ppb) (above its MCL of 200 ppb); the highest
concentration of 1,1-DCE detected was 3,800 ppb (above its MCL of
7 ppb). These concentrations were both detected in well ERM-2S.
The other significant plume originates from under the Concrete
Pad Area, impacting an area approximately 60 feet by 240 feet.
VOCs were detected above their MCLs at sampling location MW-108U.
The highest concentrations detected were as follows: 1,1,1-TCA,
2000 ppb (MCL Of 200 ppb); 1,1-DCE, 180 ppb (MCL of 7 ppb);
trichloroethene, 19 ppb (MCL of 5 ppb); and tetrachloroethylene,
20 ppb (MCL o'f 5 ppb) .
The RI also identified the Eastern Leach Field (see Figure 2)
where vinyl chloride was detected in one well (MW-ELF) at a
concentration of 4 ppb, which is above its MCL of 2 ppb.
Tansitor has made changes to the facility's interior drain system
to eliminate further discharge of process wastes to the leach
field. Vinyl chloride was not detected in a sample collected
after these changes were made.
All the groundwater contaminants detected to date have been
dissolved in the surrounding groundwater. However, the high
levels of certain VOCs found suggest that these contaminants may
exist as DNAPLs beneath the water table. Because current
technologies cannot easily locate DNAPLs, their possible presence
at the Site is based on circumstantial evidence, and the amount
of DNAPLs, if it exist, is not possible to determine. However,
if residual pools of DNAPLs do exist, they will slowly dissolve
and will continue to be a long-term source of contamination into
the surrounding groundwater.
Phase 1A sampling indicated elevated levels of lead, silver, and
manganese in some of the monitoring wells. To evaluate the
influence of turbidity on the measurements, low flow purging and
sampling methodology was employed in the subsequent sampling in
Phase IB. The Phase IB results all showed a marked decrease in
the concentrations of these metals.
2. Migration of Contaminants
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The data gathered during the RI indicates that contaminated
groundwater is limited to the Disposal Area and Concrete Pad Area
plumes, and is not migrating either vertically or horizontally.
While the exact thickness of the Disposal Area plume has not been
determined, the data reveal that contamination from this plume is
limited to the ablation till and upper basal till. The data show
that: VOCs were not detected in subsurface soil samples collected
below 32 feet from SB-113, the soil boring in the Disposal Area,
or from soil samples collected below 52 feet in the borehole for
monitoring well MW-112M, located between the Disposal Area and
Fire Pond; low levels of 1,1,1-TCA have been detected in
groundwater from the MW-112M, where the well screen is 62 feet
below the ground surface; VOCs have not been detected in another
medium-depth monitoring well (MW-104M) which is located along the
north edge of the Fire Pond and within the horizontal dimension
of the plume. See Figure 10 for a cross section of the Disposal
Area plume.
These findings appear to be consistent with a conceptual
groundwater flow model that was prepared for the Site. The
conceptual groundwater flow model is based on the following data.
Well MW-112M is located upgradient of the groundwater flow hinge
plane, the vertical divide which marks the change from recharge
to discharge. Upgradient of the plane, groundwater has a
downward component (as well as horizontal) and is therefore
recharging the aquifer. Downgradient of the plane, groundwater
has an upward component and is therefore discharging from the
aquifer. Thus, the model shows that at the Tansitor Site,
discharge from the Disposal Area groundwater is into the Fire
Pond. Absence of VOCs in MW-104M further supports this
conclusion. See Figure 4 for a presentation of the groundwater
flow model and hinge plane.
In addition, the Disposal Area plume does not currently extend
beyond the Fire Pond. This is supported by the absence of
contaminants in groundwater samples collected from wells east,
west, and south of the Fire Pond. This plume discharges to the
Fire Pond and also seasonally flows out onto the ground surface
north of the Fire Pond. The contaminants which reach the Fire
Pond are reduced through natural attenuation and volatilization.
The contaminant levels in the Fire Pond do not exceed surface
water quality standards.
A second groundwater plume, which also contains VOCs and is
separate from the plume emanating from the Disposal Area,
originates at the Concrete Pad Area north of the plant (the
Concrete Pad Plume). The Concrete Pad Plume has migrated
underneath Tansitor's manufacturing building but has yet to be
detected beyond it. Based on soil gas analyses, this second
plume appears to be approximately 60 feet wide and limited to a
depth of less than 20 feet. This is supported by the absence of
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VOCs in soils at a depth of 20 feet at the Concrete Pad and below
10 feet at a monitoring well near the Tansitor's manufacturing
building (MW-108U), located approximately 150 feet downgradient
of the pad. This plume partially discharges on a seasonal basis
to the ground surface, to the intermittent stream north of
Tansitor's manufacturing building, and to the catch basin system
northeast of the building. The remainder of the plume migrates
toward well MW-108U. This plume is expected to be partially
intercepted by subsurface utilities east and south of the
Tansitor's manufacturing building and its migration pathway may
be altered by the building foundation. The wetland south of
Route 9 is the regional receptor of this plume. See Figure 11
for a cross 'section of the Concrete Pad Area plume.
Because the underground pipes empty into the on-site wetlands
located south of Route 9, low levels of contaminants from the
Concrete Pad Plume have been found in these wetlands. Once in
the wetlands, the contaminant levels are reduced through natural
attenuation and volatilization. These levels do not exceed
surface water quality standards. Based on analytical data from
two monitoring wells on the downgradient portion of the Tansitor
property and calculation of solute transport, there is no
evidence that this plume has migrated off the Tansitor property
via groundwater flow.
Thus, with respect to both the Disposal Area Plume and the
Concrete Area Plume, contamination is limited to the shallow
overburden soils and has not migrated downward to the bedrock.
The absence of VOCs in medium-depth wells downgradient of the
groundwater hinge plane, in bedrock wells, and in the Tansitor
production well (deep bedrock) and neighboring residential wells
further indicates that contaminants from these plumes have not
migrated into lower portions of the basal till. In addition, the
horizontal extent of contamination from these plumes is limited
by discharge to the Fire Pond and ultimately, the wetlands, where
contaminants are levels are reduced through natural attenuation
and volatilization.
The migration patterns of the two plumes are not expected to
change, based upon current site conditions.
C. Stream Sediments and Surface Water
As shown on Figure 6, surface water samples were collected from
the Fire Pond and site streams in areas downstream of the
Disposal Area, the Concrete Pad Area, the Eastern Leach Field,
and a manhole located adjacent to the facility building. These
samples contained low levels of VOCs and metals. The manhole
formerly received water from sinks, a dishwasher, and a floor
drain near a solvent recovery still within the facility; Tansitor
has since modified its drainage system to prevent these
discharges to the manhole.
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Seven VOC and twelve inorganics surface water samples were
collected from nine sampling locations within the perennial and
intermittent streams. Nine VOCs were detected in the perennial
stream surface water (including 1,1,1-TCA, 1,1-DCA, chloroethane,
and N,N-dimethylformamide). No VOCs were detected in surface
water samples from the intermittent stream. The highest
concentration of VOCs were located south of Route 9 in the
perennial stream (location SW-120), where the following levels of
contamination were found: N,N-dimethylformamide (630 ppb),
1,1,1-TCA (-120 ppb), 1,1-DCA (52 ppb), and chloroethane (30 ppb).
Inorganics detected in on-site streams included iron, lead,
silver, and zinc.
Four surface water samples were collected from the Fire Pond.
Samples contained 1,1-DCA, ethyl acetate, and toluene at levels
below 10 ppb. A total of five inorganics were observed including
mercury (0.25 ppb) and manganese (25.8 ppb).
Six VOC, six semi-volatile organic compound (SVOC) and seventeen
inorganics sediment samples were collected from the perennial and
intermittent streams. Six VOCs were detected in stream sediment.
One sediment sample from the intermittent stream (SW-170)
contained methylene chloride (240 ppb). Chloroform and toluene
were also detected in intermittent stream samples at
concentrations below 7 ppb. -Sediment samples from the perennial
stream contained low levels of 1,1,1-TCA, 1,1-DCA, and
chloroform. One sample also contained 430 ppb acetone. A total
of 17 SVOCs were detected, consisting primarily of PAHs. The
highest concentrations were 3.7 ppm fluoranthene, 2.7 ppm pyrene,
and 2.2 ppm benzo(b)fluoranthene, all found at location SE-150,
about 200 feet southwest of the West Leaching Field. As noted
above, these compounds do not appear to be related to past or
current production or wastewater disposal processes at the
facility.
Eighteen inorganics were detected in stream sediments including
copper, lead, silver and zinc at levels as high as 200 ppm (SE-
110), 46.5 ppm (SE-150), 2,560 ppm (SE-170), and 360 ppm (SE-
110), respectively, all of which exceed concentrations found in
upgradient locations (SE-210).
One SVOC and three inorganics samples were collected from the
Fire Pond. No VOCs were detected in Fire Pond sediments. A
total of 17 inorganics were detected, including copper at 69.25
ppm, lead at 26 ppm, arsenic at 6.65 ppm, and chromium at 20:1
ppm.
D. Air
Air quality monitoring was performed during the drilling
activities for the Remedial Investigation (summer 1991, fall
1991, and fall 1992). No VOCs were detected by the field
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instruments.
E. Ecological Resources/Wetlands
Ecological studies at the Site combined a wildlife receptor
inventory and wetland delineation with the stream sediment and
surface water sampling discussed above, and toxicity testing of
benthic invertebrates. Habitats at the Site include forested
uplands, upland fields, forested wetlands, scrub/shrub wetlands,
and streams.
The intermittent stream to the north and west of the facility is
shallow and narrow and flows within a well defined channel.
Sedimentation is limited. The unnamed perennial stream south of
Route 9 flows through shallow and poorly defined channels.
Wetlands are located north of the Fire Pond and make up the
entire parcel of the Site located south of Route 9. The wetlands
north of the Fire Pond are primarily shrub swamp/wet meadow; the
wetlands south of Route 9 are primarily shallow marsh/wet meadow
and hardwood swamp. See Figure 12 for wetland areas.
No threatened and endangered species were identified on the Site.
Fringed gentian (Gentiana crinita), a species classified as a
special-status plant by the State of Vermont, was identified in a
few locations on the Site.
A complete discussion of site characteristics can be found in the
Phase 1A Site Characterization Report, pages 47-116 and in Phase
IB Site Characterization Report, pages 27-78.
VI. SUMMARY OF SITE RISKS
EPA performed a Risk Assessment to estimate the probability and
magnitude of potential adverse human health and environmental
effects from exposure to contaminants associated with the Site.
The risk assessment followed a four step process: 1) contaminant
identification, which identified those hazardous substances
which, given the specifics of the Site, were of significant
concern; 2) exposure assessment, which identified actual or
potential pathways, characterized the potentially exposed
populations, and determined the extent of possible exposure; 3)
toxicity assessment, which considered the types and magnitude of
adverse health effects associated with exposure to hazardous
substances, and 4) risk characterization, which integrated the
three previous steps to summarize the potential and actual risks
posed by hazardous substances' at the Site, including carcinogenic
and non-carcinogenic risks. The results of the public health
risk assessment for the Tansitor Electronics, Inc. Superfund Site
are discussed below followed by the conclusions of the
environmental risk assessment.
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A. Human Health Risk Assessment
1. Contaminant Identification
Fifty-seven contaminants of concern, listed in Tables 1 through 9
of this Record of Decision, were selected for evaluation in the
human health risk assessment. These contaminants of concern were
chosen for the overburden groundwater, Disposal Area surface and
subsurface soils, outside Disposal Area surface and subsurface
soils, stream surface water, Fire Pond surface water, stream
sediment, and Fire Pond sediment. The fifty-seven contaminants
of concern were selected to represent potential site-related
hazards based on toxicity, concentration, frequency of detection,
and mobility and persistence in the environment. A summary of
the health effects of each of the contaminants of concern can be
found in Appendix E of the Final Risk Assessment Report
(September 30, 1993) .
2. Exposure Assessment
Potential human health effects associated with exposure to the
contaminants of concern were estimated quantitatively or
qualitatively through the development of several hypothetical
exposure pathways. These pathways were developed to reflect the
potential for exposure to hazardous substances based on the
present uses, potential future uses, and location of the Site.
The Site is currently occupied by Tansitor Electronics, Inc. and
employs over 100 people. Development on the property consists of
a manufacturing facility, an Etch House, office space, parking
lots, a Fire Pond, a tennis court, and a baseball field. The
majority of this property is undeveloped wooded or open land, and
is accessible. The Disposal Area is currently surrounded by a
fence, with a fire gate that restricts vehicle but not pedestrian
access. The Fire Pond, which was used as a water supply for off-
site fire protection purposes, is also surrounded by a fence. A
bedrock production well, used for production and as a potable
water supply by Tansitor employees, is located south of the
facility and southwest of the Disposal Area. Bedrock groundwater
is used by residents within one mile of the Site as a drinking
water source. Sampling data to date, however, reveals no
contamination of these wells. Presently, the area surrounding
the Site is a mixture of commercial, residential, pasture, and
wooded areas.
The Site is located in an area zoned rural residential with a
commercial corridor overlay along Route 9. As a manufacturing
facility, Tansitor's industrial use of the Site represents a
grandfathered non-conforming use under the zoning laws. Because
the Site could be redeveloped and used for residential purposes
under the zoning laws, EPA considers the future land use of the
Site to be residential.
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Nine potential exposure pathways were quantitatively assessed for
the Site. The following is a brief summary of the exposure
pathways evaluated. A more thorough description can be found on
pages 3-7 through 3-40 of the Final Risk Assessment Report.
Future potential exposure from ingestion of overburden
groundwater as a drinking water source was evaluated. This
pathway assumes that a future user of overburden groundwater
would drink 2 liters of contaminated water for 350 days per year
for 30 years. Bedrock groundwater was not evaluated
quantitatively because of an absence of contamination in this
area.
The current potential exposure from dermal contact and incidental
ingestion of surface soils was evaluated for an adolescent
trespasser ages 9-18. An adolescent was assumed to be exposed
for 30 days per year for 9 years.
A future potential exposure from dermal contact and incidental
ingestion of subsurface soils was evaluated for a young child
(ages 1-6) and an adult. Both a child and adult were assumed to
be exposed 150 days per year. A child was assumed to be exposed
for 6 years and an adult for 30 years.
The current potential exposure to on-site stream sediments via
dermal contact and accidental ingestion was evaluated for an
adolescent who might trespass on the Site. The adolescent was
assumed to be exposed for 39 days per year for 8 years.
A future potential exposure to stream sediments via dermal
contact and accidental ingestion was evaluated for a future
resident. A young child, ages 1-6, was expected to be exposed
for 150 days per year for 6 years. An adult was expected to be
exposed for 150 days per year for 30 years.
The current potential exposure to the Fire Pond surface water and
sediments via dermal contact and incidental ingestion was
evaluated for an adolescent. An adolescent was assumed to be
exposed for 13 days per year for 8 years.
A future potential exposure to Fire Pond surface water and
sediments via dermal contact and accidental ingestion was
evaluated. The receptors were assumed to be future residents
which include a young child, ages 1-6 and an adult. A child was
assumed to be exposed for 26 days per year for 6 years. An adult
was expected to be exposed for 26 days per year for 30 years.
The current potential exposure to stream sediments via dermal
contact and accidental ingestion was evaluated for an adolescent.
The adolescent was expected to be exposed for 39 days per year
for 8 years.
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A future potential exposure to stream sediments via dermal
contact and accidental ingestion was evaluated for future
residents, which include a young child and adult. The child was
expected to be exposed for 150 days per year for 6 years. The
adult was expected to be exposed for 150 days per year for 30
years.
Complete exposure pathways assumptions can be found in Tables 3-3
through 3-16 of the Final Risk Assessment Report.
3. Toxicity Assessment
The human health risk assessment considered scientific evidence
of toxicity and information relating to chemical exposures
(doses) to anticipated health effects (responses) for each
contaminant of concern (COC). Toxicity information can be found
in Section 3.3 and Appendix E in the Final Risk Assessment
Report.
4. Risk Characterization
Excess lifetime cancer risks were determined for each exposure
pathway by multiplying the exposure level with the chemical
specific cancer factor. Cancer potency factors have been
developed by EPA from epidemiological or animal studies to
reflect a conservative "upper bound" of the risk posed by
potentially carcinogenic compounds. That is, the true risk is
unlikely to be greater than the risk predicted. The resulting
risk estimates are expressed in scientific notation as a
probability (e.g. 1 x 10"6 for 1/1,000,000 or one in a million)
and indicate (using this example), that an average individual is
not likely to have greater that a one in a million chance of
developing cancer over 70 years as a result of site-related
exposure as defined to the compound at the stated concentration.
Current EPA practice considers carcinogenic risks to be additive
when assessing exposure to a mixture of hazardous substances.
The hazard index (HI) was also calculated for each pathway as
EPA's measure of the potential for non-carcinogenic health
effects. A hazard quotient is calculated by dividing the
exposure level by the reference dose (RfD) or other suitable
benchmark for non-carcinogenic health effects for an individual
compound. Reference doses have been developed by EPA to protect
sensitive individuals over the course of a lifetime and they
reflect a daily exposure level that is likely to be without an
appreciable risk of an adverse health effect. RfDs are derived
from epidemiological or animal studies and incorporate
uncertainty factors to help ensure that adverse health effects
will not occur. The hazard quotient is often expressed as a
single value (e.g. 0.3) indicating the ratio of the stated
exposure as defined to the reference dose value (in this example,
the exposure as characterized is approximately one third of an
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acceptable exposure level for the given compound). The hazard
quotient is only considered additive for compounds that have the
same or similar toxic endpoint and the sum is referred to as the
hazard index (HI). (For example: the hazard quotient for a
compound known to produce liver damage should not be added to a
second whose toxic endpoint is kidney damage).
Tables 10 and 11 depict the carcinogenic and noncarcinogenic risk
summary for the COCs in overburden groundwater evaluated to
reflect a potential future ingestion of groundwater corresponding
to the average and the reasonable maximum exposure (RME)
scenarios. Table 12 presents a summary of the carcinogenic and
noncarcinogenic risks for all other pathways. These pathways are
summarized since they did not contribute to an unacceptable risk
at the Site (for carcinogenic risk, the acceptable risk is 10"4
or less; for noncarcinogenic risk, the acceptable risk is an HI
of 1 or less, where the HI is the sum per target organ of hazard
quotients for individual contaminants). Appendix F of the Final
Risk Assessment Report presents the chemical-specific estimates
for each exposure pathway.
The results of the Human Health Risk Assessment indicate that
unacceptable carcinogenic and noncarcinogenic risks would result
from ingestion of overburden groundwater for future residents.
The risk is based on a future scenario, since no individuals are
currently ingesting contaminated groundwater at the Site.
Compounds detected in Site overburden groundwater which exceeded
federal or state drinking water standards included; 1,1-
dichloroethene, tetrachloroethene, 1,1,1-trichloroethane, vinyl
chloride, lead, and silver. However, the increased carcinogenic
risk associated with future overburden groundwater consumption
was exclusively due to the presence of 1,1-DCE. Increased
noncarcinogenic risk was due mostly to the presence of 1,1,1-TCA,
1,1-DCE, manganese and silver.
Inhalation of volatile contaminants in groundwater could increase
the risk associated with residential groundwater use by two times
but this pathway was not evaluated quantitatively. Also, lead in
groundwater was not assessed quantitatively because of the lack
of established toxicity values. Exposure to lead in the
groundwater may cause additional risk.
All carcinogenic and noncarcinogenic risk values estimated for
exposure to soils in the Disposal Area, the primary source area
on the Site, were not shown to be excessive for current or
potential future land use. The highest carcinogenic risk
estimated for Disposal Area soil exposures was 8 x 10"7 for
future residents. Future carcinogenic risk associated with
exposure to soils outside the Disposal Area was estimated at 1 x
10"4 (reasonable maximum exposure) and 3 x 10"5 (average case) .
PAHs detected in surface and subsurface soils in the soils
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outside the Disposal Area, at sampling location SS-9, contributed
most significantly to these risk estimates. The specific source
of the PAH contamination is uncertain, since PAH concentrations
varied on- and off-site but it is believed to be indirectly site-
related through facility and automobile fuel combustion.
Noncarcinogenic risk values for Disposal Area soils were
estimated at an HI below one for a trespasser or future resident.
Noncarcinogenic risk values for soil outside the Disposal Area
were estimated at an HI of 0.03 to 1.
All carcinogenic and noncarcinogenic risk values estimated for
exposure to stream sediments were not shown to be excessive for
current or potential future land use except for the initial
calculation for ingestion (HI of 3) for a child exposed to a
maximum concentrations in stream sediments under a future
residential scenario. This initial HI value was driven by the
maximum silver concentration detected in sediments from the
intermittent stream at SE-170 (2,569 mg/kg) collected during the
Phase 1A investigation. Subsequent sampling in the intermittent
stream during Phase IB and post-RI activities did not duplicate
the initial sampling results; in fact, the highest concentration
detected in these follow-up samples was 135 mg/kg. These
additional results do not change the maximum risk associated with
ingestion of the sediment because that hazard index number is
based on the maximum concentration detected. However, the
additional sampling results do provide evidence that the areal
extent of silver-contaminated sediment is very limited. The
follow-up sample collected at SE-170 had a concentration of 1.7
mg/kg, and only the original SE-170 sample had a concentration
greater than 135 mg/kg out of the 17 sediment samples collected
onsite. Therefore, EPA and Vermont ANR concluded that the
sediments in the intermittent stream do not pose an unacceptable
risk to human health.
All carcinogenic and noncarcinogenic risk values estimated for
exposure to stream surface water were not shown to be excessive
for current or potential future land use. A swimming scenario,
including incidental ingestion of and dermal contact with Fire
Pond surface water, was evaluated. No carcinogens were detected
in the available samples and His were well below one for
noncarcinogens detected in the Fire Pond.
Relative to inhalation of airborne contaminants, the soils and
surface water are not considered a significant source for air
contamination. The maximum VOC concentration in Disposal Area
surface soils was 1.3 ppm. The most prevalent VOC in stream
surface water was 1,1,1-TCA with a highest detection of 0.120
ppm. In addition, because of the vegetative cover, dust
emissions are not expected to be significant. If the surface
soils are disturbed in the future, however, there is potential
for air emissions to increase.
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B. Environmental Assessment
EPA also performed an ecological risk assessment. The following
is a brief summary of the ecological risk assessment; a more
thorough description can be found in Section 4 of the Final Risk
Assessment Report.
The environmental assessment analyzed potential risks associated
with exposure of Site biota to contaminants in three mediums of
concern: surface waters of the Site streams and Fire Pond, stream
and Fire Pond sediments, and surface soils. Potential hazards to
aquatic biota from surface water and sediment contaminants were
assessed by comparing mean and maximum contaminant concentrations
with applicable toxicity benchmark values or criteria. Surface
soil contamination within the Disposal Area was evaluated by
modeling exposure to two indicator species (white-footed mouse
and short-tailed shrew). Risk from mercury and silver food chain
transfer was also evaluated within the Fire Pond and streams.
Overall evaluation of potential risk is estimated in the
ecological risk assessment through the calculation of risk
indices. If the total risk index is greater than one, this
indicates that exposure to all COCs within that medium may pose a
risk to organisms. The risk indices for the three mediums can be
found in Tables 4-7 through 4-10 of the Final Risk Assessment
Report.
The mean and maximum acute indices for surface water in the Fire
Pond and intermittent stream were one or less. The acute indices
for the perennial stream were greater than one for silver.
Chronic risk indices were also elevated in the Fire Pond,
intermittent stream, and perennial stream for mercury, aluminum
and iron, and silver, respectively. Therefore, the potential
existed for aquatic biota in these habitats to be adversely
affected. Aluminum and iron concentrations appeared to represent
background concentrations and not to be related to site
activities. Mercury was detected sporadically, and again does
appear to be related to site activities.
Mean and maximum risk indices for stream sediments were also
elevated for the Fire Pond, intermittent stream and perennial
stream. In an effort to further characterize potential
ecological risk associated with the elevated concentrations of
silver detected in the perennial stream, EPA collected additional
samples and conducted sediment toxicity,tests in January and
February 1993. These sediment samples were collected from three
depositional areas within the perennial stream and two reference
locations. Silver concentrations from the three perennial stream
locations were similar to those collected earlier (60.8, 55.0,
and 36.1 mg/kg).
The sediment toxicity tests concluded that no statistically
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significant differences in survival or growth for both test
organisms (Hyallela azteca and Chironomous tentans) were observed
between the three perennial stream samples and the two reference
samples. Therefore, EPA and Vermont ANR concluded that the
silver concentration detected within the perennial stream does
not present a significant risk to benthic or other organisms
inhabiting the stream.
Contaminants detected within the surface soils of the Disposal
Area are not expected to impact wildlife receptors that forage
within this area. Food chain impacts to wildlife foraging on
fish within the Fire Pond may occur if feeding is concentrated at
the pond. liowever, because of the small size of the Fire Pond,
it is unlikely that this aquatic habitat contributes a
significant percentage of the total food consumed by pescivorous
species. Estimated silver concentrations in macroinvertebrates
of the intermittent and perennial streams are below the dietary
recommendation for silver intake. Therefore, EPA and Vermont ANR
concluded that neither the surface soils or Fire Pond pose a
significant risk to environmental receptors.
C. Conclusions
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health and welfare. Specifically, the
human health risk assessment identified overburden groundwater as
posing probable health risks exceeding EPA risk management
criteria. Environmental risks initially associated with the
perennial stream sediments were determined to be nonsignificant
by EPA after EPA-conducted toxicity testing.
The response action selected in this ROD addresses the risk at
the Site by preventing exposure to contaminated groundwater and
adds contingencies to address any future migration of
contaminated groundwater, if determined to be necessary, to
protect human health and the environment.
VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. Statutory Requirements/Response Objectives
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial.actions that are
protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory
requirements and preferences, including: a requirement that EPA's
remedial action, when complete, must comply with all federal and
more stringent state environmental standards, requirements,
criteria or limitations, unless a waiver is invoked; a
requirement that EPA select a remedial action that is cost-
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effective and that utilizes permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable; and a preference for remedies in
which treatment which permanently and significantly reduces the
volume, toxicity or mobility of the hazardous substances is a
principal element over remedies not involving such treatment.
Response alternatives were developed to be consistent with these
Congressional mandates.
Based on preliminary information relating to types of
contaminants, environmental media of concern, and potential
exposure pathways, remedial action objectives were developed to
aid in the development and screening of alternatives. These
remedial action objectives were developed to mitigate existing
and future potential threats to public health and the
environment. These response objectives were:
To eliminate or minimize the threat posed to human
health and the environment by preventing exposure to
groundwater contaminants by any individual who may use
the groundwater within the area of the shallow plumes
(as shown on Figures 8 and 9) , or within an area where
groundwater could become contaminated as a result of
pumping activities;
t To prevent the migration of groundwater contamination
beyond its current extent, or to monitor the
groundwater to ensure that contamination is not
migrating beyond its current extent; and
If technically practicable, to restore contaminated
groundwater to drinking water standards, and to a level
that is protective of human health and the environment.
B. Technology and Alternative Development and Screening
CERCLA and the NCP set forth the process by which remedial
actions are evaluated and selected. In accordance with these
requirements, a range of alternatives were developed for the
Site.
As stated previously, the risk assessment of the two source
areas, Disposal Area and Concrete Pad area, determined that the
VOC concentrations remaining in these areas to be within
acceptable range from a human health and environmental
perspective. Therefore, the source areas present no significant
risk either under current site conditions or under potential
future residential use. Similarly, the same determination was
made for the soils from beyond these two areas. Additional
sampling of the intermittent stream sediments allowed EPA to
reassess the initial risk assessment, and to determine these
sediments did not pose an unacceptable risk to human health.
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Consequently, no source control alternatives were evaluated for
the Tansitor Site.
With respect to groundwater response action, the RI/FS developed
a limited number of remedial alternatives with a goal of
attaining protection of human health and the environment within
different timeframes using institutional controls and
technologies, and a no action alternative.
Chapter 5 of the Feasibility Study identified, assessed, and
screened technologies based on implementability, effectiveness,
and cost. These technologies were combined into three management
of migration (MM) alternatives. Chapter 6 of the Feasibility
Study presented the remedial alternatives developed by combining
the technologies identified in the previous screening process in
the categories identified in Section 300.430(e) of the NCP. The
purpose of the initial screening was to narrow the number of
potential remedial actions for further detailed analysis while
preserving a range of options. Each alternative was then
evaluated in Chapter 7 of the Feasibility Study.
In summary, all three management of migration remedial
alternatives screened in Chapter 6 were retained for detailed
analysis. Table 13 identifies the three alternatives that were
retained through the screening process, as well as those
technologies that were eliminated from further consideration.
C. Technical Impracticability Evaluation
As the FS progressed, the field data suggested restoration of the
groundwater using treatment might not be feasible. Consequently,
as part of the FS, a study was performed to determine whether it
would be technically practicable to restore contaminated
groundwater to drinking water standards, including Maximum
Contaminants Levels (MCLs).
Restoration of contaminated groundwater is one of the primary
objectives of the Superfund program. The NCP states that "EPA
expects to return usable ground waters to their beneficial uses
wherever practicable, within a timeframe that is reasonable given the
particular circumstances of the site." Section 300.430(a)(1)(iii)(F)
of the NCP. Generally, restoration cleanup levels in the Superfund
program are established by applicable or relevant and appropriate
requirements (ARARs), such as the use of Federal or State standards
for drinking water quality.
Further, under CERCLA, an alternative selected to address
contamination at a Site must achieve the ARARs identified for the
action, or provide the basis for waiving the ARARs. ARARs may be
waived for any of six reasons, including where compliance with
the requirement is technically impracticable from an engineering
perspective. See Section 121(d)(4) of CERCLA and Section
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300.430(f)(1)(ii)(C) of the NCP.
The primary considerations for determining the technical
impracticability (TI) of achieving ARARs are: engineering
feasibility and reliability. See NCP Preamble, 55 Fed. Reg. 8748
(March 8, 1990).
EPA's Guidance for Evaluating the Technical Impracticability of
Ground-Water Restoration. (OSWER Dir. 9234.2-25, September 1993,
Interim Final) indicates that, in some cases, where supported
adequately by detailed site characterization and data analysis,
technical impracticability (TI) decisions may be made in the
Record of Decision, prior to remedy implementation. This
guidance also provides for the following TI evaluation
components:
1. Specific ARARs or media standard for which TI determinations
are sought;
2. Spatial area over which the TI decision will apply;
3. Conceptual model that describes site geology, hydrogeology,
groundwater contamination sources, transport and fate;
4. An evaluation of the restoration potential, including
predictive analyses of the timeframes to attain required
cleanup levels and a demonstration that no other remedial
technologies could be capable of achieving groundwater
restoration; and
5. Cost estimates of the proposed remedy options.
Following a TI evaluation, EPA's goal of restoring contaminated
groundwater within a reasonable timeframe will be modified where
restoration is found to be technically impracticable. In such
cases, EPA will select an alternative remedial strategy that is
technically practicable, protective of human health and the
environment, and satisfies the requirements of CERCLA and the
NCP. Where groundwater ARARs are waived at a Superfund site due
to technical impracticability, EPA's general expectations are to
prevent further migration of the contaminated groundwater plume,
prevent exposure to the contaminated groundwater, and evaluate
further risk reduction measures as appropriate. See Section
300.430(a)(1)(iii)(F) of the NCP. These expectations should be
evaluated along with the nine remedy selection criteria provided
in the NCP.
The results of the TI Evaluation for the Tansitor Site are
provided below:
1. ARARs
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Under the EPA Groundwater Protection Strategy, EPA has classified
the aquifer beneath the Site as a Class II aquifer, i.e.,
groundwater currently and potentially a source for drinking
water.1 Thus, Maximum Contaminant Levels (MCLs), and non-zero
MCLGs, established under the Safe Drinking water Act, are ARARs.
MCLs for the major contaminants of concern include:
Contaminant
1,1, 1-Trichloroethane
(1,1,1-TCA)
1 , 1-Dichloroethylene
(1,1-DCE)
Trichloroethylene
Tetrachloroethylene
Vinyl chloride
MCL
200 ppb
7 ppb
5 ppb
5 ppb
2 ppb
2. Spatial Area
For the Tansitor Site, the TI zone covers a horizontal area of
approximately 9.6 acres. It is bounded by the facility water
reservoir (northwest corner), MW-107 (northeast corner), northern
right-of-way of Route 9 by the Eastern Leachfield (southeast
corner), and the northern right-of-way of Route 9 just beyond MW-
109 (southwest corner). This coincides exactly with the
1 As stated in Section V.A. of this ROD, the aquifer
beneath and in the vicinity of the Site was generally classified
by VT ANR as Class III, which is defined as suitable as a source
of water for individual domestic drinking water supply,
irrigation, agricultural use, and general industrial and
commercial use. However, in response to the data obtained during
the RI, on November 23, 1993, Vermont ANR reclassified
groundwater beneath a limited 9.6 acre area of the Site, where
groundwater contamination was detected, from Class III to Class
IV. Class IV groundwater is defined as not suitable as a source
of potable water but suitable for some agricultural, industrial
and commercial use. Given the use of the bedrock groundwater on
and in the vicinity of the Site as a source of drinking water,
EPA declines to follow the state reclassification in determining
the beneficial use of the groundwater and the appropriate cleanup
standards. Thus, EPA relies on its Groundwater Protection
Strategy in determining that the aquifer beneath the Site is a
Class II aquifer, and in determining that MCLs and MCLGs are
ARARs at this Site.
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horizontal Class IV area established by the Vermont Groundwater
Reclassification Order and encompasses the Disposal Area plume,
the Concrete Pad Area plume, and the Eastern Leachfield, where
vinyl chloride had been detected.2
Vertically, however, the TI zone differs from the Vermont
Groundwater Reclassification Order. The TI zone extends
approximately 180 feet below the ground surface and encompasses
both the ablation till and the basal till. The Vermont
Groundwater Reclassification Order applies to both the overburden
and the bedrock groundwater. The language in the
reclassification regulation does not provide for different
vertical groundwater classifications. Based on current
conditions at the Site, the plumes do not appear to be migrating
vertically. However, as the bedrock aquifer beneath the Site is
currently functioning as the sole source of drinking water for
the facility and surrounding properties, EPA believes in order to
protect human health it is necessary to restrict the TI zone to
the overburden soils. See Figure 13 for the locations of the
plume locations and Class IV and TI zones.
3. Conceptual Model
The conceptual model serves as a foundation for evaluating the
restoration potential of the Site and, thereby technical
impracticability as well. The model integrates the geology and
hydrogeology, contamination sources, properties and distribution,
release mechanisms and rates, fate and transport processes,
current and future receptors, and other elements to define the
contamination and allow analysis of site restoration potential.
The site geology and hydrogeology have been described in Section
V.A. of this ROD. The prominent points include the following:
the subsurface soils are comprised of approximately 180
feet of glacial till;
2 It is noted that the current extent of contamination
comprises only a portion of the TI zone. The extent of the TI
zone was chosen in order to coordinate EPA's and the State's
future evaluations of site conditions. Thus, the TI zone was
delineated to identically match the Class IV zone horizontally.
The TI zone was not chosen with the expectation that
contamination would eventually migrate to the rest of the TI
zone. Moreover, it is noted that the geologic and hydrogeologic
conditions present in the contaminant plumes are also present in
the remainder of the TI zone, so restoration of this area if it
were to become impacted would also be considered to be
technically impracticable to restore to drinking water standards,
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the average silt and clay content of the upper 50 feet
is 51%;
the average horizontal hydraulic conductivity of the
upper 50 feet is calculated to be 0.22 ft/day using
field measurements;
horizontal hydraulic conductivity decreases with depth
through the remainder of the till;
the vertical hydraulic conductivity averages less than
.002 ft/day using laboratory and field measurements;
the effective hydraulic conductivity averages .084
ft/day;
just south of the Disposal Area and Concrete Pad, the
vertical component of groundwater flow changes to
upward, thereby limiting vertical flow down to bedrock;
this upward gradient was not reversed during a 24-hour
pump test of the facility well; and
a water balance calculation estimated the groundwater
flow from the Disposal Area comprised approximately 6%
of the groundwater flow into the Fire Pond and
comprised less than 1% of the entire flow into the Fire
Pond (surface water runoff comprised approximately 86%
of the total flow).
The distribution of contaminants from the two source areas, the
Disposal Area and Concrete Pad, have been described in Sections
V.B. and V.C. of this ROD. The prominent findings are that the
concentrations of certain dissolved contaminants in the
groundwater are extremely high and that 1,1,1-TCA and 1,1-DCE,
the most frequently detected contaminants at the Site, tend to
adhere to soil particles.
The average concentration of 1,1,1-TCA.detected in the Disposal
Area plume is estimated to be 88,000 ppb, more than 40 times its
MCL of 200 ppb. This concentration is approximately ten percent
of the water solubility value for 1,1,1-TCA, suggesting that
DNAPL 1,1,1-TCA may be present in the soils beneath the water
table. Because of their affinity to adhere to soil, these
contaminants move slowly through groundwater and are difficult to
extract.
Fate and transport processes that affect VOC migration in
groundwater include rate of desorption, organic carbon content in
the soil, and biodegradation. As stated above, these compounds
adsorb to soil particles, slowly releasing into the groundwater.
The presence of organic carbon further increases the adsorption
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of these compounds and decreases their flow velocity in the
groundwater. The presence of 1,1-DCE suggests that degradation
is occurring (transformation of 1,1,1-TCA), but complete
mineralization of the chlorinated compounds to chlorine ions,
carbon dioxide and water under the anaerobic conditions at the
Site is expected to be very slow.
Current and future receptors have been described in Section VI of
this ROD and are summarized here. The human health risk
assessment identified a youth trespasser as the most likely
current receptor, and also indicated that the current risk from
soils was not excessive. The risk assessment identified
residential use of groundwater from the till as the only
potential future receptor for which risk would be excessive.
The ecological risk concluded that the site contaminants have not
impacted the wildlife receptors and food chain impacts are not
considered to be significant.
4. Evaluation of the Restoration Potential
As indicated above, the two contaminant sources no longer act as
active sources, and therefore source removal or containment are
not considered necessary for restoration of the Site.
Restoration potential of the groundwater was evaluated with
computer modeling. Modeling was used to estimate timeframes to
achieve drinking water standards through either natural
attenuation or extraction and treatment of the groundwater. This
modeling took into account the low permeability of the overburden
soils, the high concentrations of dissolved contaminants, and the
difficulty of extracting 1,1,1-TCA and 1,1-DCE. The range of
time required to meet drinking water standards by extraction and
treatment was from 160 years to more than 630 years. Within this
range, EPA considers a timeframe of 300 years to be the most
likely based on assumptions used in the model. The range of time
required to meet drinking water standards by natural attenuation
was from 220 years to more than 1,150 years. Within this range,
EPA considers a timeframe of 420 years to be the most likely
based on assumptions used in the model.
Computer modeling was also used to evaluate whether short term
pumping would significantly decrease the volume and shorten the
time to achieve drinking water standards through natural
attenuation. EPA concluded that even after 50 years of pumping,
it would still take approximately 300 more years for natural
attenuation to restore groundwater to drinking water standards.
All of the above estimated cleanup timeframes are based on an
assumption that there are no DNAPLs at the Site. In the event
that DNAPLs are present, the length of time needed for cleanup
would be even longer. As the modeling supported the technical
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impracticability of extracting the groundwater, other
technologies were evaluated to determine whether they could
attain drinking water standards at the Site within a reasonable
timeframe. Three innovative technologies, permeable reaction
wall, bioremediation, and soil vapor extraction, were evaluated
as part of the Feasibility Study. This evaluation concluded that
these technologies would not be able to attain the action levels
within the contaminant plume within a reasonable timeframe.
5. Cost Estimates
The cost estimates of a remedy using groundwater extraction and
treatment and one relying on institutional controls are described
in Section VIII below.
More detailed information regarding the technical impracticability
of restoration of the shallow groundwater can be found in the Final
Draft Technical Impracticability Evaluation Report.
VIII. DESCRIPTION OF ALTERNATIVES
This Section provides a narrative summary of each alternative
evaluated. A detailed tabular assessment of each alternative can
be found in Table 7-3 of the Feasibility Study and is included
here in the Record of Decision as Table 14.
A. Management of Migration (MM) Alternatives Analyzed
Management of migration alternatives address contaminants that
have migrated from the original source(s) of contamination. At
the Tansitor Electronics, Inc. Superfund Site, contaminants have
migrated from the two source areas, Disposal Area and Concrete
Pad, to the overburden groundwater and southerly to the Fire Pond
and toward the wetlands, respectively. The Management of
Migration alternatives evaluated include a no-action alternative,
MM-1, an institutional control/groundwater monitoring
alternative, MM-2, and an active remediation/institutional
control alternative, MM-3.
MM-1 No-Action
This alternative was evaluated in detail in the FS to serve as a
baseline for comparison with the other alternatives under
consideration. Under this alternative, no action would occur to
actively reduce chemical contamination at the Site. Groundwater
from the Disposal Area and Concrete Pad Area would continue to
migrate into the Fire Pond, intermittent stream, and storm drain
system as presently occurs. EPA would make no efforts to
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restrict use of the contaminated groundwater,3 and would
establish no contingencies to address possible changes in the
migration of contaminants in the future. Because the No-Action
alternative would result in VOCs remaining onsite, the CERCLA
statute requires that the Site be reviewed every five years to
ensure the continued protection of human health and the
environment.
Estimated Total Cost (net present worth): $3,000 (cost for
first five year review)
Alternative MM-2; Institutional Controls/Monitoring
MM-2 uses institutional controls to reduce the identified risk
associated with contaminated groundwater by controlling the
potential exposure route. An unacceptable health risk is
associated with the ingestion of VOC-contaminated groundwater if
a future resident of the Site were to install a drinking water
well into the shallow contaminant plume, or in an area where
groundwater could become contaminated as a result of pumping
activities. MM-2 includes the following key elements:
use of institutional controls to prevent the potential
use of shallow groundwater at the Site as a drinking
water source, and to prohibit activities that would
adversely affect the groundwater plumes;
long-term monitoring of site groundwater on a regular
basis to evaluate changes in site conditions over time.
In the event that contaminated groundwater migrates
significantly beyond its current extent, EPA will
assess the changes and may require future actions; and
a review of the Site every five years to ensure the
continued protection of human health and the
environment.
Estimated Time for Implementation: 6-12 months
Estimated Time of Operation: 30 years
Estimated Capital Cost; $18,000
Estimated Annual O & M (present worth): $30,600
Estimated Total Cost (net present worth): $390,000
Alternative MM-3; Groundwater Extraction/Treatment/Discharge/
Institutional Controls/Monitorincr
3 The No-Action alternative does not take into account VT
ANR's decision to reclassify and restrict the use of contaminated
site groundwater based on the findings in the RI.
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Alternative MM-3 would involve extraction of groundwater,
followed by treatment by chemical and physical processes to
remove VOCs and possibly metals. A network of extraction wells
would be installed onsite to pump groundwater from the overburden
soils. The extracted groundwater would be pretreated to remove
metals, generating sludge which may require disposal as a
hazardous waste. VOCs would be removed from the water by a
process called air stripping, which involves forcing air through
contaminated water and causing the VOCs to vaporize. The vapors
must then be filtered before they are released to the air to
collect the contaminants. Finally, treated groundwater would be
discharged to the Fire Pond in accordance with permissible
surface water discharge limits. Alternative MM-3 would also
incorporate the institutional controls, long-term monitoring
components, and five-year reviews described under Alternative MM-
2, until drinking water standards are obtained in the
groundwater.
Estimated Time for Design and Construction: 1-3 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $595,000 - 1,660,000
Estimated 0 & M (present worth): $90,000 - 185,000
Estimated Total Cost (net present worth): $1,480,000 - 3,320,000
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
A. Nine Evaluation Criteria
Section 121(b)(1) of CERCLA presents several factors that at a
minimum EPA is required to consider in its assessment of
alternatives. Building upon these specific statutory mandates,
the National Contingency Plan articulates nine evaluation
criteria to be used in assessing the individual remedial
alternatives. A detailed analysis was performed on the
alternatives using the nine evaluation criteria in order to
select a site remedy. These criteria are summarized as follows:
Threshold Criteria
The two threshold criteria described below must be met in order
for the alternatives to be eligible for selection in accordance
with the NCP.
1. Overall protection of human health and the environment
addresses whether or not a remedy provides adequate
protection and describes how risks posed through each
pathway are eliminated, reduced or controlled through
treatment, engineering controls, or institutional controls.
2. Compliance with applicable or relevant and appropriate
requirements (ARARS) addresses whether or not a remedy will
29.
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meet all of the ARARs of other Federal and State
environmental laws and/or provide grounds for invoking a
waiver .
Balancing Criteria
The following five criteria are utilized to compare and evaluate
the elements of one alternative to another that meet the
threshold criteria.
3. Long-term effectiveness and permanence addresses the
criteria that are utilized to assess alternatives for the
long-term effectiveness and permanence they afford, along
with the degree of certainty that they will prove
successful.
4 . Reduction of toxicity, mobility, or volume through treatment
addresses the degree to which alternatives employ recycling
or treatment that reduces toxicity, mobility, or volume,
including how treatment is used to address the principal
threats posed by the Site.
5. Short term effectiveness addresses the period of time needed
to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period, until cleanup goals
are achieved.
6. Implementability addresses the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
option.
7. Cost includes estimated capital and Operation Maintenance
(O&M) costs, as well as present-worth costs.
Modifying Criteria
The modifying criteria are used on the final evaluation of
remedial alternatives generally after EPA has received public
comment on the RI/FS and Proposed Plan.
8. State acceptance addresses the State's position and key
concerns related to the preferred alternative and other
alternatives, and the State's comments on ARARs or the
proposed use of waivers .
9. Community acceptance addresses the public's general response
to the alternatives described in the Proposed Plan and RI/FS
report .
A detailed tabular assessment of each alternative according to
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the nine criteria can be found in Table 7-3 of the Feasibility
Study (and repeated here in the Record of Decision as Table 14).
Following the detailed analysis of each individual alternative, a
comparative analysis was conducted, focusing on the relative
performance of each alternative against the nine criteria. This
comparative analysis can be found in Section 7.30 of the
Feasibility Study.
B. Comparison of Alternatives
The section below presents the nine criteria and a brief
narrative summary of the alternatives and the strengths and
weaknesses according to the detailed and comparative analysis.
1. Overall Protection of Human Health and the Environment
Both Alternative MM-2 and Alternative MM-3 would eliminate or
reduce risks to human health and the environment by controlling
exposure to contaminated groundwater in the shallow soils.
Actual removal of contaminants through Alternative MM-3 would
reduce risk, but not significantly beyond the protection offered
by the institutional controls required by both MM-2 and MM-3.
Because the No-Action alternative (MM-1) would not restrict
exposure to the contaminated shallow groundwater, it is not
considered to provide overall protection.
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
None of the alternatives, MM-1, MM-2, or MM-3, would attain
federal drinking water standards within a reasonable time period.
As discussed above, based on hydrogeologic factors and
contaminant-related factors present at this Site, EPA estimates
that drinking water standards would not be attained through
natural attenuation or extraction and treatment of groundwater
for several centuries. Specifically, the overburden soils are of
low permeability. Pumping of VOC-contaminated water from the
overburden soils would be done at an extremely slow rate.
Further, the concentration of dissolved contaminants in the
groundwater, such as 1,1,1-TCA, is extremely high. Moreover,
1,1,1-TCA and 1,1-DCE, which are the most frequently detected
contaminants at the Site, tend to adhere to soil particles. As a
result, these contaminants move slowly through groundwater and
are difficult to extraction. Thus, EPA believes that it is
technically impracticable from an engineering perspective to
attain drinking water standards at this Site within the TI zone.
Although alternatives MM-2 and MM-3 would not attain drinking
water standards, they would attain all other ARARs (such as air
and surface water discharge limits [MM-3] and groundwater
monitoring requirements [MM-2 and MM-3]).
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3. Long-term Effectiveness and Permanence
The institutional controls proposed in MM-2 would be effective in
the long term. As discussed previously, hydrogeologic conditions
at this Site contain the plume within a limited area. Because
the area to be controlled is relatively small, compliance with
institutional controls could be easily monitored. In addition,
because it is technically impracticable to attain federal
drinking water standards at this Site, long-term groundwater
monitoring is necessary to assure that Site conditions do not
change over time. Long-term monitoring of the groundwater and
the leach field would effectively detect both the horizontal and
vertical migration of contaminants beyond their current extent.
Alternative MM-3 would also be effective in the long term.
However, its effectiveness would be due almost entirely to the
implementation of institutional controls, because even if
extraction and treatment were performed, contamination well above
drinking water standards would still remain in the groundwater
for several centuries. Alternative MM-1 would not provide long-
term effectiveness or permanence as no further action would be
taken to reduce risk.
4. Reduction of Toxicity, Mobility, or Volume through Treatment
Neither MM-1 nor MM-2 actively remove or treat the contamination
at the Site, and so do not result in any reduction of toxicity,
mobility, or volume other than that achieved through natural
attenuation.
Alternative MM-3, which includes groundwater extraction and
treatment, would reduce the volume and mobility of existing
contamination at the Site. Treatment would reduce the toxicity
of groundwater but would produce contaminated residual materials
from the treatment process, such as used carbon filters from the
air stripping process and sludge from the settling process, which
then might require appropriate treatment and disposal. Based on
the hydrogeology of the Site and the high levels of dissolved
contaminants, EPA does not anticipate that reductions in
toxicity, mobility or volume achieved through groundwater
extraction and treatment would significantly reduce the hazards
posed by the Site within a reasonable timeframe. Although
contaminant levels would be reduced, drinking water standards
would not be achieved or approached for several centuries.
5. Short-term Effectiveness
Aside from the No Action alternative, MM-2 would pose the lowest
potential short-term risks from implementation. Risks would only
be associated with the continued monitoring of site groundwater
and would be negligible. Alternative MM-3 poses a greater short-
term risk to construction workers during the construction and
operation of the extraction well network, groundwater treatment
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system, and discharge outlet to the Fire Pond. These risks,
however, could be effectively controlled through the use of
personal protective equipment and by following safe work
practices.
6. Implementability
Given that the limited area to be controlled is currently owned
by one owner, Tansitor Electronics, Inc., EPA anticipates that
deed restrictions would be easy to implement. In addition, VT
ANR's reclassification of groundwater beneath the Site to a Class
IV aquifer supports the goal of preventing its use as a drinking
water source. The monitoring component of the preferred
alternative could also be readily implemented, due to the limited
extent of the two plumes of contaminated groundwater and the
number of monitoring wells already present onsite.
Groundwater extraction systems such as the one proposed in
Alternative MM-3 have been routinely installed at other sites.
However, because the soils have low permeability, pumping would
be extremely slow. For this reason, and the high concentrations
and types of dissolved contaminants, significant reductions in
contamination would be unlikely within a reasonable time period.
7. Cost
A comparison of the estimated present worth costs for each
alternative is as follows:
Total Total
Alternative Capital 0 & M Total Costs
MM-1 $ 0 $ 3,000 $ 3,000
MM-2 18,000 30,600 390,000
MM-3 595,000- 90,000- 1,480,000-
1,660,000 185,000 3,320,000
The estimated total present worth costs for MM-2 and MM-3 are
based on thirty years of operation and a 7% interest rate; the
present worth cost for MM-1 is based on one five year review.
8. State Acceptance
VT Agency of Natural Resources has reviewed and approved the
RI/FS, Technical Impracticability Evaluation Report and Proposed
Plan, and concurs with the selection of MM-2 as the remedy for
the Tansitor Site.
The State's declaration of concurrence with this Record of
Decision is attached as Appendix A.
9. Community Acceptance
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The comments received from the community on the RI/FS and the
Proposed Plan during the public comment period, and EPA's
responses to the comments, are summarized in the Responsiveness
Summary in Appendix D. of this document. In addition, a summary
of the comments and EPA's responses appears below.
Oral comments were received from members the community during the
public hearing. Various community members expressed support for
the Proposed Plan, under current conditions. However, some
community members expressed concern about a proposed rock quarry
to be constructed in New York State, and within a mile to the
west of the Site. Specifically, community members are concerned
that excavation and pumping at the proposed quarry might
adversely impact the contaminant plumes at the Tansitor Site.
Given these comments, EPA reviewed a draft Environmental Impact
Statement concerning the proposed rock quarry. As indicated in
the Responsiveness Summary to this ROD, EPA found nothing in the
EIS or the comments by community members which warranted any
alteration of the selected remedial action for the Site. In
addition, EPA found no affirmative data in the EIS which suggests
that the proposed quarry would adversely affect contamination
from the Tansitor Site. Nevertheless, in EPA's view, additional
data collection, including a pump test, would be warranted in
order to fully understand the extent of possible impact from the
proposed quarry. It is EPA's understanding that the matter of
whether the quarry is to be constructed, and the potential
impacts of the proposed quarry, are presently under consideration
by the State of New York.
Written and oral comments also were received from the two PRPs
that performed the RI/FS under an Administrative Order By
Consent. Both PRPs concurred with the Proposed Plan and
advocated that the Site be removed from the National Priorities
List. In response, EPA acknowledged the PRPs concurrence with
the remedial action, and indicated that the issue of whether to
delete the Site from the National Priorities List would be
considered after the issuance of this ROD.
X. THE SELECTED REMEDY
The remedy selected to address contamination at the Tansitor
Electronics, Inc. Superfund Site is MM-2, which includes
institutional controls, long-term monitoring, contingencies, and
five-year reviews. This remedy addresses the groundwater
contamination at the Site. A detailed description of the
selected remedy is presented below.
A. Institutional Controls
Institutional controls will be established to prevent the use of
groundwater impacted by the Site and to inform future purchasers
of the property of the groundwater restrictions associated with
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the property. These institutional controls will consist of deed
restrictions, which will provide permanent, enforceable
restrictions on the use of groundwater at the Site. In addition
to the deed restrictions, the Vermont Groundwater
Reclassification Order will also serve to restrict use of the
Site groundwat e r.
The deed restrictions shall generally provide as follows:
(1) No water supply well shall be installed in either the
overburden soils or bedrock within the area designated as a Class
IV Groundwater Area by the State of Vermont (marked generally by
MW-107U in the northeast, the Eastern Leach Field in the
southeast, MW109U in the southwest, and the Water Reservoir in
the northwest). A copy of Reclassification Order is found in
Appendix C of this ROD.
(2) No water supply well shall be installed in either the
overburden soils or bedrock within the Class III Area on the
Tansitor property without prior EPA approval. Tansitor's
operating facility currently draws its water from a bedrock well
located west of the Class IV area. EPA acknowledges that either
the current owner or potential future owners of the property may
need or desire another source of water outside the Class IV Area
at some time in the future because of possible failure of the
existing well or development on other parts of the property. The
addition of a new well, however, may cause contaminants to
migrate or otherwise affect the contaminant plumes. Therefore,
any proposal for a new well shall demonstrate to EPA that such an
action would not induce movement of the contaminants into
uncontaminated areas. This demonstration shall include, at a
minimum, pump tests and laboratory analysis for VOCs. Should the
demonstration indicate the proposed well would have an adverse
affect on the plume, as determined by EPA, it shall not be
installed. It is not the intent of EPA to preclude the use of
other areas of the Site with this requirement, rather it is to
ensure that the institutional controls and monitoring remain
protective and that further migration is prevented.
In the event that new water supply wells are installed with EPA
approval in the future, additional monitoring positions located
between the contaminant plume and the new water supply well may
be required. These positions will be used to monitor for
possible changes in on-site groundwater flow patterns (as it
affects contaminant distribution). The water level monitoring
program will be accomplished through the periodic use of
continuous recorders on selected monitoring wells during seasonal
low water periods.
(3) The existing water supply well located at the Tansitor Site
shall not be used to extract more than 20,000 gallons of water
per day, without prior EPA approval. As stated above, changes in
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the use of groundwater at and in the vicinity of the plumes may
adversely affect the plume. Therefore, if use and pumping of the
current well were to be proposed beyond the level of the RI pump
test, which was approximately 20,000 gallons per day, a
determination will be made by EPA as to the potential impact on
the plumes.
(4) All of the above-listed restrictions shall remain in effect
as long as contaminated groundwater is present at the Site at
levels in excess of federal drinking water standards, and at
levels that are not protective of human health and the
environment.
With respect to the State or local requirements, as noted above,
the State of Vermont reclassified the groundwater in the area of
the contaminated plumes as Class IV groundwater. Class IV
groundwater under the state classification system is considered
not suitable as a source of potable water but suitable for some
agricultural, industrial, or commercial use. While VT ANR took
this action independently of EPA, EPA believes that the
reclassification, together with institutional controls described
above, will effectively prevent future residential exposure to
contaminated groundwater at the Tansitor Site.
The risk assessment qualitatively evaluated the groundwater
inhalation exposure in a potential residential scenario and
determined it was equal to the risk from ingestion. Calculations
based on the average contaminant concentration in the Disposal
Area plume indicated that inhalation exposure in a future
industrial scenario would also exceed the carcinogenic and
noncarcinogenic risk levels. Therefore, although the VT GWPRS
regulation permits the use of Class IV water for industrial,
commercial, or agricultural activities, the deed restriction
shall ensure that no water supply well be installed within the
overburden or bedrock soils between the Disposal Area and the
Fire Pond.
B. Monitoring
The monitoring program will be implemented to demonstrate that
the conceptual model presented previously is correct, i.e., that
the contaminants are not migrating horizontally beyond the Fire
Pond or vertically toward the bedrock. The monitoring will also
be used to evaluate the overall protectiveness of the remedy.
The groundwater monitoring program shall include sampling and
analytical methods that are appropriate for groundwater sampling
and that accurately measure hazardous constituents in the
samples. Monitoring will be performed in wells located at and
around the property boundary and within the interior of the Site
to monitor the levels, distribution, and migration of VOCs,
silver, and lead. Monitoring will include water level
measurements.
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Groundwater monitoring for VOCs shall be conducted semi-annually
in the Spring and Fall for a period of at least five years. EPA
concurred with VT ANR regarding the sampling locations,
frequency, and analytes for the groundwater monitoring required
by the November 1993 Vermont Groundwater Reclassification Order.
Therefore, the monitoring data collected in accordance with the
Reclassification Order is deemed suitable as part of the semi-
annual monitoring required by this Record of Decision. See
Appendix C of this ROD for a copy of the Reclassification Order.
Groundwater monitoring for silver and lead shall be conducted
semi-annually in the Spring and Fall for a period of at least
three years. As with the VOCs, monitoring data for silver and
lead collected in accordance with the Reclassification Order
prior to this Record of Decision are deemed suitable for this
monitoring.
The monitoring program will include selected groundwater
monitoring wells. To evaluate the vertical extent of the
contaminant plume, at a minimum, the following existing medium
depth and bedrock wells shall be included in all semi-annual
monitoring: MW-101M, MW-112M, MW-104M, MW-105M, MW-103M, ERM-5D,
and MW-103R. To evaluate the horizontal extent of the
contaminant plumes, at a minimum, the following existing shallow
wells shall be included in all semi-annual monitoring: ERM-2S,
MW-104U, ERM-4S, MW-108U, ERM-5S, MW-109U, MW-110U, MW-114U and
MW-ELF.
Should the groundwater monitoring indicate a potential impact to
surface water quality, e.g. VOCs, lead or silver detected in MW-
109U, MW-110U, or MW-114U, surface water and sediment sampling
shall be conducted in the unnamed stream south of Route 9.
The surface water monitoring program shall include sampling and
analytical methods that, as determined by EPA, are appropriate
for surface water sampling and that accurately measure hazardous
constituents in the samples.
The sampling and monitoring program presented above for VOCs
shall be conducted for at least five years. At that time, and as
determined by EPA, the frequency and list of analytes monitored
in the groundwater (and surface water if applicable) will be
evaluated and possibly reduced, in accordance with relevant and
appropriate RCRA groundwater monitoring standards. Subsequent to
the initial reassessment, the duration and scope of monitoring
activities will be reassessed periodically based on sampling
results and observed trends. At a minimum these reassessments
will occur during each five-year site review described below.
Finally, all monitoring reports will also include documentation
detailing the level of use of the existing water supply well at
the Site, consistent with the requirement that this well should
not be used to extract more than 20,000 gallons of water per day.
37
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C. Contingencies for Future Action
EPA has established contingencies in the event that wells outside
the current contaminant plumes become impacted.
As stated previously, the first of these contaminant plumes (the
Disposal Area Plume) extends from the Disposal Area to the Fire
Pond and is approximately 50-60 feet thick. The second plume
(the Concrete Pad Area Plume) extends from the Concrete Pad to
Tansitor's manufacturing building and is approximately 60 feet
wide and 20 feet thick. Certain existing monitoring wells that
are outside of these two plumes are identified below. EPA's
contingencies for future action will be triggered in the event
that contamination, above specified levels, is detected in the
existing monitoring wells identified below.
The contingencies are ordered in terms of depth, beginning with
shallow wells and moving down to bedrock. This appears to be the
most likely sequence for detection of contaminants, should
migration occur from the current plumes. With each contingency
described below, an evaluation of the field sampling and
analytical methods shall be performed in the event of detection
of a contaminant of concern. The monitoring well in question
shall be resampled if the review indicates the methods did not
meet data quality objectives. If the evaluation indicates the
detection is valid, the frequency of sampling for the appropriate
well or wells shall be increased to quarterly for overburden
wells and monthly for bedrock wells to characterize seasonal
fluctuations and migration trends.
For each contingency, the concentrations of contaminants shall be
compared to their respective and applicable standard: MCLs, non-
zero MCLGs, Vermont drinking water standards where more stringent
(VT GWPRS are applicable at the Class III/IV boundary), or health
based levels if the contaminant has no MCL. The contingencies
are as follows:
1. If concentrations of 1,1,1-TCA or 1,1-DCE or any other
contaminants are detected at or above one half their respective
standard in compliance monitoring wells outside the current
limits of the contaminant plumes (i.e., in wells 101M, 104M,
105M, 103M, ERM-5D, ERM-4S, ERM-5S, 109U, 110U, and 114U), the
frequency of sampling shall be increased to quarterly.
2. If concentrations of 1,1,1-TCA or 1,1-DCE or any other
contaminants are detected at or above their respective standard
in the shallow depth compliance monitoring wells. ERM-5S, 109U,
110U, and 114U, an evaluation of possible impacts to surface
water habitat shall be performed.
3. If concentrations of 1,1,1-TCA or 1,1-DCE or any other
. 38
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contaminants are detected at or above their respective standard
in any of the medium depth compliance monitoring wells. 101M,
112M, 104M, 105M, 103M, and ERM-5D, the Site conceptual model
shall be reviewed and an evaluation of the possible migration and
impacts to bedrock and surface water shall be performed. This
evaluation will include, to the extent feasible, a consideration
of natural or seasonal fluctuations in groundwater quality that
may affect concentrations.
4. If concentrations of 1,1,1-TCA or 1,1-DCE or any other
contaminants are detected at five times or above their respective
standard for four consecutive quarters in any of the medium depth
compliance monitoring wells. 101M, 112M, 104M, 105M, 103M, and
ERM-5D, additional monitoring wells shall be installed to
determine the vertical extent of the plume. The location and
number of additional well(s) will be determined by EPA based on
the monitoring data. Secondly, an evaluation on the possible
impact to the bedrock and surface water will be performed. This
evaluation will include a review of the need for a groundwater
extraction and treatment system for plume containment, an
alternate drinking water supply, or other remedy.
5. If quantifiable concentrations of 1,1,1-TCA or 1,1-DCE or
any other contaminants are detected in any of the bedrock
compliance monitoring wells, MW-101R and MW-103R, sampling of
bedrock wells shall be increased to monthly. Additional response
actions, including wellhead treatment, an alternate supply of
water for the facility, or pump-and-treat will be evaluated and,
if deemed necessary, implemented.
6. If concentrations of 1,1,1-TCA or 1,1-DCE or any other
contaminants are detected at or above their respective standard
any of the bedrock wells, MW-101R, MW-103R, or the Tansitor
production well, residential water supply wells shall be sampled
within two months after such concentrations are first detected.
Should these residential water supply sampling results indicate
offsite migration has occurred, further actions as deemed
necessary by EPA will be taken.
D. Five-Year Review
Because this alternative would result in contaminants remaining
on-site, EPA will review the Site at least once every five years
after the initiation of the remedial action at the Site to assure
that the remedial action continues to be protective of human
health and the environment. This review will be consistent with
the CERCLA standards applicable for five-year site reviews in
effect at the time of the review.
XI. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Tansitor
39
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Electronics, Inc. Superfund Site is consistent with CERCLA and
the NCP. The selected remedy is protective of human health and
the environment, attains ARARs or invokes an appropriate waiver
and is cost effective.
The selected remedy does not satisfy the statutory preference for
treatment which permanently and significantly reduces the
mobility, toxicity or volume of hazardous substances as a
principal element because it has been determined that it is
technically impracticable to restore the groundwater to drinking
water standards within a reasonable timeframe. Given these
circumstances, the selected remedy utilizes alternate treatment
technologies or resource recovery technologies to the maximum
extent practicable.
A. The Selected Remedy is Protective of Human Health and the
Environment
The remedy at this Site will permanently reduce the risks posed
to human health and the environment by eliminating, reducing or
controlling exposures to human and environmental receptors
through institutional controls, groundwater monitoring, and
contingencies for further assessment and action, if necessary.
More specifically, institutional controls will prevent exposure
to the contaminated groundwater in the overburden soils.
Additionally, these controls will prohibit future activities
(without further investigation) that may cause the plume to
migrate, such as the construction and use of additional water
supply wells in the immediate vicinity of the plumes.
Groundwater contamination at the Site is currently limited to the
overburden, and is not migrating either horizontally or
vertically. Groundwater monitoring will detect contaminant
migration, should it occur in the future, and thereby assure that
the institutional controls remain protective. In addition, in
the event that contaminants migrate either horizontally or
vertically in the future, the contingency provisions will require
an evaluation to ensure that necessary actions be taken at the
Site to maintain protection of human health and the environment.
B. The Selected Remedy Waives Attainment of MCLs, and Attains
All Other ARARs
1. EPA Considers It Technically Impracticable To Restore
Groundwater to MCLs
As explained above, MCLs and non-zero MCLGs established under the
Safe Drinking Water Act are ARARs at the Tansitor Site. Under
CERCLA, the remedy must meet, or provide the basis for waiving,
the ARARs identified for the action. For the Tansitor Site, EPA
considers it technically impracticable from an engineering
perspective to clean up the contaminated shallow groundwater
within the TI Zone (defined above) to MCLs and non-zero MCLGs.
40
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EPA is therefore waiving these ARARs4, for the following
reasons.
First, the overburden soils in the area of the contaminated
plumes have low hydraulic conductivity, ranging from 0.0096
feet/day to 0.3 feet/day, and the effective conductivity averages
0.084 feet/day. These soils, which consist of a mixture of clay,
silt, sand, and gravel, can yield only limited volumes of water.
Therefore, pumping the VOC-contaminated water from the overburden
soils would be done at an extremely slow rate.
Second, the concentrations of certain dissolved contaminants in
the groundwater are extremely high. For example, the average
concentration of 1,1,1-TCA detected in the Disposal Area plume is
estimated to be 88,000 ppb, more than 40 times its MCL of 200
ppb. This concentration is approximately ten percent of the
water solubility value for 1,1,1-TCA, suggesting that separate
phase, (DNAPL) 1,1,1-TCA may be present in the subsurface.
Third, 1,1,1-TCA and 1,1-DCE, which are the most frequently
detected contaminants at the Site, tend to adhere to soil
particles. As a result, these contaminants move slowly through
groundwater and are difficult to extract.
Fourth, computer modeling indicated that an extended period of
time would be required to achieve drinking water standards
through either natural attenuation or extraction and treatment of
the groundwater. This modeling took into account the low
permeability of the overburden soils, the high concentrations of
dissolved contaminants, and the difficulty of extracting the most
common contaminants detected at the Site, 1,1,1-TCA and 1,1-DCE.
The range of time required to meet drinking water standards by
extraction and treatment was from 160 years to more than 630
years. Within this range, EPA considers a timeframe of 300 years
to be the most likely based on assumptions used in the model.
The range of time required to meet drinking water standards by
natural attenuation was from 220 years to more than 1,150 years.
Within this range, EPA considers a timeframe of 420 years to be
the most likely based on assumptions used in the model.
Computer modeling was also used to evaluate whether short term
pumping would significantly decrease the volume and shorten the
time to achieve drinking water standards through natural
attenuation. EPA concluded that even after 50 years of pumping,
4Section 264.94 of RCRA contains a list of metals and
organic compounds for which maximum concentrations for
groundwater protection have been established. These maximum
concentrations, often referred to as RCRA MCLs, are ARARs and are
waived along with the Safe Drinking Water Act MCLs and non-zero
MCLGs.
41
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it would still take approximately 300 more years for natural
attenuation to restore groundwater to drinking water standards.
These estimated cleanup timeframes are based on an assumption
that there are no DNAPLs at the Site. In the event that DNAPLs
are present, the length of time needed for cleanup would be even
longer.
In addition to evaluating extraction and treatment, EPA has
identified no other technologies that could attain MCLs and non-
zero MCLGs within the TI Zone at the Site within a reasonable
timeframe.
For all of the above reasons, EPA has determined that it is
technically impracticable from an engineering perspective to
attain MCLs and non-zero MCLGs within the TI Zone at the Tansitor
Site.
2. The Selected Remedy Attains All Other ARARs
This remedy will meet or attain all applicable or relevant and
appropriate federal and state requirements that apply to the
Site, with the exception of the MCLs and non-zero MCLGs which are
waived above. A detailed listing of environmental laws from
which ARARs for the selected remedial action are derived, and the
specific ARARs for this remedial action can be found in Appendix
B of this ROD. These tables give a brief synopsis of the ARARs
and an explanation of the actions necessary to meet the ARARs.
These tables also indicate whether the ARARs are applicable or
relevant and appropriate to selected remedy at the Site (as well
as to the two other alternatives considered in the FS). In
addition to ARARs, the tables describe standards that are To-Be-
Considered (TBC) with respect to the selected remedy (and the two
other alternatives considered in the FS).
Environmental laws from which the ARARs for the selected remedial
action are derived, and the specific ARARs include:
Chemical-Specific
_ Vermont Groundwater Protection Act - 10 VSA Chapter 48.
Applicable
_ Vermont Groundwater Protection Rule and Strategy - 10 VSA
Chapter 48, EPR Chapter 12. Applicable
_ Federal Safe Drinking Water Act (SDWA) Maximum Contaminant
Levels (MCLs) - 40 CFR Part 141. Relevant and Appropriate, but
grounds for waiver in the TI zone are present
. SDWA Maximum Contaminant Level Goals (MCLGs) - 40 CFR 141.50-
141.62. Non-zero MCLGs are relevant and appropriate, but grounds
for waiver in the TI zone are present
. Resource Conservation and Recovery Act (RCRA) Groundwater
Protection Standard - 40 CFR 264.94. Relevant and Appropriate,
42
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but grounds for waiver in the TI zone are present
Location-Specific
_ Vermont Wetlands Protection Law (10 VSA Chapter 37) and the
Vermont Wetland Rules. Applicable
. Federal Clean Water Act (CWA) (33 USC 1344) 40 CFR 230, 404.
Applicable
_ Executive Order 11990, Protection of Wetlands - 40 CFR 6,
Appendix A. Applicable
. Fish and Wildlife Coordination Act (16 USC 661). Applicable
- Endangered Species Act of 1973 (16 USC 531) 50 CFR 200 and 50
CFR part 402. Applicable
_ Groundwater Vermont Groundwater Protection Rule and Strategy -
10 VSA Chapter 48, EPR Chapter 12. Applicable
. RCRA Groundwater Protection Standard - 40 CFR 264.94. Relevant
and Appropriate
Action-Specific
. Department of Transportation (DOT) 49 CFR 107, 171.1-171.5.
Applicable
. RCRA Subtitle C, 40 CFR 260. Relevant and Appropriate
_ Subpart B - General Facility Standards for Owners and
Operators of Permitted Hazardous Waste Facilities 40 CFR
264.10 - 264.18. Relevant and Appropriate
. Subpart C - Preparedness and Prevention 40 CFR 264.30 -
264.37. Relevant and Appropriate
_ Subpart D - Contingency Plan and Emergency Procedures 40
CFR 264.50 - 264.56. Relevant and Appropriate
. Subpart E - Manifesting, Record-keeping and Reporting 40
CFR 264.70 - 264.77. Relevant and Appropriate
. Subpart F - Groundwater Protection 40 CFR 264.90 - 264-
101. Relevant and Appropriate
. Subpart G - Closure and Post-Closure 40 CFR 264.110 -
264.120. Relevant and Appropriate
_ Vermont Hazardous Waste Management Act - 10 VSA Chapter 159,
EPR Chapter 7. Applicable
To Be Considered
. EPA Groundwater Protection Strategy. TBC
. US EPA Reference Doses (RfDs). TBC
_ EPA Carcinogen Assessment Group Potency Factors. TBC
_ EPA Health Advisories and Acceptable Intake Health Assessment
Documents. TBC
A brief narrative summary of certain ARARs follows.
First, while MCLs and non-zero MCLGs are ARARs, EPA has provided
the basis for waiving attainments of these ARARs in the TI Zone
as stated above. EPA will, however, require that MCLs and non-
43
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zero MCLGs continue to be attained as ARARs for groundwater
outside the TI Zone, both horizontally and vertically.
Groundwater monitoring will be performed to assure that these
ARARs are maintained over time. With respect to state drinking
water standards, the Vermont Groundwater Protection Act is an
ARAR. In response to contamination present at the Site, on
November 23, 1993, Vermont ANR classified the contaminated
groundwater plumes at the Site as Class IV groundwater, which is
not acceptable for drinking but acceptable for commercial and
industrial uses. The substantive requirements provided in
Vermont ANR's Reclassification Order are ARARs and must be
followed. Adjacent to the plumes, groundwater is classified as
Class III, or suitable for drinking water. Monitoring will
detect any migration of contaminants away from the Class IV area,
and assure that state drinking water standards in the Class III
area are maintained.
In establishing a groundwater monitoring program, and performing
future investigations and response actions (if necessary),
wetland protection considerations will be incorporated in design
and implementation, in compliance with such ARARs concerning
wetlands as the Executive Order 11990, Protection of Wetlands,
and the Vermont Wetlands Protection Law.
Finally, the design and implementation of the groundwater
monitoring program will comply with relevant and appropriate RCRA
requirements concerning groundwater monitoring.
For a review of the other ARARs selected for the Site, see
Appendix B of this ROD.
C. The Selected Remedial Action is Cost-Effective
In the Agency's judgment, the selected remedy is cost effective,
i.e., the remedy affords overall effectiveness proportional to
its costs. In selecting this remedy, once EPA identified
alternatives that were protective of human health and the
environment and that attain, or, as appropriate, waive ARARs, EPA
evaluated the overall effectiveness of each alternative by
assessing the relevant three criteria: long-term effectiveness
and permanence; reduction in toxicity, mobility, and volume
through treatment; and short term effectiveness. The costs of
this remedial alternative are:
Estimated Capital Cost: $18,000
Estimated Annual 0 & M (present worth): $30,600
Estimated Total Cost (net present worth): $390,000
For comparison, the estimated total costs for MM-3 (Extraction
and Treatment, with Institutional Controls) were between
$1,480,000 and $3,320,000. EPA, however, does not consider MM-3
to be cost-effective because extraction and treatment would not
44
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result in attainment of drinking water standards within a
reasonable timeframe. Under current site conditions, extraction
and treatment is also unnecessary to achieve containment of the
groundwater plumes. Instead, MM-3 would be effective due almost
entirely to the implementation of institutional controls. The
only other alternative considered, MM-1 (No Action), was
estimated to cost $3,000, for the cost of performance of five-
year reviews at the Site. MM-1, which does not include any
groundwater monitoring, however, was not considered protective.
Thus, in comparison with the other alternatives, EPA has
determined that MM-2 is cost-effective and represents reasonable
value for the money.
D. The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery Technologies to
the Maximum Extent Practicable
Once the Agency has identified those alternatives that attain or,
as appropriate, waive ARARs and that are protective of human
health and the environment, EPA identifies which alternative
utilizes permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable. This determination is to be made by deciding
which one of the identified alternatives provides the best
balance of trade-offs among alternatives in terms of: 1) long-
term effectiveness and permanence; 2) reduction of toxicity,
mobility or volume through treatment; 3) short-term
effectiveness; 4) implementability; and 5) cost. The balancing
test emphasized long-term effectiveness and permanence and the
reduction of toxicity, mobility and volume through treatment; and
considered the preference for treatment as a principal element,
the bias against off-site land disposal of untreated waste, and
community and state acceptance. The selected remedy provides the
best balance of trade-offs among the alternatives.
In addition, where groundwater ARARs are waived at a Superfund
site due to technical impracticability, EPA's general
expectations are to prevent further migration of the contaminated
groundwater plume, prevent exposure to the contaminated
groundwater, and evaluate further risk reduction measures as
appropriate. Given these considerations, EPA's selected remedy
for Tansitor also provides the most appropriate remedial strategy
for the Site.
With respect to long-term effectiveness and permanence, EPA
believes that institutional controls will be effective because
the area to be controlled is relatively small and compliance
therefore can be easily monitored. Long-term monitoring will
also effectively detect migration of contaminants beyond their
current extent. The effectiveness of Alternative MM-3 would be
due almost entirely to the implementation of institutional
controls, because even if extraction and treatment were
45
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performed, contamination well above drinking water standards
would still remain in the groundwater for several centuries.
Alternative MM-1 would not provide long-term effectiveness or
permanence as no further action would be taken to reduce risk.
None of the alternatives would significantly reduce the toxicity,
mobility, or volume of contaminants through treatment, as
drinking water standards are not expected to be attained for any
of the alternatives considered for several centuries. Nor were
there significant differences among the alternatives with respect
to short-term risks to workers or the community due to
implementation of the action. With respect to implementability,
Alternative MM-2 was determined to be easy to implement because
the limited area to be controlled is currently owned by one owner
and because VT ANR's reclassification supports to the goal of
preventing use of the groundwater. Alternative MM-3, however,
was not considered to be implementable. Due to the low
permeability of the soils, pumping would be extremely slow and
drinking water standards would not be attained. With respect to
cost, EPA considers MM-2 to be the only cost-effective
alternative, as described above. In addition, both VT ANR and
the community are supportive of the selected alternative.
In selecting Alternative MM-2 as the remedial action, EPA
determined that there was no need to actively contain the
groundwater contamination at the Site. Due to the geology and
hydrology of the Site, groundwater contamination present in the
shallow overburden is not migrating either vertically or
horizontally. Thus, the selected alternative achieves EPA's
general expectation of preventing further migration of the
contaminated groundwater plume where drinking water standards
cannot be attained.
The selected remedy also meets the general expectation of
preventing exposure. This is accomplished through the use of
institutional controls. It does not meet the final general
expectation of further risk reduction; MM-3 would meet this
expectation by lowering the concentrations within the plumes but
again would not approach MCLs for several centuries.
For the above reasons, and given the circumstances present at
this Site, EPA has determined that the selected remedy utilizes
permanent solutions and alternative treatment or resource
recovery technologies to the maximum extent practicable.
E. The Selected Remedy Does Not Satisfy the Preference for
Treatment as a Principal Element
The selected remedy does not actively remove or treat the
contamination at the Site, and so does not result in any
reduction of toxicity, mobility, or volume other than that
achieved through natural attenuation.
46
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EPA has determined that it is technically impracticable from an
engineering perspective to restore the groundwater at the Site to
drinking water standards within a reasonable timeframe. Based on
the hydrogeology of the Site and the high levels of dissolved
contaminants, EPA does not anticipate that reductions in
toxicity, mobility or volume achieved through groundwater
extraction and treatment would significantly reduce the hazards
posed at the Site. Extraction and treatment of contaminated
groundwater are not expected to achieve drinking water standards
for several centuries. Additionally, because groundwater is not
migrating horizontally or vertically, active containment was not
considered necessary at this Site. Given that drinking water
standards cannot be attained and that active containment measures
are unnecessary, EPA has not selected a remedy that satisfies the
statutory preference for remedies which, as a principal element,
employ treatment which permanently and significantly reduces the
toxicity, mobility or volume of contaminants. To ensure
protection of human health and the environment, exposure to
contaminated groundwater will be prohibited through institutional
controls, groundwater monitoring will be performed, and
contingencies for further investigation and action are
established in the event that contaminant migration occurs in the
future.
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA presented a proposed plan (preferred alternative) for
remediation of the Site on March 8, 1995. In the proposed plan,
no source control actions were proposed as no unacceptable risks
were associated with the surface or subsurface soils. The
management of migration portion of the preferred alternative as
described in the proposed plan included:
implementation of institutional controls to prevent the
use of contaminated groundwater at the Site as a drinking
water source;
long-term monitoring of site groundwater on a regular
basis to evaluate changes in site conditions over time; and
establishment of contingencies for future evaluation and,
if necessary, additional action, should the long-term
monitoring reveal that contaminants have migrated beyond
their current vertical or horizontal extent; and
a review of the Site every five years.
Based on hydrogeologic conditions and the levels and types of
contaminants present at the Site, EPA also presented a proposed
determination in the proposed plan that it would be technically
impracticable from an engineering perspective to achieve Federal
drinking water standards at this Site within a reasonable
47
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timeframe.
The remedy selected contains no significant changes from that
proposed during the public comment period. The selected remedial
action as set forth in this ROD provides a more detailed
description of the deed restriction requirements, the long-term
monitoring, and the contingencies for future action that will be
required, but does not significantly alter the preferred
alternative as described in the proposed plan.
XIII. STATE ROLE
The Vermont Agency of Natural Resources has reviewed the various
alternatives and has indicated its support for the selected
remedy. The State has also reviewed the Remedial Investigation,
Risk Assessment, Feasibility Study, and Technical
Impracticability Evaluation Report to determine if the selected
remedy is in compliance with applicable or relevant and
appropriate State Environmental laws and regulations. The State
of Vermont concurs with the selected remedy for the Tansitor
Electronics, Inc. Superfund Site. A copy of the declaration of
concurrence is attached as Appendix A.
48
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RECORD OF DECISION SUMMARY
TANSITOR ELECTRONICS, INC.
TABLES
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TABLE 1: SUMMARY OF CONTAMINANTS
OF CONCERN IN OVERBURDEN GROUNDWATER
Contaminants
of Concern
Average
Concentration1
(ug/1)
Maximum
Concentration
(ug/1)
Frequency of
Detection
Chloroethane
1, 1-Dichloroethane
1, l-Dichloroethene
Tetrachloroethylene
1,1, 1-Trichloroethane
Vinyl Chloride
Arsenic
Barium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Nickel
Silver
Zinc
12.78
8.84
6.50
5.96
18.26
10.51
2.91
50.81
5.45
21.5
18.16
987.2
2.62
866.1
0.0729
24.96
2.91
39.72
36
940
3800
31
470,000
4
7.3
462
13.2
92.5
1400
10, 900
174
11,500
.25
87.2
186
4,890
3/37
9/37
10/37
2/37
10/37
3/37
1/8
6/8
1/8
2/8
10/25
7/8
25/34
8/8
8/25
2/8
2/25
15/25
1 The average concentration for the Risk Assessment is a
geometric mean of the data from all of the onsite monitoring
wells. The average concentration for the Technical
Impracticability modeling is an arithmetic mean of the data from
the monitoring wells within the contaminant plumes.
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TABLE 2; SUMMARY OF CONTAMINANTS
OF CONCERN IN DISPOSAL AREA SURFACE SOILS (0-2 ft.)
Ton t* flim 1 n WP **- f
of Concern
Chloroform
1 , 1 -Dichloroethane
1, 1-Dichloroethene
Methylene Chloride
Tetrachloroethylene
1,1, 1-Trichloroethane
Trichloroethene
Bis (2-ethylhexyl)
phthalate
Arsenic
Cadmium
Chromium
Cyanide
Nickel
Silver
Average
Concentration
(ua/1)
2.711
3.11
3.568
3.509
4.001
21.6
3.487
403.9
12,120
1,778
15,330
892.7
32,970
4,032
Maximum
Concentration
(ua/1)
2
4
12
9
18
1300
15
700
14,900
2,400
18,800
23,500
41,600
60,800
Frequency
of Detection
2/8
1/8
2/8
1/8
3/8
5/8
2/8
1/8
8/8
8/8
8/8
2/6
8/8
5/8
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OF CONCERN IN DISPOSAL AREA SURFACE /SUBSURFACE SOILS (0-8 ft.)
Contaminants
of Concern
Acetone
2-Butanone
Chloroform
1, 1-Dichloroethene
1 , 2 -Dichloroethane
1, 1-Dichloroethene
N, N-Dimethylf ormamide
Ethanol
Methylene Chloride
Tetrachloroethylene
1,1, 1-Trichloroethane
1,1, 2 -Trichloroethane
Trichloroethene
Bis (2-ethylhexyl)
phthalate
Arsenic
Cadmium
Chromium
Cyanide
Nickel
Silver
Average
Concentration
(ug/1)
10.78
6.598
3.366
5.707
3.72
6.284
141.3
24
5.606
4.527
39.23
3.917
4.25
411.3
11,100
1,787
15,330
726.4
30,610
3,817
Maximum
Concentration
(uq/1)
1060
12
23
530
27
5.0
71,000
24
180
18
16,000
37
41
700
210,000
2,650
19,650
23,500
41,600
60,800
Frequency
of Detection
3/16
1/16
4/16
4/16
1/16
5/16
2/16
1/1
3/16
5/16
11/16
2/1
4/16
1/16
16/16
16/16
16/16
4/13
16/16
11/16
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TABLE
4: SUMMARY OF
CONTAMINANTS
OF CONCERN IN SURFACE SOILS OUTSIDE DISPOSAL AREA
Contaminants
of Concern
Acenapthene
Anthracene
Benzo (a) Anthracene
Benzo (a) Pyrene
Benzo (b) Fluoranthene
Benzo (g,h, i) Perylene
Benzo (k) Fluoranthene
Chrysene
Dibenz (a, h) anthracene
Dibenzofuran
Fluoranthene
Fluorene
Indeno (1,2, 3-cd)pyrene
2 -Methylnaphthalene
Naphthalene
4-Nitrophenol
Phenanthrene
Pyrene
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cyanide
Manganese
Nickel
Silver
Average
Concentration
(ua/1)
425
463
484
499
511
469
375
493
404
413
622
452
394
370.89
356
2030
570
591
6546
51158
344
1601
12167
1000
7.90 X 105
28910
1474
Maximum
Concentration
(ua/1)
870
1,700
4,400
3,100
5,400
1,900
1,200
4600
570
690
11000
1400
1700
290
210
3700
11000
10000
12900
194000
670
3200
20700
1000
t
4.40 X 106
224000
51800
(0-2 ft.)
Frequency
of Detection
1/8
1/8
2/8
1/8
2/8
1/8
2/8
2/8
1/8
1/8
3/8
1/8
2/8
1/8
1/8
1/8
3/8
3/8
8/8
8/8
1/8
8/8
8/8
1/1
8/8
8/8
2/8
-------
Contaminants
of Concern
Acetone
1,1,1-Trichl
Xylene (Total)
Acenapthene
Anthracene
Benzo(a)Anthracene
Benzo(a)Pyrene
Benzo(b)Fluor
Benzo(g,h,i)P
Benzo(k)Fluor
Chrysene
Dibenz(a,h)an
Dibenzofuran
Fluoranthene
Fluorene
Indenod, 2,3-
2-Methylnapht
Naphthalene
4-Nitrophenol
Phenanthrene
Pyrene
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cyanide
Lead
Mercury
Nickel
Silver
OF CONCERN IN SURFACE /SUBSURFACE SOILS
OUTSIDE DISPOSAL AREA (0-17 ft.)
Average
Concentration
(ug/1)
14
roethane 8 . 1
1 4.7
394
407
acene 414
5 419
anthene 423
2rylene 409
mthene 376
417
ihracene 386
390
456
403
:d)pyrene 383
lalene 373
369
1894
441
447
8997
54759
369
1876
14546
371
20899
43
10150
930
Maximum
Concentration
(ug/1)
1600
29000
9
870
1700
4400
3100
5400
1900
1200
4600
570
690
11000
1400
1700
290
210
3700
11000
10000
27900
194000
1400
8700
27700
1000
119100
160
224000
51800
Frequency
of Detection
2/23
1/23
1/23
1/21
1/21
2/21
1/21
1/21
2/21
2/21
1/21
1/21
3/21
1/21
2/21
1/20
1/21
1/20
3/21
3/21
13/13
15/15
2/15
18/19
15/15
1/12
19/19
5/19
14/14
3/19
-------
Contaminants
of Concern
Chloroethane
1,1-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethene
N,N-Dimethylforma
tetrachloroethene
1,1,1-Trichloro
Trichloroethene
Trichlorotriflu
Manganese
Mercury
Silver
Zinc
OF CONCERN IN STREAM
SURFACE WATER
INTERMITTENT AND PERENNIAL STREAMS
Average
Concentration
(ucr/1)
7.29
me 6 . 97
sne 3 . 84
sne 3 . 77
namide 39.55
le 3.1
sthane 15.19
2.62
sroethane 2.236
730.6
0.0833
2.92
11.93
Maximum
Concentration
(ua/1)
30
91
48
56
620
33
800
9
2
967
.33
70.2
53.5
Frequency
of Detection
2/8
4/8
2/8
2/8
1/7
2/8
5/8
2/8
1/2
2/2
1/7
2/13
7/12
-------
TABLE 7; SUMMARY OF CONTAMINANTS
OF CONCERN IN FIRE POND SURFACE WATER
Average Maximum
Contaminants Concentration Concentration Frequency
of Concern (uq/1) (ug/1) of Detection
1,1-Dichloroethane 1.581 1 1/2
Manganese 19.67 25.8 1/2
Mercury .35 1.10 3/4
-------
TABLE 8; SUMMARY OF CONTAMINANTS
[N
Contaminants
of Concern
Chloroethane
Chloroform
1,1-Dichloroethane
Methylene Chloride
Toluene
1,1,1-Trichloroethane
Acenaphthene
Anthracene
Benzo(a)Anthracene
Benzo(a)Pyrene
Benzo(b)Fluoranthene
Benzo(g,h,i)Perylene
Benzo(k)Fluoranthene
Bis(2-ethylhexyl)-
phthalate
Chrysene
Dibenz(a,h)anthracene
Dibenzofuran
Fluoranthene
Fluorene
Indeno(l,2,3-c
Naphthalene
Phenanthrene
Pyrene
Arsenic
Barium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Vanadium
Zinc
OF CONCERN IN STREAM SEDIMENTS
[ INTER
me
.de
! thane
me
.hene
rlene
hene
)-
acene
pyrene
MITTENT AND PE
Average
Concentration
(ua/1)
14.24
4.677
5.527
12.1
4.973
5.111
611.6
560.9
690.7
662.8
744.7
660.3
646.3
495.1
758.9
499.7
502.8
1053
427.1
678.2
569.9
800
955.9
7361
80410
1731
14200
18450
49040
27720
2295000
114.2
24170
4666
12658
13790
131719
DDIPXTTRT OTmS'&MO
lCK.JSJIJ.Ali PlKiSAMo
Maximum
Concentration
(UQ/1)
130
17
22
130
8
10
810
680
1600
1300
2200
850
1100
660
1700
390
250
3700
470
910
530
3100
2700
8600
150000
3700
22400
22400
200000
46500
3420000
1500
37200
6500
2560000
28800
360000
Frequency
of Detection
1/6
4/6
2/6
2/6
2/6
2/6
1/6
2/6
3/6
3/6
3/6
2/6
3/6
2/6
3/6
2/6
1/6
3/6
2/6
2/6
1/6
3/6
3/6
2/2
2/2
5/6
2/2
2/2
6/6
6/6
2/2
4/6
2/2
1/2
7/11
1/2
11/11
-------
Contaminants
of Concern
Arsenic
Barium
Cadmium
Chromium
Cobalt
Manganese
Nickel
Vanadium
OF CONCERN IN FIRE POND SEDIMENTS
Average
Concentration
(UQ/1)
6650
147000
2450
20100
16500
1300000
30450
21550
Maximum
Concentration
(ua/1)
6650
147000
2450
20100
16500
1300000
30450
21550
Frequency
of Detection
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
-------
TAIU.I-
siTi-
P.NV. MI-DIIIM
I-XI'OSUKETYI'E
RISK TYPE
10
TANS II OK l:.l.I:CI HONK'S
<;KOUNl>WATI-K/OVI:.KHUm>l N
INGES1 ION/1-U'l UKIi/KLSIDI-N I
CARCINOGENIC
Contaminant of
'Joncern
1.1.1 mii-iii.uKDi-iiiANi-:
I.I nUIII.OKOITIIANI-
i.i IHCIII.OROI:HII:NI-
CIIIOKDI IIIANI:
M IKAHII.OKOI IMI:NI:
VINYI.CMI.OKIDI-
AKSINK'JASI
UAKII'MlllA)
i'HKOMtliM ll'Kl
IKON (1 II
UAlMI'lll
MANliANI-M-CMN)
MIKIURY (Illil
NICKI-I.(NI)
MI.VI-K «Aoi-:.o2
2()ll- 01
^ *>7|:.(i>
Maximum
Concentration
(111)1(1)
I7oi:,o2
') 101- 01
VXIII ill)
l.WH- 02
U0| 02
I KOI: in
/ mi o<
M.2I III
1 ^21- ll '
i O*M- tot
1.7 1C 01
I.ISI «li|
2 Sill ol
X.72I--02
I.XMvlll
-I.WI-.I.I
Exposure
1' actor (a)
Illkft/tuiv)
i /i: 02
1/1:02
I/C02
171-02
I/C02
171-02
I/I- 02
I/I 02
I/I 02
I/C 02
I7C02
I7i:02
,i7i: 02
1/1:02
171 02
171:02
A verage
Invested
Dose (b)
(in^tk^lilii\')
2 1 II 01
I nil in
7.MI-: os
i.soi: in
7 IIO|: OS
1 21): Ol
1 I2C OS
S«l/|- 01
6.-IDI- OS
I.IM-: 02
VSiCllS
I02IMI2
X 221- 07
2.'ni:. oi
TI2IMIS
4M,V,M
Maximum
Ingested
Dose
(ni)>/kxlco» -ii-:-«7 n IK.
S.20C-02 -llvlki 21- OS
1 VIII » 00 21-01 '<| OS
1 /SClOO f.COS || 01
IOIAI.KISK M ol M -112
h
Ni'lr: '
«l»k« |MWNlr«l M lhl«l«Hr l*ut l« (MMlrr*IK c*«»|»i«n
-------
TAHI.I-
SITE
ENV. MEDIUM
EXPOSURE TYPE
RISK TYPE
II
TANSITOR ELECTRONICS
GROUND WATER/OVERBURDEN
INGESTION/FUTURE/RESIIJENT
NONCAKCINOCJENIC
Average Maximum
Contaminant of A verage Maximum l^xptisure Ingested Invested
'.'oncern Concentration Concentration I- actor (a) Dose (h) Dose
I.I.I TRICIII.OKOI-IIIANI-:
I.I DICIII.dKOIVIIIANI-:
i.i-Diciii.oRoi-'nii-Ni-:
C|||.OKOI;TIIANI;
rr.'iR ACI ii .OKOI-: ri II-:NI-
VINYI.CIII.ORIDI;
AKSi:NIC(ASl
ItAKIUM (ItAI
CHROMIUM (CIO
IRON (II-)
I.I-AIXIMI)
MANCANI-Si; (MM)
MP.RfURYlIKi)
NICKI-I.(NI)
SII.VI-K (All)
/INCI/.N)
1 X1|-:<>2
K.H-II: 7i;o2
l.70|-:«02 2 7 II-: (12 V(MI|:.OI I.2')l:i0l
Mill- »l 2. Ml-: 112 2.l2i:oi 2 1XI: (12
1.XIII-HIO 2.711: 02 I.7XIMM I Oil: 01
1. Mil- 02 2. 7 II-' 02 I.SOIMll ')Kr.l (II
1.|OI-:02 2.711-02 . I.MCOI X I'll ill
I.OOI: IK J/ II 112 2. XXI- 01 Mill' III
7.»oi-:in 2.7-n-:o2 7.'>7i-:-os 2001:01
I.62I-: 01 2. 7 II-' 02 l.l'M-IH 12 /I-' 02
I.»2I:. 02 2.711-02 l.l')|:ill V(,2I OI
I.IH)|-:»(|| 2 /-IT. 02 2.7OI--02 2WI-OI
1.7 ii- oi 2.7ii: 02 x.22i-:os i//i:in
1 I5IUOI 2.7-II--02 2 17I; (12 1.IM:(I|
2.50l-:oi 2.7IIMI2 l.'>2lvOf» A.XSI- 116
X.721-02 2.7 II-: 02 r.XIIMll 2 WI-: IU
i.xf>r:oi 2. MI-: 02 7,'j7i-:o5 s.ioi-:in
I.X')I:.»IXI 2.7.||;.-02 MWIvin I-VII-OI
A venire Maximum
Chronic Chronic Chronic
Protective lluiard Hazard
Itody Dose Quotient Quotient
(mi'lkgld'aj)
'MMH--02 61- in Il-i02
iooi-:oi 21: in M-OI
i:o2
5.00i:(n -1.7.51-1 IXI A.Mtl-NOI
roOIMM A.V;|-:(H 2.2XI:.02
2.OOIM12 1.-I2I--O2 I.I'JIMU
5.001-01 1.591-02 I.02I-i< t<4.iiilr .Mp.inti «.4it|»>iiii i« iv«i HHl>l
-------
TABLE 12. SUMMARY OF CARCINOGENIC RISKS
TANSITOR ELECTRONICS, INC. SITE
Scenario
Receptor Present/ Total Risk
Future Average Max
Groundwater - Overburden1
Ingestion Resident
3xlO'4
3xlO'2
Surface Soils (Outside Disposal Area)
Ingestion Trespasser P
IxlO"6
5x10
-6
Surface Soils (Disposal Area)
Ingestion Trespasser
6xlO"7
8x10
-7
Surface/Subsurface Soils (Outside Disposal Area)
Ingestion Resident F 3xlO'5
IxlO'4
Surface/Subsurface Soils (Disposal Area)
Ingestion Resident F
IxlO'5
3xlO'5
Stream Sediments
Ingestion
Fire Pond Sediments
Ingestion
Fire Pond Surface Water
Ingestion
Dermal Contact
Trespasser
Resident
Trespasser
Resident
Trespasser
Resident
Trespasser
Resident
P
F
P
F
P
F
P
F
IxlO'6
3xlO'5
IxlO'7
IxlO"6
NC2
NC
NC
NC
3xlO'6
6xlO'5
IxlO'7
IxlO'6
NC
NC
NC
NC
1The risks presented in this table may be underestimated by
approximately one-half because the contribution of volatile
organic compounds via the inhalation pathway is not included in
this quantitative risk assessment.
2 NC = not calculated, no carginogenic COCs
-------
walci (icitfi.it Ki'MMMiM.1 At'tiitiiN MeiiH'ifial !*> I
T.-ihlo 13
IMIIIAI '.( l.'l I NINOlll IIIMI IHAI I LI IUII II ( M ill S A KM I'll! II I SMI|-|I(INS
M. ,,!!. Ill I.I Ml,',,.!,
I'llll CVS I Illtllllls
|N,. A. in.i
lliivliliihnii.il I'liiiiiiiK
d,Hi tu,HI
I fCJHIIVMt
iMiniiliiiiiig
i-ll(ii)
P.R Situ lliiili>git:il TIC:I|IIN:II|
11 icilt l
I-K Xiln I'liysKalH "ln-iimal I ii-alinritl |
An Slii|i|tjii|;
In Siln
IVnitc.il.le Mt.Hlton W.il!
IhLltlClillllMI
SMc Misili.ti
IIM II.IIJT In lin- I'OIK
No...
~i
J |t Himiitlw.iiet MmnliMin^ j
Krijmitil IIM iiiiisi.l, t.iti..iil.y tl< I'
K> -.11 n Is IIM n| \\.ihi in icil.itn uttltiNhi.il am) rult-iili.il ly a|i|>ln .1)1)1:
.1,:.iiiilnn.il uses
IVriU I.-i |>M'|»-ily in .iM.isnl inllnt me MM lii.lc I'nieitli.illy anptu .idle
ii-'.hlt lnnis tin writs ami ns.i|;r iif I'.MHiinlwafef
itti^iMiij; MMiHiliiiiii|; ul wvlls I'tilL'iilially a|>|ilicalilc
Si in \ til WL-MS in t;ih.u l t;i mi m l>*.He i 1'iiicnlially a|i|)ll(.ulilc. (lumping talcs w»
lintiicil ilnc lu Inw |»ciincjlnhly nf \int
IVidiKiicil |H|H.- MI MI-IK lies ttatklilltti wild May tuil (K: lejsilile in eciiain arcus
iHiinuv iiK-ilta in t til Ice? wuicr
Nlll (caMltlc, tlllllMMJICtl LIIMt|MIIIMlU ItOl
litoilcgiadalilc uiiiln uciiiliic LomliiiDiis
NiM fcasilitc. |Milciilijlly KIKIC I>MM|< |;t Jil.ilnm liy
iniLMMir|;:iiit\tn\ in jn aciuliii. CHVUDIIIMCH
I K'gi.nlalimi o| tniisliliienls iisuiy
inn tiiIIHII til iniisiHm-nls unlit |;I.HIM|.M riilriiH.illy ;i|i|»hi;»lilL, |iiuvcii Uilmnlugy
at livatfil cattmn
ti.iMsIri nl ilisMilvol i inishhu nls In ;HI. I'lilrnlully .i|i|iluaide. |if>
I'nl^htl.tlly j|i|ilu .idle. Inyli t;i|nijl toil
|iioniiitc ac i nl HC Lnnililnnis aiul
liiniL'iiK-iliaMiin nl mnsiiiueiiiN
iliniii|',ti K'.iitivc wall
I lii'tinal nMil.itiiHi. ollrit cnlianii'il unli
AiKiii|iiniM nl iiinvtiltifnls iinln gi.inulji
activated lailtnn
Mn in .itinrnl. iii"iin|- itnly rnlenti.iU)r ii|-|'ln .Jilc
I IIM li.ii|;t in i-«flni|: Int. |K mil via MH).I« r ni Cult nli.ill) .i|i|ilii.ilile. MIIIM II|>I.HII Nl'I'ltS
snliMiil.it r |>t|Mii(- M.iinl.iuK. IIM nf |niin| vv.itri InniUtt In
tin li|:liiini: ,
-------
lAltll 1/|
I ANSI I OK I I ASIIIII II V SIIIIIY
MIMMAUV 01 ANALYSIS - MANAIil Ml Nl Ol Mlt.ltA I ION AMI UNA MM S
Atsessmenl Foclot
AMenuMtve MM I
No Action
Alternative MM 2
Inslilutionnl Conliols
Allrin.ilivc MM-}
(iiotindwiitcr I!«liacli«n/Trealnienl/I)iscliar|!i: In
Sin I an: Wulcr anil litslilMlioiial
Major Components
No major components; Vycar reviews
I liislilnliiiital ciinliols mi|IH|III|> Deed Kcsliicliiiiis
2 I onp IciMI < iiitiiiulwiilct M«»niliiiin|; l'[i»(!i;un
1 ^ yc:ii Kcvicw\
l conliiils mini griiiHiilw:Mt;r clc;niii|i l
2 Invljll.iliiMi n| (iiiHimlwuIci I'lliiKliiHi Well-. :inil
piping
V Mirlals I'lcliculiiicnl
<\ Slnil|!c Itcwiilcnnp/Olf Nile Disptisnl
S I icaliiii'Ml i>l (iiimnilwalcr In Kcmnvc VCK's
(> Disch.iigc of Ticalol (iroinitlwalei lo llic I'lic I'oiiil
7 I unc li'iin MiiniliHiHi;
M ^ VIMI kcvirws
Ovi-i.ill I'liHiilion ul Human llciillli
anil ilk: linviioninviil
Nil icifiulinii in nsk
CiiiMimlwiilcr tiinlaiiiMig clcvalcil fiiniciiiijliiins ul
clihuinalril snlvi-nts may IN: ingcvk-il liillnwiii|;
polcnlul luluic msluthiliim of supply wells in
ovciburik'n Mills on tile (none ciiiu-nlly ciiisl)
MCl.s expected In lie aclticvril iliiou|!li nalitial
allciin.Mion nvri svvrial tcnlinifs
I'nilfi lion nl human licahli anil lite cnviiiiniiM'nl
Klvks a->\i»i l.rti'il wllll lli(;fslMMl ul ^liiinuKvalfr
wiinhl lie linnlril tiy li-vlni Iliilis I Ursc liskv woiilil
lie inili|!.iicil as Icpup as icslnclinns wcic cllfilivc
MCl.s fn|>cflccl In IN: ;K|IICVI:I! lliiungh naluial
aMcnn:ilinn over scvcial ccnlinies
I «ili|' Irlin iminHolini', wunlil ilfliTl tonlaiinnanl
ini^Kiliiiii lieyonil its ciiiicnl cnlcnl
I'liHfilion til human health anil I!H* eiivmmmenl
Hfilucfs itsk Ihionpli |iump ami deal
Kisks assiH'iirieil with m^eslinn ol I'liHinilvvalei wunlil IH*
limiteil by inslilulional conliiils unlil lemeili.iliun n"'1''' aie
:H hiex-eil
Hue In low yiehl of oveilmnk'n soils and lui'Ji
iiineenli;riiiHis ol dissolved ilH'imials, M( l.s not c»|ieiled
lo he achieved lluough pump and Heal loi al leasl seveial
teiilinies
-------
TAIII.I.:
(cont.)
Assessment Factor
Alternative MM-1
No Action
Allcinalivc MM 2
lll.slillllllllllll Coilliols
Alli-inalive MM I
(iioiimlwalcr lijiliaclinii/Trealiiienl/Disihait'c In
SiiiCacc Water ami Institutional Councils
Compliance wilh AKAHs/THCs
Chemical-Specific
Doesn't comply wilh Vciiiinni (nounilwaici
I'roteclion Act It) VSA Chapter 48
Doesn't comply wilh Vermont (jioumlwaiei
Hrutectiun Kule and Strategy 10 VSA Chapter -1H
lil'A Ciioiiiulwiilci riolcclinn Strategy li> l>c
considered.
Federal Sale Dunking Walci Act (SI)WA)
Maximum Contaminant Levels '111 ('IK I'ail Ml.
Does nnl incel MOI.s in a rcusonahle lime peiiiKl
SDWA Maximum Contaminant Level (ioals
(MCl.ds) - 40O:K l I'mcncy
Laclurs aie to be considcicil.
LI'A lleallli AJvismies anil Acceptable Intake
Health Assessment Documents aie to he
consitlcml.
C4ini|)lics wilh Vciniiiiil (iiiiiiiiilw.ili.i I'lolciliun Ail
III VSA Chaplin -IK
Complies wilh Vcimoiil (iioiniilwalci I'ltilccliifii
Kule ami Siialegy II) VSA Chaplci -IK
LI'A (iiiiiiinlwali'i 1'ioicfiioii Sli.ilc[:y to IK;
consnh:icil
Lcilcial Sale Dnulini; Walci Ail I.SDWAI
Maximum Com.mini.ml Levels - -III CLK Can I'll
Does mil meel MCl.s in a reasonalile lime |xjm«l
SDWA Maxiniiim Ciiiii.iiiimaiii Level (iuaK
(MCI.(is) -III CLK Ml 'ill Ml <>> Does no) nu-el
MCIX is in a leasniialile lime penoil
KCKA (HoinnliAalei I'liiletlion Slamlaiil -III CLK
2M 'M Does not meet KCKA MCLs in a leasitnaliU:
lime peiioil Salisfies mtiiiiiiinii); iriiuiicmrnis
II S LI'A Keleieiu'e Doses aie In lie i uiiNlili'ieil
lil'A Caicinogen Assessment (iionp I'niency Lacluis
aie lo lie consiilereil
lil'A lleallli Ailvisones anil Accepiadle Inlake
Health Assessmenl Documents aie In he eonsuleieil
Same as MM 2
Luculion-Sjieciric
Vermont (irounilwater I'lulcciion Kule and
Sliaicgy 10 VSA Chapter -IS. lil'K Chapter 12
Veimonl Wellanils I'loleenon Law (10 VSA
Chapter .I/) ami the Veimonl Wellanil Kules
|ieilainiiig lo lemeilial activities impacting vegclalcil
wellanils
Leileial I 'lean Walci A. I (('WAI It t I ISC I I HI 'Id
CLK 2111. -MM
liieiulive Ouli-i I Pi'MI. I'loleiliiin ol Wi ll.inds -III
CLK d, Appemlu A
Lish ami Wilillile Coonliiialion Ail (Hi DSC doll
Lmlaiigcicil Spei tes A, I,,I I'lMlll. I ISC Sill Ml
CLK 2IIO ami .SO CLK pail -III.'
Veimonl (I'liitiiulwaici I'liiletlion Kule ami Siialegy
10 VSA Chapiei -IH. lil'K Chaplei 12
Veimonl Wellanils I'loieciinii Law I Ml VSA Chaplei I/I
ami Ihe Veimnnl Wellanil Kules |u-ilunnn|! in icmcihal
aelivuii:s impaclmg vegelaleil wellanils
Leileial Clean Walei Ait (CWA) ( 11 DSC I III) -Id CLK
2 III. IIH
l.iriullvc Oi.ln I I'PMI. l'i,.l>. li.iu ill Well.miK III ( I II
d. Appenilu A
Lish anil Wil.lhle Cooi.linaliiin Act I Id IISC fidl)
Lmlanitcicil Spei ics Ai I ol I1)/1 (Id DSC S II) Ml Cl K
.'(Kl.in.l MM IK p.ui .|(IJ
Veimonl (iioiinilw.ilei rioleillon Kule anil Snatchy III
VSA fliaplei IH. I I'll I li.iplel 12
-------
AMU: 14 (cont.)
AkscsMncnl Facloi
Allcnialive MM I
No ACIUMI
Alleinalive MM 2
lifetilulional ConlioK
Aluin.iiive MM I
(iioiimlwalei L:miuelioii/rrciiliiM:iil/l>istliai|.-e lo
Suilaee Wjiei ami Inslilulional CiuHiiils
Action S|K.'cilic
None applicable
llepaillllelll III ll.llls|klllallllll (IHII | ( I1) CI K III).
171 I 171 S)
HCMIIIIIC ('iiiiM'iviilion anil Hi-ioveiy Ail (Kl'KAl
SulMille ( . -4IK IK ->(.(!
Ill (IK 2(ll. Sllll|MIIS II llMIMI^Il (i
Vciiiioul ll.i/aiiluus Waslc Maiia^cnk'itl Ail Ml
VSA I lu|th i I S't. I I'K ( li.i|Hti 7
Nalinnal I inisMiiii SlaiulanK lui lla/.iuloiiv An I'olliil.in^
(Nl SIIAIM I III CI K (.I)
Kl KA III (IK .'(,1 .Sulipail A A. All I.IIIISM,.II Slaml.n|iii| CI K 107. I /I I
I It M
I isli anil Wilillilc CiMiulllKMlon Ail (Id (IS( Mil)
KesiHine Ciinsciv.iliun ami Kccovciy Ail (KCKA) Sulmlli-
( . IIICI-K .'Ml
KM IK 2(il. Sulipails II lliiouyli (!
VniiHHH All I'lilliiliiiii Ciiiilnil Kc|!iilaliiiiis III V S A
ScilliHl SSI.cl M.| I-I'K Chaptci S
V.IMBIIII ll.i/.ililiiiis W.islt M.III.IIH ilk nl All III VSA
( li.i|rtci IV). I CK (lia|hcl /
I anil Use ami llcvclii|iiiienl Law I III VSA I'ail S. Cli.i|>K'i
ISI)
Vciiiuiiil Waler (Jualily Slaiulanls lisk-il iiiuki I lie Veiiimnl
Water I'lillullim Ciinll.il Atl (VWK'A) 10 VSA Clu|Mei
17 .in.l III CMK I IN) ami Kill
Alnental! ('iililcii'llte ill ( iiixflnilk'lllal |IM|IIS|II.I|
HyfUinsIs (A( (illl) Iliieslmlil liinil Value III V) I line
Wei|;lueil Aveia|!c (I WA) .IIH! Muni It-mi I «|>OMIIC I nun
ISM-:i.s»
CAA Si.lie lni|ileinciilaliiiii Clan I IIHSMIIII Sl.iinl.uiK -III
CI-R S2
-------
TAIHI. U (cnnt.)
Assessment factor
Alternative MM-1
No Acliun
Allcinalivc MM 2
Institutional ('uniiols
Allciiiallvc MM-3
(iiuiindwalci I'xIiaclinii/ricalmciil/Dischaigc In
Suilacc Walei nnil Insliluliunal (..'munils
LonR-lerin F-lfeclivcncss ami
Permanence
Magnitude uf Hcsiihial Kisk
Kcinaining Untreated Waste
- Treated Kesidual Waste
Adequacy ami Reliability uf
Controls
Need for VYear Review
Groumlwaler above MCl.s will icinaiii uniil
levels are icducetl through natural attenuation
Nol applicable
Not applicable
- Yes
(.iioundwalci above M('l.\ will icinain uniil l
aic reduced llunut;h nattiial allcnujliuii
Mill applicable
Degiee id icliabibly dc|icnds on the level id
cnliiiccmcriil, itiniiilmiiig cx|»cclcil In lehably deled
(iii)uiidv\alei al>ii\e MCl.s will icmiiiu unlil levels aie
leduccd lluough siithcienl poic vidiiinc Hushes, c\|n:tlcd
lo lake mine than seveial ceultiiies
Nol appbcablir
(iliitiiulwalei cxIiaclitMi and liealiuenl l^ well pinvi-u
leibmtli>f;y lul dlssidved ciiiiceulialKMis ol chcinic.ds. but
ellecliveiiess is dccicascd in low yielil suds
1'iesciice id sepal ale phase |>indiicl geueially decieases
ellecliveiiess ol lecliuiihigy unless sepaiale phase can IK;
liu aled
Yes
Reduction in Mobility. Tonicily and
Viduiih:
Trealnicnt or Recycling
Process Used/Materials
Treated
Irreversible Trealincnl. and
Quaintly uf Kcsiduuls Allct
Treaiiiieni
Degree lu which Treatment
Keduces lla/anK I'osed by
Principal Threal(s)
Groundwaler containing solvents will remain
in place, mi reduction in Ml V (iiibei than by
naluial allenualion processes)
- None
- Nol applicable
No treatment; no reduced lineal
Same as MM I
None
Nul applicable
No liealiiienl
Mobility coiiiiiilled through giiiuiidwalei CAli.iclinn.
liiKicity leduced Ihiougb abovegliiulul liealiiienl, pump and
Heal will leiluce viilume. hotvevei, luw yield limn ai|inlei
will be a limning laclui
l:xliacied gioundwalel Healed Illliiugh all slil|lpili|! uilh an
polliilniii ciiiiliols and melals pieliealineiil willi sludge
dexvalenng
Shipping ol VM(\ bom gioundwalel is uicxrisihlc
< ieneiatinn ol activated laibnu and dewaieicd sludge is
anticipated
Ticaliiicnl will occiii, but dcgicc lo wbii'li il leduces
ha/.uds will IK: limited by luw yield
-------
IAIII>: 14 (cont.)
Assessment Factor
Alternative MM
No Action
Alternative MM 2
l C'unliols
Aliiin.nivc MM 1
(iinnmlwaler I: nl i.u In in/I lealmciil/Disi luige in
Suilace Water ami Institutional Cnnlinls
Short Term Effectiveness
I'rirteclioa of Community
Protection uf Woikcrs
Environmental Impacts
Not applicable
NIK applicable
No short-term adverse cnviriwuiienial impacts
enpeclcil deyniul lln)«; Ih;i4 tuilc-iilly olsl
None iilcnlilicil
1'iHcilll.il ,H|VCI\C n|nisincs to woikciN iluiiii)!
gliHiliilwuIci sampling Kisk 1.111 lie ciinlitillcil
llnoii|:li IIM: of si.iiul.uil s.ilcly f<|uipincnl
Suinc us MM I
Risks ICSIlllMI£ llOIII III! Sllc IfilllsplMl llf llcvvilk'lftl sllhl(!CS
anil pnitvss upsfls Ifillk'i va|hii in atiik'uus fllliifiil)
« IHISIlll'lt it t I lllllllll.ilill'
1'iilciilial ailvirist: cxposincs coulil *H:I.III iliinii); insl.ill.iiiiiii
ul cxIi.Kliiin wells anil lic.ilincnl ul cxii.Hlnl ymimiln.iifi
Ilicsc tail lie iiiiiliiilkil llnougli ii|>|Mii|iiialc luallll ami
salely putceiluics
INilcnlial atlvcisc enviiiiniiiciilal impacts usMteialcil with
IIIIHCSS upsets can lie iiiiiiiini/ctl llH
-------
TAIII.I-: 14 (cont.)
ASSCSSIIKIII Factor
linplemenlahilily (continued)
Cunslrucliun and Operation
(Availability of Services,
Equipment. Specialists.
Materials, and Technologies)
Reliability of Technology
Ease of Undertaking
Additional Remedial Aciion
Monitoring Considerations
Administrative feasibility
,
(Tost
Slate and Ooniniunity Acceptance
Alieniuiivc MM 1
No Aciion
Not applicable
Not applicable
Additional remedial action unaffected l>y this
alternative
Not applicable
Nut applicable
No costs associate wit I the No Hunt A uin.illvi
I'o be addressed following public comment
pciiod
Alternative MM 2
Institutional Conlinls
Ucaddy available
(iioumlwulcr iiioiiitoiing is an clfcclive means loi
assessing changes in gioiindwalei conditions over
lime
Same as MM 1
I'enodic collection ami analysis of gioumlwalci
samples ici|imcd
l:x|M;ct to implement deed icstiuiums/ msliliiiitmal
conliols in si> imiinbs
Allcinalive MM 3
( iioundwiitei lixliaction/ l'rcatuu:ut/l)lsihaii!C to
Surface Water and Institutional Contiols
Meathly available
An .snipping, metals pK-ci|iualion and sludge dL-v\aieim^
aie all tellable lcchnolo(;ics
(iiiiiindwalcr |inmping is a icliablc Icchnoliigy loi
uinluillmg plume inigialion
(iiouiulwalcr moniiointt: is an ellecli\t; means toi
assessing changes in gioiindwaicr coodilions o\ci lime
Same as MM- 1
I'ciioihc collection anil analysis of t'.immdwalci. pitH'ess
walei, cllUienl an and wastes icquiicd
Same as MM J
Discbaigcs would need in mcfi stibsianlixe uH|imemenls ol
ai|ncons and an dischai^e pomils
.
1 'A! lni;tli'il iu'1 |iti'M'iil iiisi i\ \|.-IKO.(NN) >1.'.0.(HK)
-------
RECORD OF DECISION SUMMARY
TANSITOR ELECTRONICS, INC.
FIGURES
-------
C 1901 CZ>To«ornvlronmrntiil.lnc.
3.'£'i
/ . . r"S(
o
N)
TANSITOR ELECTRONICSJNC
Rl / FS STUDY
- Ht'NNINGTON. VF.
C«AFJHIC
3CALE
O1 1000' 2000'
4000'
SOURCE: U.S.G.S. HOOSIC FALLS. N.Y.-VT..
POWNAL.NORTH POWNAL ft BENNINCTON VT.
QUADRANGLE MAPS 1954 It 1980
DESIGNED BY: MMS
CHtCKED BY: MMS
REVIEWED BY: MMS
DRAWN BY: R.R.M.
SCALE: 1: 25000
DATE: OCT. 1991
OI\
GZA
GeoEnvironmental.lnc.
-------
Figure 2
Site Plan
Tansitor Electronics
-------
,CO O
^.
co,<
m
3
00
-------
^
i
On
0
0
-------
PERIMETER
GROUNDTER ARE*- °
Figure 5
CLASS 4
GROUNDWATER AREA
TANSITOR ELECTRONICS, INC.
Bennington, VT.
SCALE
OO
trow » "IB DT G/A
Itc OJlfO Jtff. 1993
-------
V
Figure 6
01\
SAMPLING LOCATION PLAN
TANSITOR ELECTRONICS, INC.
BENNINGTON, VERMONT
-------
»
Figure 7
SUBSURFACE EXPLORATION LOCATION PLAN
TANSITOR ELECTRONICS, INC.
BENNINGTON, VERMONT
-------
o
on O
Figure 8
Ol\
DISPOSAL AREA PLUME
TANSITOR ELECTRONICS, INC.
BENNINGTON, VERMONT
I I I"
-------
s^
Figure 9
Ol\
CONCRETE PAD PLUME
TANSITOR ELECTRONICS, INC.
BENNINGTON, VERMONT
c.< Al. I I"--
Vi- c.i.-'
-------
08
zm
-HO?
> -no
2 o
in
HO
OCO
-H |
om
I
O o
O Oo
^^
w<
om
03
sJs ; >'
ll r -M
i
IOI-: . I,
II =^ <
HillOi
-------
NORTH
860
ANALYTICAL RESULTS
SB-toe
SOU. (mq/kq)
OCP'H
_
-
I
-
3 -72
1 -I*
34-76
1 -20
2 -30
IVQC
NO
02
t.J
ND
HD
ND
NO
NO
NO
NO
CROUWWAICfl (uq/i)
12/5/91
IVOC 332
. . C J«0
10/26/92
2*7
<0
ieo
5/10/9*
2039
«7O
2000
SOIL (mgAg)
DEP'M
-
_
;
i - j
i - j
1 - 9
1 - >
3 - 5
3 - i
2 -30
IVOC
i ^
1 1
16
1O2
16
(r
li
lr
ND
NO
CffOUNDWMCR
-------
8
.^>r">-v. *-:,^"
., |
rl i :
V j !
Figure 12
WETLANDS AND SURFACE WATER AREAS
TANSITOR ELECTRONICS, INC.
fyj\ BENNINGTON, VERMONT
-------
MW-107U !
Figure 13
CONTAMINANT PLUMES
TI ZONE, AND
CLASS 4
GROUNDWATER AREA
TANSITOR ELECTRONICS, INC.
Bennington, VT.
00
SCALE
00
JOOFEST
AdaotBd from a "IV Or GZA
GeeCnv*onni«nlil. l^e Oltea UT. 1993.
-------
RECORD OF DECISION SUMMARY
TANSITOR ELECTRONICS, INC.
APPENDIX A
STATE OF VERMONT'S CONCURRENCE
-------
State of Vermont
Department of Fisn and Wildlife
Department of Forests. Parks and Recreation
Department of Environmental Conservation
State Geologist
RELAY SERVICE FOR THE HEARING IMPAIRED
1-800-253-0191 TDD>Voice
1-800-253-0195 Vaoe>TDD
AGENCY OF NATURAL RESOURCES
Department of Environmental Conservation
29 September 1995
Ms. Linda Murphy, Waste Management Division Director,
US EPA, Mail Code: HAA
JFK Federal Building
Boston, MA 02203
Dear Ms. Murphy:
Vermont has reviewed the draft Record of Decision (ROD) for the Tansitor Electronics
Superfund Site located in Bennington, VT. Vermont concurs with the draft ROD as written.
We feel it is protective of human health and the environment, and provides adequate safeguards
in the event the contamination remobilizes from its present and predicted location.
The Agency of Natural Resources has confirmed through the State Attorney General's
Office that the State of Vermont through the Secretary of the Agency of Natural Resources can
accept the use of restrictive covenants as a mechanism for establishing institutional controls at
this site.
Thank you for giving Vermont the opportunity to work so closely with the US EPA on
the investigation and development of remedial options for this site.
Sincerely,
Barbara Ripley
Secretary of the Agency of Natural Resources
Chlorine Free 100% Recyded Paper
Regional Offices - Barre/Essex Jct./Pittsford/Rutiand'N. Springfield St Johnsbury
-------
RECORD OF DECISION SUMMARY
TANSITOR ELECTRONICS, INC.
APPENDIX B
ARARS TABLES
-------
I AIU,K l-l
Page I nl 2
CIII'MICAI.-SI'I'CII 1C AI'I'I.K'Ani.r. OK Um.I'VANTANI) APPROPRIATE
oin-coNsini;.Ki:.n(rhCs)
Medium
G round water
Requirement
Summary of Requirement
Slnlus
Action to be Taken to Attain
Requirement
Vermont Grounclwater
Protection Act -
10 VSA Chapter 48.
Act protects gronndwaler through existing
regulatory programs ami provides restrictions,
prohibitions, slandaids and uilciia lor
gioundwaliT pmlrrlinii lor pio)'.iams which
icgiiliitc activities which may ailed gioiindwalci.
Applicable
Vermont has classified the groundwuler
plume as Class IV, which is not
acceptable lor ill inking but allows
commercial and industrial uses. All of
the iillcinalives will iillain standaids lor
these permitted uses at the site.
Adjacent to the plume, groundwater is
classified ns Class III. Pump and treat
(MM-3) will ensure that contaminants
do not migrate and cause a violation of
these standards. Monitoring (MM-2)
will detect any migration of
contaminants away from the Class IV
area.
Applicable
Allcrnalivcs
MM-I
MM-2
MM-3
Vermont Groundwater
Protection Rule and Strategy - 10
VSA Chapter 48,
I-PR Chapter 12
The standards consist of groundwater
classifications, which designate and assign uses
lor groundwalci; In addition, the regulations
establish water quality criteria necessary to
sustain the designated uses.
Applicable
Same as above.
MM-I
MM-2
MM-3
ITA Ciioundwater Protection
Strategy
Federal Safe Drinking Water Act
(SI)WA)
Maximum Contaminant Levels
(MCI,s)-40CFR Part 141
Piovides classification and icsloialion ol goals ol
groundwater based on its vulnerability, use and
value.
Maximum Contaminant Levels (MCl.s) arc
enforceable standards that are applicable to
di inking water supplies. M< 'l,s aic lelcvanl and
appropriate for groimdwaliT that may be a
potential source of di inking water.
To Me
Considered
Relevant
and
Appropriate
This strategy is considered in
conjunction with the Federal SDWA and
Vermont Groundwater Protection Rule
and Strategy in determining cleanup
goals.
MCLs must be attained unless waived.
None of the alternatives will attain these
ARARs in a reasonable limcframc.
MM I
MM-2
MM-3
MM-I
MM-2
MM-3
-------
Ki Jo No. 1?'»'M,. i,
Page 2 ol
TAm,E 2-1 (CONT'D)
Medium
Requirement
SDWA
Maximum Contaminant Level
Goals (MCI. Gs)-
IOCTR 1 'II.SU- Ml .62
RCRA Groundwalcr Protection
Standard- 40 CHI 264.94
US EPA Reference Doses (RIDs)
fiPA Carcinogen Assessment
Group Potency Factors
RPA Health Advisories and
Acceptable Intake Health
Assessment Documents
Summary of Requirement
MCI (i arc sol wild a maii'.iu ol safety at levels
that would lesull in no known or anticipated
adverse health elf'crls over a lifetime.
The RCRA cjoundwaler pioleclion standard is
established from groimdwalcr nioniloi inn "'
RCRA permitted treatment, storage or disposal
facilities. The standard is set at cither an existing
or proposed KCRA-MCI., background
concentration, or an alternate concentration
protective of human health and the environment.
Rf'RA-MCI.s may ho used or ACI.s may be
developed at the site to identify levels of
contamination above which human health or the
environment is ;il risk and provide an indicator
when corrective action is necessary.
RIDs arc dose levels developed by lil'A for use in
the characterization of risks due to non-
carcinogens in various media.
EPA Carcinogenic Potency factors are used to
compute the individual incremental cancer risk
resulting from exposure to carcinogens.
Intended for use in qualitative public health
evaluation of remedial alternatives.
Status
Non-7ero
MCI, (is are
relevant and
appropriate
Relevant
and
Appropriate
1 o He
Considered
To Be
Considered
To He
Considered
Action to be Taken to Attain
Requirement
Non-7.cro MCl.s must l>c attained None
of the alternatives will attain these
ARARs in a reasonable lime frame.
Compliance with concentration limits
and regular monitoring requirements will
be considered in developing remedial
alternatives for groundwatcr. None of
the alternatives will achieve RCRA -
MCl.s in a reasonable time frame. MM-
2 and MM-3 will meet monitoring
requirements.
RIDs are typically employed to
characterize risks of groundwaler
contaminant exposure (for ingestion
pathways).
These factors are used to assess health
risks from carcinogens present at the
site.
Used, if adequate data exist, in assessing
health risks from ingesting groundwaler
at the site.
Applicable
Alternatives
MM-I
MM-2
MM-3
MM-I
MM-2
MM-3
MM-I
MM-2
MM-3
MM-I
MM-2
MM-3
MM-I
MM-2
MM-3
IKI llM;VX>»t\UVK> 61 121
-------
File No. I259<>.62
07/27/9.1
Page I of 2
I AIH.K 1-2
l.orATION-SPF.CII 1C AI'IM.K'AMI.K OK Kill .KVAN I AND APPROPRIATE
REQUIREMENTS (AKARs) AND CRITERIA TO HE CONSIDERE
Location
Wetlands
Requirement
Vermont Wetlands Protection Law
(10 VSA Chapter 37) and the
Vermont Wetland Rules.
Federal Clean Water Act (CWA)
(33 USC 1344)
40 CFK 230, 404.
Executive Order 1 1990, Protection
of Wetlands - 40 CFR 6, Appendix
A
Fish nnd Wildlife Coordination Act
(I6USC66I)
Endangered Species Act of 1973
( 1 6 USC 53 1 ) 50 CFK 200 and 50
CTR part 402
Summary of Requirement
The rules require that the Vermont Water Resources
Board adopt rules to identify and protect Vermont's
significant wetlands. These standards include wetland
classification. Any activities within fifty-foot buffer
zones around vegetated wetlands, or within the
wetlands, require the filing of a Request for Conditional
Use Determination with the ANR.
Applies to dredge and 111! activities. Under this
requirement, no activity that adversely affects a welhuul
shall be permitted if a practicable alternative that has
less elicit is available. Appropiialc and piaclii aMc
steps must be taken to minimi/e (he potential adverse
impacts of the discharge on the aquatic ecosystem.
Under this regulation. Federal agencies are required to
iniiiiini/e the destruction, loss or degradation of
wetlands and preserve and enhance natural beneficial
value of wetlands.
This regulation requires that any Federal Agency (hat
proposes to modify a body of water must consult with
Ihc U.S. Fish and Wildlife Services. Addressed under
CWA regulations at 40 CFK 230 and 404.
This regulation is designed to protect endangered
species. Consultation with the Department of Ihc
Interior is requited if endangered species are identified
at or near the site.
Status
Applicable
Applicable
Applicable
Applicable
Applicable
Aciion to be Taken to Attain
Requirement
Protection of wetlands and
compliance with the substantive
requirements of these regulations
will be incorporated into (he
design.
During Ihc identification,
screening, and evaluation of
alternatives, the effects on
wetlands are evaluated. All work
will be performed in accordance
with these regulations.
Remedial alternatives that involve
construction must include all
practical means of minimizing
harm to wetlands. Wetlands
protection consideration must be
incorporated into the design of the
remedial action.
During the identification,
screening, and evaluation of
alternatives, Ihc effects on
wetlands are evaluated, (fan
alternative modifies a body of
water, I7,PA must consult U.S. Fish
and Wildlife Services.
Design of remedial action must
include means to minimize
disruption nf the natural
environment.
Applicable
Alternatives
MM-2
MM-3
MM-2
MM-3
MM-2
MM-3
MM-2
MM-3
MM-2
MM-3
-------
TABLE 2-2 (CONT'D)
File No.
12b'J (..!>:?
ie 2 ol ,'
Location
Requirement
Summary of Requirement
Slattis
Action to be Taken to Attain
Requirement
Applicable
Alternatives
Hoodplains
RCRA Location Standards -
40 CFR 264.18 and 761.75
Executive Order 11988, Protection
of Flondplnins -
40 CTR 6, Appendix A
This regulation outlines the requirements for
construction of a RC'RA facility on a 100-year
lloodplaiii.
Applicable
Federal Agencies are required to reduce the risk of Hood
loss, minimize impact of Hoods and restore and preserve
the natural and beneficial value ol lloodplains.
Applicable
No activities are expected to take
place in a 100 year floodplnin.
No activities are expected to take
place in a 100 year floodplain.
None
None
Ciroundwatcr
Vermont (Jrouiidwater Protection
Rule and Strategy -
10 VSA Chapter 48,
I-PR Chapter 12
Instructs the ANR to identify, map, and classify
groiindwaler into classes so that various groundwatcr
resources shall he enhanced, maintained and protected.
The regulations piesciihe Ilie minimum water quality
criteria requited to sustain the designated uses. The
Hazardous Material Management Division of the
Department of Lnviionmenlal Conservation reviews
petitions for the leclassilien!ion of ground waters to
Class I, II or IV status.
Applicable
The ANR approved a petition to
rcclassify the site area
gioundwatcr to Class IV status on
November 18, 1993. The
requirements provided in AWK's
determination must be followed.
MM-I
MM-2
MM-3
-------
TAHLIC I-J
File No. I2.S"6.<>.>
07/2 7/'M
Page I ->M
AniON-SPI'CIFIC AI'I'I.ICAMI.I- OK KI-I.I-VANT
AND APPROPRIATE KI-OIIIKI--MI'N'IS(AKAKs) ANIH'KfllWIA 11) HI- C< >NSII)I:.KI-I> (UK's)
Requirement
liedeiaj
National Emission Standards for
lla/nrdous Air Pollutants
(NI'SIIAPs)(40CFR6l)
RCRA 40 CFR 264
Snbparl AA, Air Emission
Standards I'or Process Venls
RCRA 40 CFR 264
Subpart Hll, Air Emission
Standards lor Equipment Leaks
OSWI'R Directive 9355.0-28,
Air Stripper Control Guidance
department of Transportation (DOT)
(19 CFR 107, 171. l-l 71. 5)
Fish and Wildlife Cuoidinalion Act
(16 USC 661)
Resource Conservation and Recovery
Act (RCRA)
Subtitle C, 40 CTR 260
Summary of Requirements
Specify maximum emission talcs of ha/ardoiis
air pollutants.
Regulates facilities that have operations
involving air emissions above pailicnlar levels.
Requirements governing response to equipment
leaks at facilities that may cause air emissions.
Guidance regarding use of air emission controls
at CP.RCI.A sites.
Regulations for off-site lianspoil of ha/aidous
waste. Regulations specify piocedures lor
packaging, labelling, manifesting, as well as
transportation.
Requires the notification olllie appiopiialc Slate
agency exercising juiisdiclion over Wildlife
Resources and U.S. Fish and Wildlife Service,
when undertaking any Federal action that
modifies any body of water or al feels lisli and
wildlife.
RCRA regulates the generation, transport,
storage, treatment and disposal of hazardous
waste.
Status
Applicable
Relevant and
Appropriate
Relevant and
Appropriate
To He
Considered
Applicable
Applicable
Relevant and
Appropriate
Action to be Taken to Attain ARARS
Remedial alternatives involving air emissions from
tiealmenl units must comply with these regulations.
Air Stripping System must conform to these
requirements
If, during implementation of remedial action,
equipment leaks occur the response must be' in
confortnancc with this Subpart.
The remedial action should address this guidance.
Off-site shipment of hazardous materials will have to
be properly contained, labelled and manifested.
Relevant federal agencies must lie contacted to help
analy/e impacts of remedial action on wildlife. in
wetlands and rivers.
Remedial alternatives involving transport, storage
and disposal of materials must comply with these
regulations.
Applicable
Alternative
MM-3
MM-3
MM-3
MM-3
MM-2
MM-3
MM-3
MM-2
MM-3
-------
TAMI.E 2-3 (CONTM5)
I i I
Requirement
IOCi:R2fi4
Sitl<|<»il II - (iciicinl Facility
Slandnids (or Ownei* anil Operators
of Permitted llarardous Waste
Facilities (-10 CI:R 26-1. 1 0 - 26-1. 1 8)
Siili|<;iil (' - Prcpaicdncss and
ricvcntion
(40 CFR 26-1.30 -26-1.37)
Suli|inil 1) - Contingency Plan nml
1 nicigcncy Proccdmcs
(l Kcqiiiieincnls
General facility requirements outline general
waste analysis, scciuity iiiciisnii";. inspi't lions
niul liaiiiing m|iiiicmrnls
l(f(|iiiioiucnls loi salcly i'i|iii|iMH-nl and spill
crmltol
Rci|tiircincnls lor ri-spon-io In pincfdnics such as
explosions and liies.
Rcqniicnirnls lor icpoilini; anil ii-icmlkcrpini; at
RCRA fiicililics.
Rcquircincnls for priiiin
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TABLE 2-3 (CONT'D)
u No.
I'dljl!
'I <1
Reqiiircnicnt
Land Use iiiut Development Law
(10 VSA Part 5, Chapter 151)
Vermont Water Quality Stntiilnrds listed
under (lie Vermont Water Pollution
Control Act (VWPCA) -
10 VSA Chapter 47 and
fM CMR .1.00 nnd 4.00
American Conference of Governmental
liulnslrial 1 lygicnists (ACGII 1)
Threshold Limit Value (TLV) Time
Weighted Average (TWA) and Short
Term Exposure Limit (STP.Ls)
CAA-Statc Implementation Plan
Emission Standards - 40 CFR 52
Summary of Re<|iiircmenls
Regulates areas in which there is construction or
improvement, or some proposed change to (lie
land.
The standards consist ol 'classification ol surface
waters which designate the most sensitve uses
for which various waters shall be enhanced,
maintained, and protected; and which prescribe
the minimum water c|ii;ilily uilcii.i rccjiiiicd to
.sustain the designated uses. Slandaids icgulalc
discharges ol pollutants to surface waters.
TLVs are issued as criteria for controlling air
quality for occupational sellings. S ITI.s arc
11 llecn minute lime-wcigliled conccnlialions.
Emission Standards designed to attain National
Ambient Air Quality Standards
Stains
Relevant and
Appropriate
Applicable
To He
Considered
Relevant and
Appropriate
Action to be Taken to Attain ARARS
I'Xtinclion and treatment system must produce no
undue air or water pollution.
lilllneiil standards will be attained in the discharge of
treated groundwaler to the perennial stream or
Browns Brook. No state numerical standards apply
to parameters measured at the site. However, the
rcf.ulalions require the use of Federal Ambient Waler
Quality Crileiia to establish water quality for toxic
pollutants. AWQC are non-regulatory
concentrations for the protection of aquatic life; and
the protection of human health from water ingcstion
and lish consumption.
TLV-TWAs and STELs will be used in the
evaluation of predicted air concentrations during
lemcdial activities.
Stale Implementation Plan requirements are
enforceable ARARs and must be attained.
Applicable
Allernali\e
MM-3
MM-3
MM-3
MM-3
FRI:,DM2S')662M2?'Ni-62T2)
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RECORD OF DECISION SUMMARY
TANSITOR ELECTRONICS, INC.
APPENDIX C
STATE OF VERMONT GROUNDWATER RECLASSIFICATION ORDER
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State of Vermont
O*p*nm«nt of Pith «nd Wildlife
Department of Fornts. P»rt<» and Recreation
Department of Environmental Contervatibn
Sun Geologist
Natural Reiourca* Conieruation Council
Telephone Relay Service
for the Hearing Impaired
1-800-253-0191 TDD > Voice
1-800-253-0195 Voice>TDD'
AGENCY OF NATURAL RESOURCES
Department of Environmental Conservation
WATER SUPPLY DIVISION
The Old Pantry Building
103 South Main Street
Waterbury. VT 05671-0403
TELEPHONE (802) 241-3400
FACSIMILE (802) 244-5141
March 15, 1994
Carroll Killen, Director
Tansitor Electronics, Inc.
P.O. Box 230
Bennington, VT 05201
Dear Mr. Killen:
Enclosed please find a March 10, 1994, order modifying the terms
of the groundwater reclassification order of November 23, 1993.
Acting on advice of the Groundwater Coordinating Committee,
Agency Secretary Barbara Ripley has executed the modifications.
By this letter, I am approving your suggested list of organic
contaminants of concern, corrected to read as follows. These
are:
1,1,1-trichloroethane (1,1,1-TCA)
tetrachlorotehane (PCE)
trichloroethane (TCE)
1,1-dichloroethane (1,1-DCA)
1,2-dichloroethane (1,2-DCA)
1,1-dichloroethene (1,1-DCE)
1,2-dichloroethene (1,2-DCE)
chloroethane
vinyl chloride
This list does not have to be specified in the order; this letter
constitutes state concurrence with your list, except for two
typographical errors where you indicated "1,1-dichloroethane
(1,1-DCE)" and "1,2-dichloroethane (1,2-DCE)." I believe you
intended'those to read "dichloroethene" rather than
"dichloroethane.."
The modification to the order provides that you may use a.
specific, named employee of Tansitor Electronics to conduct the
monitoring and reporting, but only upon approval of the
secretary. Such approval has not yet been given, however,
pending acceptance of the named employee and a demonstration that
the employee has the knowledge and skills to conduct the
sampling. We will have to develop a method of making that
evaluation, and will contact you when we have.
TDD: 1-800-2*3-0191
-------
Carroll Killen, Director
March 19, 1994
Page 2
Please give me a call if you have any questions or comments on
this action by the Secretary.
Sincerely,
Jay L. Rutheptord, P.E., Director
cc: Groundwater Coordinating Committee Members
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STATE OF VERMONT
AGENCY OF NATURAL RESOURCES
DEPARTMENT OF ENVIRONMENTAL CONSERVATION
CLASS 4 GROUNDWATER
Modification to
Rectification Order
of November 23, 1993
Re:
Application of
Tansitor Electronics, Inc.
For a Rectification
of a Portion of The Groundwater Resources
at the Tansitor site in Bennington, Vermont
February 28, 1994
-------
Modification to
Rectification Order
of November 23, 1993
Re: Tansitor Electronics
Pagel
I. Background
On November 23, 1993, the Secretary of the Agency of Natural Resources issued a
Groundwater Rectification order under the authority of 10 V.S.A., Chapter 48, for
a portion of the groundwater at the site of Tansitor Electronics, Inc. ("Tansitor"), in
Bennington, Vermont.
This order reclassified an approximately 9.6 acre area of ground, wholly on
Tansitor's property, from Class 3 (suitable for use as a domestic water supply, and
for some industrial and agricultural purposes) to Class 4 (not potable, but suitable for
some industrial and agricultural purposes).
The rectification order imposed four conditions on the applicant, Tansitor, to
facilitate appropriate oversight over the next five years. The conditions required two
major actions by the applicant:
1. Surveying, boundary marking, and filing of a map in the town records, so the
public would have available information on location of the reciassified area
was, and
2. Continued monitoring of the site to track the subsurface conditions near and
within the reclassified area.
Tansitor has requested modifications to the order, based on economic considerations,
contending that the purpose of the order could be upheld at a lower cost to Tansitor.
II. Findings
1. No change in the location or size of the reclassified area has been requested.
2. For certain monitoring wells, with high levels of contaminants of concern in
them, adherence to extremely low levels of detection places an unnecessary
economic burden on the applicant.
3. Silver is a secondary contaminant under drinking water regulations, with no
known health effects. Two years of monitoring results with no detection of
silver is an adequate oversight for this chemical, on a well-by-well basis.
4. Lead is a primary contaminant with significant health effects, and there is a
substantial public interest in environmental lead. Semi-annual monitoring for
-------
Modification to
Reciassification Order
of November 23, 1993
Re: Tansitor Electronics
Page 2
this contaminant, for at least five years, is in the public interest.
5. Groundwater sampling twice per year, in the fall and spring, provides
information correlated to seasonal fluctuations of subsurface groundwater
conditions. Two samples per year provides increased statistical validity in
analyzing for and detecting trends in subsurface groundwater conditions.
6. Self-monitoring is a basic tenet of the state's environmental programs. With
appropriate training and oversight, a specific employee of Tansitor may
perform sampling and reporting on behalf of Tansitor.
7. By adding another existing monitoring well to the list of wells to be
monitored, and alternating sampling from that well with another well nearby,
additional subsurface groundwater data will be available at no increased cost to
Tansitor.
HI. Modifications to the Reciassification Order
Based on the findings noted herein, on petition of Tansitor Electronics, Inc., and on
recommendation of the Groundwater Coordinating Committee, I order the following
changes to the rectification order issued on November 23, 1993.
1. For the following observation wells, the detection limits shall be low enough
to provide an accurate representation of the contaminant levels:
ERM-2S
MW-104U
MW-108U
For the remaining observation wells, the detection limit is unchanged from the
order.
2. For each observation well, after two years of semi-annual sampling and no
detection of silver, Tansitor may discontinue sampling for silver at-that well.
3. Upon written approval from the Secretary of the Agency of Na'tural Resources,
Tansitor may conduct self-monitoring and self-reporting of sample results, by a
specific, named, employee. In the event the Secretary does not approve self-
monitoring and reporting, or withdraws such approval, Tansitor shall use an
independent consultant to perform these tasks.
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Modification to
Rectification Order
of November 23, 1993
Re: Tansitor Electronics
Page 3
4. Tansitor shall alternate semi-annual monitoring between the two observation
wells MW-112M and MW-104M. This monitoring requirement replaces the
requirement for semi-annual monitoring of well MW-104M.
^Rtxjb^-g
Barbara G. Ripley
Secretary
Date:
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3£-> 01 1993
State of Vermont
Oeoarrment o* 'in ana «Viiai>(e
Deoerrment of ^or-Mn 33r«t ana Si^refltion
State Geoiogist
Nriiu'di Besou'te^ Ccviervation Conn* >i
Telephone Relay Service
for the Hearing Impaired
1-800-253-0191 TDD > Voice
1-800-253-0195 Voice > TDD
AGENCY OF NATURAL RESOURCES
Department of Fnvironmental Conservation
WATER SUPPLY DIVISION
The Old Pantry Building
103 South Main Street
Waterbury. VT 05671-0403
TELEPHONE (802) 241-3400
FACSIMILE (802) 244-5141
November 24, 1993
Carroll Killen, Director
Tansitor Electronics, Inc.
P.O. BOX 230
Bennington, VT 05201
Dear Mr. Killen:
Enclosed please find a reclassification document, reclassifying a
portion of the lands owned by Tansitor in Bennington as Class 4,
or non-potable. The document has been signed by the Secretary of
Natural Resources, in accordance with the provisions of 10
V.S.A., Chapter 48, governing reclassification of groundwaters of
the state.
In this department's and the Groundwater Coordinating Committee's
reviews of your petition, the opinion of the reviewers was that
it was in the public interest to reclassify this portion of the
groundwater to a non-potable classification. In reaching this
recommendation to the Secretary, we examined the criteria
specified in statute and reached the findings described in the
reclassification document.
I ask you to give your attention to the following requirements
and conditions of the reclassification:
1. The area reclassified is not identical to the area in your
petition. This simpler shape was done to facilitate
identification and tracking of the actual land area
involved.
2. Your petition requested a classification that was both
horizontally and vertically delineated. Even if we had
agreed that such a designation was appropriate, the language
in the Groundwater Protection Rule & Strategy does not
provide for a vertical reclassification. Accordingly, all
groundwater beneath the area designated as Class 4 is Class
4 groundwater at all depths.
3. The reclassif ication contains upgradient, plurr.e, and
downgradient monitoring requirements on a semi-annual basis.
Please contact us to establish who will do the sampling and
who will analyse the results.
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Carroll Killen, Director
November 24, 1993
Page 2
4. Tansitor must engage the services of a Vermont licensed
surveyor to describe the reclassified area accurately, to
prepare a plan of it, and to mark the corners of the
reclassified area in the field with permanent markers. This
will facilitate identification of the actual reclassified
area.
5. Although -not discussed in this document, you should know
that we will, under the drinking water regulations, be
requiring the company to monitor the company well adjacent
to the Class 4 area for the contaminants of concern, among
others. This monitoring will be required in accordance with
the Vermont Water Supply Rule and is not a special or
additional requirement of this reclassif ication.
Please review this document carefully, and if you would like to
discuss it further or need clarification of the requirements,
please feel free to contact me.
Finally, we appreciate and thank you for the civilities and
courtesies you have shown to us as we have considered and
reviewed your petition.
Sincerely,
Jay L. Rutherford, P.E., Director
cc: Governor Dean
Rep. Richard Pembroke
Merrill Hohman, US EPA w/encl
Jane Downing, US EPA w/encl
Secretary Chuck Clarke
Commissioner Jack Long
William Ahearn, DEC-HMMD w/encl
Groundwater Coordinating Committee Members w/encl
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STATE OF VERMONT
AGENCY OF NATURAL RESOURCES
DEPARTMENT OF ENVIRONMENTAL CONSERVATION
CLASS 4 GROUNDWATER
Findings and Reciassification Order
Re:
Application of
Tansitor Electronics, Inc.
For a Reciassification
of a Portion of The Groundwater Resources
at the Tansitor site in Bennington, Vermont
November 18, 1993
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Findings & Rectification Order
Re: Tansitor Electronics, Inc.
Page 1
I. Background
On July 15, 1993 the Water Supply Division received an application from Tansitor
Electronics, Inc. to reclassify a portion of the groundwater under its site on Vermont
Route 9 west of Bennington, Vermont. The application contained a summary report
on the conditions at the site which led up to the application with reference to four
other reports with detailed information.
According to the reports, the groundwater at the site has been contaminated by
industrial solvents including 1,1,1-trichioroethane, 1,1-dichloroethane and other
volatile organic compounds which have reached the groundwater as a result of historic
disposal practices. These practices stopped approximately fifteen years ago.
The application requesting reclassirlcation from Class 3 groundwater to Class 4
groundwater, due to concentrations of chemicals exceeding drinking water standards,
was signed by 72 affected or potentially affected persons. The package was reviewed
by hydrogeologists assigned to the Hazardous Materials Management and Water
Supply Divisions and determined to be complete with minor exceptions. By letter
dated July 29, 1993 Tansitor's consultant. Environmental Project Control, Inc.
responded to the noted exceptions and the application was judged complete on that
date.
A notice of a public hearing was mailed to all known parties of interest and published
in the Bennington Banner on August 11. 1993.
An informal public hearing was held on September 15, 1993 in the Mt. Anthony
Union High School with approximately forty persons in attendance. There were no
adverse comments to the rectification request. Approximately 5 commentors
focused their remarks on the projected economic hardships if Tansitor were denied the
rectification, and as a result were forced to conduct additional expensive testing
and remediation of the groundwater.
On September 30, 1993 Merrill S. Hohman, Director of the Waste Management
Division, US EPA Region I, requested via letter that the Secretary not issue a
reclassification order until after EPA had developed its final RI/FS and clean up plan.
The plan is expected during June of' 1994.
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Findings & Rectification Order
Re: Tansitor Electronics, Inc.
Page 2
II. Findings
Regarding the application from Tansitor Electronics, Inc. for a rectification of the
groundwater beneath the proposed Class 4 area at the Tansitor site in Bennington,
Vermont, the Secretary of the Agency of Natural Resources, under the provisions of
10 VSA, Section 1394 and the Ground Water Rule and Strategy, Chapter 12, Section
12-401, finds:
1. Regarding the use or potential future use of the ground water as a public water
supply source-
...that the groundwater under the attached designated Class 4 area is not in use
as a public water supply source and the contamination present in the ground
precludes the potential future use of the groundwater for the immediate (5
years) future.
...that the present water supply well for the Tansitor facility does draw its
water from the fractured bedrock aquifer nearby, but there is no available
evidence that indicates that the water supplying the well comes from beneath
the proposed Class 4 area and it is further noted that this finding and
reclassification order does not preclude the continued use of that well for the
Tansitor facility as long as the water continues to meet all applicable drinking
water standards;
2. Regarding the extent of the activity which poses a risk to the groundwater-
...that the sources of contamination found in the groundwater were the result
of former, now discontinued, disposal practices which were limited in areal
extent to a very small area entirely within the Tansitor property;
3. Regarding the current water quaiity-
...that the groundwater is contaminated beyond drinking water standards for
1,1,1 trichloroethane and 1,1 dichloroethane, at a 95% confidence level.
4. Regarding the availability of the groundwater in quantities needed for
beneficial use-
...that the unconsolidated materials overlying the bedrock demonstrate a low
permeability which limits the feasibility or" beneficial use and that the potential
for the bedrock to vield water for benerlciai uses is unknown except as
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Findings & Rectification Order
Re: Tansitor Electronics, Inc.
Page 3
indicated by the Tansitor production well and other nearby wells;
5. Regarding the consequences of potential contamination and the availability of
alternate sources of water-
...that the groundwater is already contaminated beyond drinking water
standards so that the issue of potential contamination is moot, and that the
availability of alternate sources of water is demonstrated by the Tansitor
production well, which continues to produce potable water and the other
nearby wells which remain uncontaminated;
6. Regarding the classification of adjacent surface water and other factors
relevant to determine the maximum beneficial use of the aquifer-
...that the classification of the adjacent surface water in the perennial stream
south of and down gradient from the Tansitor s..s is Class B. suitable for
public water supply use with filtration and disinfection;
...and that the current use of the property as an industrial facility is compatible
with a Class 4 classification.
III. The Class 4 Groundwater Area
A map showing the Class 4 groundwater area at the Tansitor site in Bennington. VT.
as ordered by the Secretary, is attached.
The area is described as:
Beginning at a point on the northerly Right-of-Way boundary of Route 9, said point
being located 216 ft., more or less, southwest along the Right-of-Way boundary from
the southwestern comer of a parcel of land owned now or formerly by Buzzell:
Thence, turning to the northwest approximately right angles to the Route 9 Right-of-
Way, and travelling 774 ft., more or less, to a point marked by the monitoring well
MW-107U;
Thence, turning to the west and travelling 586 ft., more or less, to a point marked by
a water reservoir;
Thence, turning to the southeast and travelling 890 ft., more or less, to a point in the
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Findings &. Rectification Order
Re: Tansitor Electronics, Inc.
Page 4
northerly boundary of the Route 9 Right-of-Way, said point being located a distance
of 424 ft., more or less, along the northerly boundary of Route 9, rrom the point of
beginning;
Thence, travelling along the northerly boundary of the Route 9 Right-of-Way a
distance of 424 ft., more or less, to the point of beginning.
Said area contains 9.6 acres, more or less.
IV. Conditions of This Reclassification Order.
I. Monitoring of the groundwater is required to determine the need, if any, for
future modifications or extensions of the reclassification order. Tansitor
Electronics, Inc., as a condition of this reclassification order, shall conduct the
following monitoring of the groundwater at its site.
There are four monitoring areas in the Tansitor Class 4 groundwater quality
monitoring plan. These are:
1. Disposal Area/Fire Pond Plume Monitoring
2. Concrete Pad Plume Monitoring
3. Downgradient Compliance Monitoring
4. Upgradient Background Monitoring
Groundwater monitoring shall be conducted semi-annually in the Spring and
Fall for a period of at least five (5) years commencing January I, 1994. The
monitoring schedule shall be reconsidered by the Water Supply Division at the
completion of the first five year monitoring period and petitioner may be
required to continue monitoring.
Monitoring shall be conducted by an independent consultant and analyses shall
be performed by a laboratory acceptable to the Secretary-. All analyses shall
be evaluated by methods with detection limits as good or better than the
Preventive Action Limits in Subchapter 7 of Chapter 12 of the Environmental
Protection Rules, Ground Water Protection Rule &. Strategy.
The groundwater samples taken from the Disposal Area/Fire Pond. Concrete
Pad and downgradient monitoring wells shall be analyzed for the volatile
organic Contaminants of Concern and lead and silver. The upgradient
monitoring wells shall be monitored for VOCs and lead and silver.
The wells to be monitored in each monitoring area are described below. The
well identifiers are those depicted on a map entitled Exploration and Sampling
Locations Remedial Investigation, (Figure 2 of the Tansitor Electronics. I.r.c.
Class 4 Groundwater Area. Benning'.on. V'T report, dated 7/15/93.
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Findings &. Reclassifi cation Order
Re: Tansitor Electronics, Inc.
PageS
Area 1: Disposal Area/Fire Pond Plume
ERM-5S: (shallow directly down gradient monitoring)
MW-103M: (medium depth directly down gradient monitoring)
MW-103R: (deep directly down gradient monitoring)
These wells (ERM-5S, MW-103M &. 103R) will allow the Department to
determine if the contaminants are migrating under the Fire Pond.
ERM-2S: (shallow in-plume monitoring)
MW-104U: (shallow in-plume monitoring)
MW-104M: (medium depth in-plume monitoring)
These wells will allow the Department to determine what is occurring
within the plume.
Area 2: Concrete Pad Plume
MW-108U: (shallow in-plume monitoring)
This well will allow the Department to determine what is occurring within
the plume.
MW-109U: (shallow directly downgradient monitoring)
MW-110U: (shallow directly downgradient monitoring)
These wells will allow the Department to determine if the plume is
migrating.
Area 3: Downgradient Compliance Monitoring
MW-ELF: (shallow monitoring)
This well will allow the Department to determine whethej or not there is a
plume directly downgradient of the eastern leaching field.
New Well: If Tansitor Electronics. Inc.. is able to secure sufficient
access, a shallow monitoring well designed to intercept the top ten (10) feet
of the water table shall be drilled and monitored on the south side of Rte.
9, approximately halfway between MW-109U and MW-ELF. This well
will allow the Department to esti.nate if the plume is migrating beneath the
highway and to refine the groundwater flow contour map.
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Findings & Rectification Order
Re: Tansitor Electronics, Inc.
Page 6
In the event Tansitor Electronics, Inc. is unable to secure access to lands at
the location specified above, it shall install a senes of shallow monitoring
wells across the Class 4 Ground water area, on the North side of Route 9,
at locations to be designated by the Secretary.
Area 4: Upgradient Background Monitoring
MW-101M:
Monitoring this well will provide background water quality data at the site.
For ail sampling, groundwater levels shall be taken at the time of monitoring and
supplied to the Department with the sampling results.
2. Reporting
Tansitor Electronics, Inc., shall report all results from its monitoring of the
groundwater required above, semi-annually on or before June 30 and
December 31, 1994, 1995, 1996, 1997. and 1998. The reporting shall be to
the Water Supply Division, in a forma: acceptable to the Secretary.
The required reports shall include all data from the monitoring, a map showing
the location of the sampling points and :he concentrations of the monitored
compounds, and a brief report summarizing the groundwater conditions on the
Tansitor site with emphasis on the grocndwater quality within the Class 4
groundwater area.
3. Surveying of Class 4 Area
Within 90 days of this rectification order, Tansitor Electronics, Inc., shall
employ a licensed surveyor to prepare a map of the reclassified area, mark the
comers in the field with suitable permanent markers, and prepare a description
of boundaries of the reclassified area.
4. Land Records
Upon completion of the surveying of the Class 4 area. Tansitor Electronics.
Inc., shall cause the map and survey description of the reclassified area to be
filed in the land records of the Town of Bennington.
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Findings &. Rectification Order
Re: Tansttor Electronics, Inc.
Page?
V. Reclassification Order
Based on the findings listed above, and other considerations, I order the
rectification of the ground water beneath the area shown on the attached map from
Class 3 to Class 4.
Chuck C. Clarke, Secretary
Date: //
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RECORD OF DECISION SUMMARY
TANSITOR ELECTRONICS, INC.
APPENDIX D
RESPONSIVENESS SUMMARY
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Table of Contents
Section Page
PREFACE 1
I. OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE
FEASIBILITY STUDY AND PROPOSED PLAN 2
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS .... 5
Site History 5
History of Community Involvement 8
Public Reaction to EPA's Preferred Alternative .... 9
III SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES .... 10
Part I - Summary of Citizens' and Local Officials'
Comments 10
Effects from Daley Mining Company 10
Other Comments 15
Part II - Summary of State Concerns 16
Part III - Summary of Potentially Responsible Party
(PRP) Comments 16
Concurrence with EPA's Proposed Plan 17
Deletion of the Tansitor Site from the National
Priorities List 18
Figures
Figure 1 Location Map of Proposed Quarry and Tansitor Electronics,
Inc.
Figure 2 Cross Section of Proposed Quarry and Tansitor
Electronics, Inc.
Attachments
A List of Formal Community Relations Activities Conducted to
Da~e at the Tansitor Electronics, Inc. Site
B Public Hearing Transcript
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TANSITOR ELECTRONICS, INC. SITE
DRAFT RESPONSIVENESS SUMMARY
PREFACE
The U.S. Environmental Protection Agency (EPA) held a 30-day
public comment period from March 9, 1995 to April 10, 1995, to
provide an opportunity for the public to comment on the Proposed
Plan to address contamination at the Tansitor Electronics, Inc.
Superfund Site (Site) in Bennington, Vermont. EPA prepared the
Proposed Plan based on the results of the Remedial Investigation
(RI) and Feasibility Study (FS). The RI was conducted to
determine the nature and extent of site contamination and to
identify potential risks to human health and the environment.
The FS examined and evaluated various options, or alternatives,
for addressing the contamination. The Proposed Plan, issued on
February 23, 1995, presented EPA's preferred alternative for the
Site, before the start of the public comment period. All
documents which were used in EPA's selection of the preferred
alternative were placed in the site Administrative Record, which
is available for public review at EPA Records Center at 90 Canal
Street in Boston, Massachusetts, and at the Bennington Free
Library, 9 Silver Street, Bennington, Vermont.
The purpose of this Responsiveness Summary is to document EPA's
responses to the questions and comment raised during the public
comment period. EPA considered all of the comments in this
document before selecting a final remedial alternative to address
contamination at the Site.
This Responsiveness Summary is organized into the following
sections:
I. Overview of Remedial Alternatives Considered in the
Feasibility Study and Proposed Plan, including the
Preferred Alternative - This section briefly outlines
the remedial alternatives evaluated in the FS and the
Proposed Plan, including EPA's preferred alternative.
II. Site History and Background on Community Involvement
and Concerns - This section provides a brief history of
the Site and an overview of community interests and
concerns regarding the Site.
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III. Summary of Comments Received During the Public Comment
Period - This section summarizes and provides EPA's
responses to the oral and written comments received
from the public during the comment period. Part I
presents comments received from citizens, and Part II
presents comments received from potentially responsible
parties (PRPs).
In addition, two attachments are included with the Responsiveness
Summary. Attachment A lists community participation activities
conducted by EPA and the Vermont Department of Environmental
Conservation (VT DEC) to date at the Site. Attachment B contains
a copy of the transcript from the public hearing held on March
22, 1995 in Bennington, Vermont. The original written comments
submitted by citizens and PRPs are available in the
Administrative Record.
I. OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE
FEASIBILITY STUDY AND PROPOSED PLAN
Using information gathered during the RI and the Risk Assessment,
EPA identified several response objectives to address groundwater
contamination at the Tansitor Electronics, Inc. Site.
The primary objectives are 1) to eliminate or minimize risks to
public health and the environment by preventing individuals from
being exposed to groundwater contaminants; 2) to prevent the
migration of groundwater contamination beyond its current extent;
and 3) to restore contaminated groundwater to drinking water
standards, if technically practicable.
After identifying the response objectives, EPA developed and
evaluated potential alternatives to address groundwater
contamination. The FS describes the alternatives and the
criteria EPA used to narrow the list to three potential
alternatives.
As the FS progressed, the field data suggested restoration of the
groundwater using treatment might not be feasible. Consequently,
as part of the FS, a study was performed to determine whether it
would be technically practicable to restore contaminated
groundwater to drinking water standards, including Maximum
Contaminants Levels (MCLs). These standards, established under
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the Safe Drinking Water Act, are Applicable or Relevant and
Appropriate Requirements at this Site (ARARs). Typically, an
alternative selected to address contamination at a site must
achieve ARARs. However, under CERCLA, there are certain
specified circumstances under which ARARs may be waived. One
such circumstance is if achieving ARARs is technically
impracticable from an engineering perspective.
EPA has concluded that it is technically impracticable to restore
the groundwater to drinking water standards within a reasonable
timeframe and therefore has waived this ARAR.
EPA selected a preferred alternative by considering the extent to
which each alternative would meet the response objectives. The
preferred alternative includes the following features:
Implementation of institutional controls to prevent the
use of contaminated groundwater;
Long-term monitoring of site groundwater on a regular
basis to evaluate changes in site conditions over time;
Establishment of contingencies for future additional
investigation or further action should the long-term
monitoring reveal that contaminants have migrated
beyond their current vertical or horizontal extent; and
A review of the Site every five years to ensure that
the remedy remains protective of human health and the
environment.
The estimated net present worth of the remedy is $390,000. The
selected remedy provides an effective reduction in human health
risk through a combination of institutional controls, long-term
monitoring, and five-year site reviews. The long-term monitoring
program and five-year review ensure that if site conditions
change, further assessment will be taken and action may be
required. None of the alternatives evaluated would restore the
groundwater to drinking water standards within a reasonable time
frame. As stated above, EPA has waived the requirement to
achieve drinking water standards at this Site due to technical
impracticability.
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The following other alternatives were evaluated in detail in the
FS:
Alternative MM-1 - No Action: Under this alternative, no actions
would occur to actively reduce chemical contamination on-site.
Both contaminant plumes would continue to migrate, the Disposal
Area plume into the Fire Pond and the Concrete Pad plume into the
intermittent stream and storm drain system as presently occurs.
EPA would make no efforts to restrict use of the contaminated
groundwater, and would establish no contingencies to address
possible changes in the migration of contaminants in the future.
Alternative MM-3 - Groundwater
Extraction/Treatment/Discharge/Institutional Controls/Monitoring:
Alternative MM-3 would involve extraction of groundwater,
followed by treatment by chemical and physical processes to
remove VOCs and possibly metals. Treated groundwater would then
be discharged. Alternative MM-3 would also incorporate the
institutional controls, long-term monitoring components, and
five-year reviews described under EPA's preferred alternative,
Alternative MM-2.
All of the remedial alternatives considered for implementation at
this Site are described in the Record of Decision (ROD) Summary
Document and in the Proposed Plan, and are discussed in detail in
the Feasibility Study.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Site History
The Site consists of approximately 44 acres of land on West Road
(Route 9) in the Town of Bennington, Vermont, and is
approximately 3.5 miles west of Bennington Center (see Figure 1).
Most of the Site (37.6 acres) is located to the north of Route 9,
with the remainder of the Site (6.6 acres) located to the south
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of Route 9. The portion of the Site located to the south of
Route 9 consists of wetlands and there are also wetlands on the
property north of Route 9.
The Site is located in a predominantly rural residential area.
It is bounded to the north by privately owned woodland; to the
east by Houran Road and a commercial property; to the south by
wetlands; and to the west by agricultural/residential areas.
Pleasant Valley School is located approximately 1,200 feet east
and upgradient of the Site.
Tansitor Electronics, Inc. ("Tansitor" or the "facility")
currently manufactures electronic capacitors at the Site.
Approximately 100 workers are employed at the facility. Major
site features include Tansitor's operating manufacturing/office
building, an Etch House, a man-made pond (known as the Fire
Pond), parking areas, a Solid Waste Disposal Area, a Disposal
Area, a Concrete Pad Area, and a Borrow Area (see Figure 2).
Potable water supplies within the vicinity of the Site, including
the water supply on the Site, are provided by private bedrock
wells. Sanitary waste water from the Tansitor facility is
disposed of into two on-site leachfields.
The Site has been used as a manufacturing facility by various
owners since 1956. Between 1956 and 1979, manufacturing process
wastes were disposed on a portion of the property known as the
"Disposal Area," located approximately 400 feet north of the main
building. These wastes contained contaminants known as volatile
organic compounds (VOCs), a class of chemicals which readily
evaporate, or volatilize, into the air. During the period of
1975-1979, the process waste disposed in the Disposal Area
included 1,1,1-trichloroethane which is the predominant volatile
organic compound (VOC) present in the groundwater.
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Another contaminant source is the Concrete Pad Area, located east
of a small manufacturing building known as the Etch House.
Tansitor reported that waste methanol had been burned
periodically on the Concrete Pad. Records also indicate that
some waste cleaning solutions may have been discharged to the two
leach fields or directly into the perennial stream south of West
Road via underground piping. Construction debris, brush, and
office wastes were disposed at the Site in a roadcut known as the
"Borrow Area" and in another location referred to as the "Solid
Waste Disposal Area." See Figure RS#1.
In July 1983, VOCs including 1,1,1-trichloroethane (1,1,1-TCA)
and 1,1-dichloroethane (1,1-DCA) were detected in soil samples
collected from the Disposal Area. In 1988, VOC contamination was
detected in groundwater samples collected from shallow monitoring
wells located between the Disposal Area and the Fire Pond.
However, VOCs were not detected in bedrock wells, including the
on-site Tansitor supply well and nearby residential drinking
water wells.
Using all sampling data obtained through 1987, EPA calculated a
Hazard Ranking System (HRS) score for the Site. The Site was
listed as a proposed National Priorities List (NPL) site in June
1988, based on an HRS score of 35.72, which exceeded the NPL
threshold value of 28.5. The listing became final on October 4,
1989.
On September 12, 1990, EPA entered into an Administrative Order
by Consent (AOC) for the Remedial Investigation/Feasibility Study
with two of the seven current or former owners of the Site. These
two parties, or Potentially Responsible Parties (PRPs) also
agreed to reimburse EPA for a portion of EPA's past costs through
a Cost Recovery Administrative Agreement. Pursuant to the AOC,
the settling PRPs retained a contractor and conducted the RI/FS
under EPA oversight.
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The RI was conducted in three investigative steps; Scoping,
Phase 1A, and Phase IB. These investigations characterized the
nature and extent of contamination related to the Site. The RI
identified two sources of VOC contamination in groundwater: the
Disposal Area plume and the Concrete Pad Area plume.
Contaminants detected above Federal and State drinking water
standards include 1,1-dichloroethane and 1,1,1-trichloroethane.
The RI confirmed that current migration of groundwater
contaminants in the Disposal Area and Concrete Pad plumes is
limited to the shallow overburden soils and has not migrated
downward to the bedrock and that the Disposal Area plume does not
extend beyond the Fire Pond.
EPA conducted a risk assessment to evaluate potential risks to
human health and the environment posed by the Site if no action
were taken to address contamination. The risk assessment
indicated that there are no unacceptable current health risks to
people exposed to contamination at the Tansitor Site. However,
if the Tansitor property is developed for residential use in the
future, EPA has determined that an unacceptable health risk would
result if residents installed drinking water wells which drew
water from the contaminated shallow soils. The ecological risk
assessment indicated that levels of chemicals detected in surface
water and sediments in the Fire Pond and area streams are
unlikely to harm aquatic organisms.
History of Community Involvement
Throughout the Site's history, community concern and involvement
has been fairly low. EPA has kept the community and other
interested parties apprised of the site activities through
informational meetings, fact sheets, press releases and public
meetings.
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During October 1990, 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 November 1990, EPA conducted interviews
with members of the public to ascertain the level of concern the
public held. EPA interviewed city officials, nearby residents
and interested parties.
In February 1991, EPA issued a Community Relations Plan which
included a summary of the site's history; a description of
anticipated investigations and activities to be conducted at the
Site; a summary of key community concerns regarding the Site; and
a schedule of public involvement activities.
A press release was sent out on July 29, 1991 announcing the
beginning of field work at the Site. A Fact Sheet was mailed in
December, 1991, to inform the public of the progress during the
first portion of field work. Another Fact Sheet was mailed in
September, 1993 to discuss the outcome of the Remedial
Investigation (RI) and Risk Assessment and to announce a public
meeting to discuss the RI and Risk Assessment. A press release
in the Benninqton Banner also announced the public meeting
concerning these topics, which was held in the Bennington Free
Library on October 5, 1993.
EPA published a notice and brief analysis of the Proposed Plan in
the Benninaton Banner on February 23, 1995 and made the plan
available to the public through a February 23, 1995 mailing as
well at the Bennington Free Library on March 8, 1995. Also on
March 8, 1995, EPA made the administrative record available for
public review at EPA's offices in Boston and at the Bennington
Free Library. A notice that EPA proposed to waive attainment of
Maximum Contaminant Levels (MCLs) was also included in the
Proposed Plan.
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On March 8, 1995, EPA held an informational meeting to discuss
the results of the Remedial Investigation and the cleanup
alternatives presented in the Feasibility Study and to present
the Agency's Proposed Plan. During this meeting, the Agency
answered questions from the public. From March 9 to April 10,
1995, the Agency held a thirty-day public comment period to
accept public comment on the proposed waiver of MCLs, on the
alternatives presented in the Feasibility Study and the Proposed
Plan and on any other documents previously released to the
public. On March 22, 1995 the Agency held a public hearing to
discuss the Proposed Plan and to accept any oral comments.
Public Reaction to EPA's Preferred Alternative
Individuals who attended the March 8, 1995 public meeting and
March 22, 1995 public hearing, and who submitted written comments
to EPA, generally support EPA's preferred alternative. The
concerns voiced by citizens at the March 22, 1995 public hearing
related primarily to the effect that the activities of the
proposed Daley Mining Company in Hoosick, New York, less than a
mile from the Site, will have upon groundwater migration and
whether or not EPA considered this effect when developing the
Proposed Plan.
Ill SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES
Part I - Summary of Citizens' and Local Officials' Comments
Effects from Daley Mining Company
Several citizens commented on the potential effect that blasting
activities at the proposed Daley Mining Company quarry may have
upon groundwater contaminant migration from Tansitor. The
proposed location for the quarry is Hoosick Falls, New York,
approximately 3/4 of a mile from Tansitor. Citizens generally
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agreed that the preferred plan proposed by EPA was adequate under
current site and groundwater conditions. However, they expressed
their concern that the plan may not adequately address concerns
that blasting and dewatering during quarry operation could
possibly cause a change in flow patterns, resulting in migration
of contaminants to the west.
Response: EPA understands the concern that offsite activities
might affect the contaminant plumes on the Tansitor property. In
fact, this is one reason why it is emphasized in the Record of
Decision that the selected remedy was chosen based on existing
conditions. Should a change in conditions cause a migration of
contaminants, then EPA and Vermont ANR will reevaluate the remedy
for its protectiveness.
In response to the concerns raised, EPA has performed a general
review of the draft Environmental Impact Statement for the
proposed quarry, and EPA's review of this document is more fully
described in the following responses to comments. In general,
EPA found nothing in the EIS, or the comments by community
members, which warranted any alternation of the selected remedial
action for the Site. In addition, EPA found no affirmative data
in the EIS which suggests that the proposed quarry would
adversely affect contamination from the Tansitor Site.
Nevertheless, in EPA's view, additional data collection,
including a pump test, would be recommended in order to fully
understand the extent of possible impact from the proposed
quarry. It is EPA's understanding that the matter of whether the
quarry is to be constructed, and the potential impacts of the
proposed quarry, are presently under full consideration by the
State of New York.
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Comment 1: Four citizens, including two from the Whipstock Hill
Preservation Society, were concerned that activities at the
proposed quarry would affect groundwater flow rates and
groundwater migration patterns. Specifically, citizens were
concerned that blasting a deep hole into the ground could cause
preferential pathways for groundwater and change direction of
flow at the Tansitor Site toward residential properties to the
west. These citizens were also concerned by an estimate that a
hydrologist retained by their organization had given them that
suggested that 1.2 million gallons of water would be pumped out
of the mine site each day. Citizens questioned what effect this
would have upon the contaminated groundwater at the Tansitor
Site.
Response: From the description provided in the EIS, it appears
that the quarry will be in the same geologic formation as the
Tanstor production well and monitoring well MW-103R, which is
directly south of the Fire Pond. The draft EIS also provided
some information on how blasting and pumping at the planned
quarry might affect contaminants at the Tansitor.
With respect to the planned blasting, EPA researched blasting
methods used in the quarry industry and believes that the ground
vibrations generated by blasting at the proposed quarry should
largely attenuate before reaching the Tansitor Site. More
importantly, it is doubtful that any fracturing of the bedrock
from the blasting would extend to beneath the Site.
Consequently, it is expected that the blasting would not create
preferential pathways within the bedrock from beneath the Site.
Therefore, the effect from blasting should be minimal, if any, in
the bedrock beneath the Site and no energy would be expected to
be transmitted to the overburden till. Consequently, EPA
considers it unlikely that blasting at the planned quarry will
open up new pathways for groundwater from the contaminant plumes
at the Site.
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The second issue raised is what impact withdrawal of 1.2 million
gallons per day at the proposed quarry would have on groundwater
flow. The concern is that such pumping activity would move the
groundwater flow divide eastward sufficiently to cause capture of
groundwater beneath the Disposal Area plume.
This effect seems unlikely, because it would require shifting the
groundwater divide several hundred feet to the east. However,
there are several unknowns. First, as stated at the hearing for
the proposed Tansitor remedy, EPA is not involved in the review
process for the proposed mine. Therefore, a critical review of
the underlying data that forms the basis of the EIS has not been
performed for the remedy selection. The EIS estimates a maximum
of 600,000 gallons per day would need to be extracted and it
further states that the maximum distance of drawdown effect to
the east would be 950 feet. EPA does not have sufficient
information to evaluate the accuracy of these estimates.
Second, EPA estimates that the Disposal Area plume is 1500 feet
east of the the second groundwater divide between the proposed
quarry and Tansitor (assuming that they mimic the surface water
divides). It is assumed that the pumping at the mine would draw
water from all directions, rather than just from the east. Based
on overburden soil data collected at the Tansitor Site, it
appears unlikely that the area of influence from the proposed
quarry dewatering would extend to the overburden at the Tansitor
Site.
Third, as the majority of the proposed excavation will be into
bedrock and therefore the majority of the dewatering is to occur
in bedrock, the area of influence on the bedrock aquifer may
extend further than that for the overburden. Without pump tests,
the impact of such pumping on the bedrock cannot be precisely
determined. It should be noted that a pump test of the Tansitor
bedrock well did not reverse the upward gradient in the
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groundwater flow pattern present within the Disposal Area plume.
As noted above, the Tansitor well and the proposed quarry
apparently will be located within the same geologic formation,
the Walloomsac limestone. See Figure RS#2 for a cross section
showing the proposed quarry, Tansitor, and the surface water
divides.
In conclusion, while the current data suggests that the proposed
quarry will not adversely affect the Tansitor contaminant plumes,
additional study of the impacts of the proposed quarry on site
contamination, including the performance of a pump test, would be
recommended.
Comment 2: One individual from the Whipstock Hill Preservation
Society commented that EPA should have evaluated the Daley
blasting report during their study of the Tansitor Site.
Response: EPA began the characterization of the groundwater
contamination at the Tansitor Site in September 1991. As part of
that characterization, information concerning regional geology
and hydrogeology was obtained to put the Tansitor Site in context
within the larger regional setting. The data obtained during the
RI pointed to shallow plumes moving southerly with no evidence of
plume migration off the Tansitor property.
News of the proposed quarry was brought to the attention of EPA
during the Feasibility Study phase at Tansitor. At the time, EPA
was evaluating alternatives to meet the response objectives
outlined above. Further investigation was not considered
necessary to characterize the extent of contamination or evaluate
the alternatives.
In response to the discussion at the hearing for the Tansitor
Proposed Plan, EPA requested and received a copy of the September
1994 draft EIS. EPA's response to the draft EIS is provided
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above. As indicated above, EPA finds no reason to alter its
remedial action based on the information contained in the EIS.
Comment 3: A representative of the Whipstock Hill Preservation
Society requested that monitoring wells be drilled along the
upper east side of Whipstock Hill to a depth of the final
elevation of the mine floor and that the monitoring wells be
drilled along the rock fractures in the same area.
Response: EPA agreed with the observation that there were no
monitoring wells spaced between the contaminant plumes and the
proposed quarry location. However, since the RI data indicates
groundwater flow is to the south and contaminant migration is
limited to the shallow soils, there was no need to install wells
upgradient and further side-gradient of the Disposal Area Plume
or the Concrete Pad Area Plume in order to characterize the Site.
Existing monitoring wells within the plumes will be monitored on
a regular basis and groundwater elevations will be determined.
Groundwater contour maps will be developed based on these
measurements and any changes in flow direction noted. Should the
monitoring indicate a change from current conditions, EPA will
make a determination on the need for any additional action.
Comment 4: One individual suggested that the Vermont Agency of
Natural Resources (VT ANR) and the New York Department of
Environmental Conservation join forces and start analyzing the
Tansitor Site and the Daley Mining Company site together.
Response: EPA and VT ANR agree with the sentiment expressed by
this comment - it would have been preferable to have shared
information earlier in the process. However, the information
contained within the draft EIS does not alter the remedy selected
for the Tansitor Site. EPA and VT ANR are aware of the concerns
of the community regarding the proposed mine, and are willing to
work with NYDEC.
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Comment 5: One individual from the Whipstock Hill Preservation
Society suggested that EPA should consider the effects of the old
mine shafts from the historic Burton Iron Works.
Response: In response to this comment, EPA and VT ANR inquired
with local and state officials regarding the location of the
Burton Iron Works. Although we were unable to determine its
location, any impact from it would be considered part of the
existing conditions. As the RI indicated, under the existing
conditions, the contaminant plumes are located in the upper fifty
feet of soil and are not migrating either vertically or
horizontally. Therefore EPA does not foresee any impact from
inactive mine shafts.
Other Comments
Comment 1: One individual who lives in close proximity to the
Tansitor Site wanted to make EPA aware that he has a 700-foot
deep well on his property and that he would be happy to offer his
well for testing.
Response: As part of the RI, Tansitor sampled selected
surrounding residential wells based on the location relative to
the Site and groundwater flow direction. Tansitor also sampled
residential wells prior to the RI at the direction of VT ANR.
There was no indication of contamination from the Tansitor Site
from any of the residential sampling activities. One contingency
with the selected remedy requires residential wells to be sampled
in the event contaminants are detected above the applicable
levels in the bedrock wells onsite. Should such an event occur,
the agencies will develop a list of residential wells to be
sampled and the offer from this individual will be considered.
Part II - Summary of State Concerns
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At the public hearing, a representative of the State VT ANR
confirmed that the State of Vermont concurred with EPA's proposed
alternative for the Tansitor Electronics, Inc. Site.
Part III - Summary of Potentially Responsible Party (PRP)
Comments
The Director of Tansitor Electronics, Inc. and the Director of
Corporate Environmental Affairs from Siemens Corporation
(Siemens) submitted written comments to express their support of
EPA's Proposed Plan and to express their belief that Tansitor
Electronics, Inc. should be deleted from the CERCLA National
Priorities List (NPL) upon approval of the Proposed Plan.
Tansitor expressed its strong desire for the deletion of the Site
from the NPL because it will "remove the cloud of Superfund
liability from the Tansitor facility and assist the company in
obtaining the financing necessary to maintain and expand its
business."
Concurrence with EPA'a Proposed Plan
Comment 1: The Director of Tansitor commented at the public
hearing and in written comments that the proposed approach is
technically sound, protects public health and the environment,
and satisfies CERCLA's remedy selection criteria. Tansitor
concurs with and supports EPA's proposed determination that it is
technically impracticable to restore the shallow groundwater to
drinking water standards. Based on the fact that no technologies
exist that could attain drinking water standards in groundwater
within a reasonable time frame, Tansitor states that it would be
a "tremendous waste of governmental and private resources" to
attempt to clean up the on-site groundwater. Tansitor agrees
with both EPA and VT ANR that institutional controls are
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appropriate to preclude the use of shallow groundwater on the
Site for drinking water purposes.
At the public hearing, the Director of Tansitor pointed out that
the geology of the area, the depth of the wells in the area, and
the extensive testing that has been done at the Tansitor Site
confirms that groundwater contamination is not a significant
threat to human populations.
Comment 2: Siemens concurs with EPA's conclusion that the
proposed institutional controls to prevent the use of site
groundwater, coupled with the long-term sampling plan and five-
year reviews, will fully protect human health and the
environment.
Response: EPA acknowledges these comments in support of the
selected remedial action. To the extent that the commenters
suggest that there is no risk to human health present at the
Site,.EPA reiterates that the risk assessment did determine that
potential future users of the overburden groundwater would be at
risk.
Deletion of the Tansitor Site from the National Priorities
List
Comment 1: Tansitor and Siemens request that, following the
approval of the Proposed Plan, EPA prepare a Superfund Site Close
Out Report and initiate the delisting process under the
assumption that the State of Vermont will assume responsibility
for the Site. According to Tansitor and Siemens, the criteria
for deletion set forth in Section 300.425(e) of the National
Contingency Plan, 40 C.F.R. § 300.425(e) and in the "Procedures
for Completion and Deletion of National Priorities List Sites,"
EPA Office of Emergency and Remedial Response; OSWER Directive
9320.2-3A (April 1989), OSWER Directive 9320.2-3B (December
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1989); and OSWER 9320.2-3C (February 1992) will be satisfied upon
issuance of the ROD.
Response: EPA does not believe that these comments relate
directly to the selection of the remedial action. EPA
understands that Tansitor and Siemens would strongly support
EPA's deletion of the Site from the NCP as soon as possible.
Following the issuance of the ROD, EPA will begin to evaluate
this issue. To the extent that Tansitor and Siemens suggest by
their comments that no further remedial action is necessary at
the Site, and that EPA may immediately delete this Site from the
National Priorities List, EPA disagrees. While no extraction and
treatment of the groundwater will be performed, EPA is requiring
the imposition of institutional controls under the ROD. Because
no deed restrictions are currently in place at the Site, it would
be improper to delete the Site from the National Priorities List
at this time.
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R2SPONSIVZNSSS SUMMARY FIGURE 1
LOCATION MA? OF PROPOSED QUARRY AND TANSITOR ELECTRONICS, INC.
Scale 1" = 850 feet
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RESPONSIVENESS SUMMARY FIGURE 2
CROSS SECTION OF PROPOSED QUARRY AND TANSITOR ELECTRONICS, INC.
( :
SCALE OF CROSS SECTION: 5:1 (VERTICAL TO HORIZONTAL)
SOURCE: U.S.G.S. HOOSICK FALLS, NEW YORK - VERMONT QUADRANGLE (1980)
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ATTACHMENT A
LIST OF FORMAL COMMUNITY RELATIONS ACTIVITIES CONDUCTED TO DATE
AT THE TANSITOR ELECTRONICS, INC. SITE
November 15 and 16, 1990
Community interviews conducted
by EPA in Bennington.
February 19,1991
Community Relations Plan
issued.
December 1991
Fact Sheet No. 1 issued
describing site history, the
upcoming RI / FS, and the
Superfund process.
September 1993
Fact Sheet No. 2 issued
summarizing the results of the
RI and risk assessment and
listing upcoming opportunities
for public involvement.
October 5, 1993
Public meeting held by EPA and
VT DEC at the Bennington Free
Library to discuss the results
of the RI and risk assessment.
February 23, 1995
EPA Proposed Plan released.
March 1, 1995
Public notice published in the
Bennington Banner announcing
the availability of the
Proposed Plan and
Administrative Record and the
upcoming public meeting.
March 9, 1995 - April 10,1995
30-day public comment period on
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EPA's Proposed Plan and other
alternatives considered for the
Site.
March 8, 1995 Public meeting held by EPA and
VT DEC at the Bennington Free
Library to present the Proposed
Plan and other alternatives
evaluated in the FS.
March 22, 1995 Public hearing held by EPA and
VT DEC at the Bennington Free
Library on the Proposed Plan.
September 1995 Responsiveness Summary issued
as part of the Record of
Decision on EPA's preferred
alternative for the Tansitor
Electronics, Inc Site.
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ATTACHMENT B
PUBLIC HEARING TRANSCRIPT
Tansitor Electronics, Inc. Site
Bennington, Vermont
March 22, 1995
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Volume:
Pages:
1
1-35
COPY
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
PUBLIC HEARING
RE: EPA - PROPOSED PLAN
FOR THE
TANSITOR ELECTRONICS
SUPERFUND SITE
PANEL MEMBERS:
Mary Jane O'Donnell
Terrer.ce Connelly
Michael Smith
Date : Wednesday
March 22~, 1995
Place: Bennington Library
Silver Street
Bennington, Vermont
Time: 6:00 p.m.
O'BRIEN REPORTING SERVICES, INC.
135 North Main Street
Rutland, Vermont 05702 _
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1 Bennington, Vermont
2 Wednesday, March 22, 1995
3 Commencing at 6:00 p.m.
4 PROC-II^INGS.
5 MS. O'DONNELL: Good evening
6 everyone. I would like to welcome to you to
7 tonight's public hearing for the Tansitor
8 Electronics Superfund Site. My name is Mary
9 Jane O'Donnell. I work in the EPA's office in
10 Boston and am in charge of the Maine and
11 Vermont Superfund Section. With me tonight is
12 Terry Connelly. Terry is the EPA project
13 manager for the Tansitor site. And also with
14 me is Michael Smith. Michael is also the
15 manager of the site for the state of the
16 Vermont. Also here is the court stenographer
17 Linda O'Brien. As you can see, we will record
18 all that is spoken during the formal part of
19 tonight's meeting.
20 The purpose of tonight's meeting is
21 to formally accept your many comments on the
22 proposed alternatives for the Tansitor
23 Electronics Superfund Site. I would like to
24 emphasize the word "formal" because tonight's
.25__ meeting is a bit more structured than our
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March 8th meeting, for those of you who did go
to that meeting. As you can see, we are
transcribing the entire contents of tonight's
meeting. The reason for this is that the
comments made tonight will become part of the
administrative record for the site. Also, any
written or oral comments that we receive
tonight and those comments received during the
formal part, during the comment period, will
be responded to in a document called the
responsiveness summary. This responsiveness
summary will summarize EPA's responses to
comments received during the comment period.
It will be issued with the final decision
document which is called the Record Of
Decision.
I would like to begin by describing
the format for tonight's meeting. First Terry
Connelly will give a brief description of the
preferred alternative plant for this site and
EPA's rationale for that particular
alternative. Finally, as an overview, I would
like to open the floor for oral comments for
anyone that is present here tonight. If you
wish to make a comment, I would like you to
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identify yourself and your association to the
Tansitor Superfund Site.
As many of you may already know, the
comment period for the proposed plan began on
March 9th and is scheduled to conclude on
April 10th of next month. For those of you
who don't wish to make oral comments, we
encourage you to submit written comments and
they will be considered equally, as well as
the other comments that, oral comments that we
receive here tonight. However, they should be
postmarked no later than April 10th and all
written comments should be mailed to Terry
Connelly at the EPA's office in Boston. The
address can be found in the handout which I
hope most of you received when you came in; if
you didn't, please let us know and we will
make sure that you get a copy of it or that
you know what the address is.
Finally, I would just like to
emphasize that the entire contents of the
hearing is being transcribed and will beco'me
part of the formal administrative record for
the site.
Any questions in terms of how
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things are going to be handled from a logical
point of view?
(No response from audience.)
MS. O'DONNELL: Then as for
background, I'm now going to. turn this meeting
over to Terry.
MR. CONNELLY: Again, my name is
Terry Connelly. I have been working as the
project manager on the site since 1990. We
had a public meeting on the 8th of March,
there weren't quite as many people here at the
time. And at that time I gave a description
of the results of our investigation as far as
our characterization of the extent of
contaminants from the site and explained the
results of our risk assessment the EPA did to
look at thos.e numbers and to calculate some
type of a risk based on present conditions and
under future possible conditions at the site,
and we then presented the options that we
looked at to address the situation at the
site, and then we presented our proposed plan
to deal with the situation at the site.
So tonight what I'd like to do is
just'begin by summarizing, again, the
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different alternatives that we evaluated and
then our proposed plan and then we'll be,
after the hearing we'll be here to answer any
questions or try to answer any questions.
(Displaying overhead on wall.)
As you know, Tansitor is located
on West Road. It includes the current
facility, the Fire Pond that was constructed
there, and areas that we've designated,
Disposal Area, Concrete Pad, where
contaminants were disposed of and disposal
area, and there's some history of burning of
materials on the concrete pad. The site also
includes a solid waste disposal area. The
borrow area indicates where they took gravel
for various activities on the site. And the
facility is, as all you are aware, operating.
It has two leach fields on each side, and
across the road we have wetlands that is
referenced. These are supposed to represent
the wetlands (indicating on overhead).
There's a stream that flows through the site
and, on intermittent basis that is, it's dry
at times; and then a perennial stream, which
is unnamed, on the south side of the west
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road.
Contaminants were disposed of in
this area (indicating). They have moved with
the groundwater flow towards the fire pond.
The groundwater flow is in the direction from
the hill up here, Whipstock Hill, towards the
wetlands. The results of the investigation
found high consentrations within the
groundwater in the shallow soils between the
disposal area and the Fire Pond. Wells here
and here, and south of the Fire Pond
(indicating) revealed no contaminants going
past the Fire Pond on either the east, the
west, and no contaminants going underneath the
Fire Pond. So what we have is a contained
area of contamination, groundwater
contamination here.
The concrete pad, there was, we
also saw something similar, but a much, much
smaller in terms of concentrations and extent.
We've seen contaminants somewhere into this
area here (indicating). Wells located in the
parking lot have not detected any
contaminants.
The ultimate location for all
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contaminants is the wetlands from the
underground piping/ from the Fire Pond, and
perhaps this plume of contaminants from the
concrete pad may eventually make its way down
to the perennial stream. I would like to
emphasize that by the time the contaminants
which are volatile organic compounds reach the
Fire Pond, they volatilize, okay, you know,
they just volatilize.
So, the concentrations that we see
in the Fire Pond are below federal and state
standards. We have seen some contamination
again in the perennial stream, some organic
compounds and, again, they are at
concentrations that are extremely low, below
federal and state standards.
With that, with the investigation,
we then turn to an evaluation of remedies to
deal with it. I want to point out, also, the
soils in the disposal area were not considered
a risk by EPA, either, under the current
situation, which is its manufacturing
facility. We also evaluated it as potential
future residential area. Essentially the
material that was disposed of in that area is
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pretty much left the area. The concentration
is very low. The same with the concrete pad.
So, what that did is -- we had six
people here en March 8th, I guess that's why
they gave us this room.
(Additional members of the
public entered meeting room.)
MR. CONNELLY: So, in looking at
the feasibility study, we did not evaluate any
remedies for the soils because we determined
they did not pose .a risk.
We looked at in detail three
alternatives for the groundwater at the site;
first one. Then we identified MM1; no action.
This is required by our regulations to give us
some type of comparison. What would happen if
we took no action, what would the risk be?
Second one (indicating MM-2), institutional
controls with groundwater monitoring
contingencies in case something were to happen
on the site; five-year reviews. And third one
(indicating MM-3), we looked at, in depth,
combined institutional controls with
groundwater extraction treatment where we
would be installing wells pumping the
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1 groundwater from the soils, treating and
2 removal of the organic compounds, and then
3 discharging, most likely on site. That would
4 also include five-year reviews.
5 Our regulations require that we
6 evaluate the options with nine criteria:
7 protection of human health and the
8 environment, compliance with ARAR's. These
9 two are considered the threshold criteria,
10 remedies selected have to meet those criteria
11 normally. And then (indicating) long term
12 I effectiveness through cost are considering
13 balancing criteria which we use to determine a
14 balance. State acceptance and community
15 acceptance is what the public comment period
16 is for.
17 I said just a few minutes ago
18 these two threshold criteria, our laws and
19 . regulations say to pick a remedy it has to
20 meet these two (indicating on overhead.)
21 As you can see, I put up the
22 comparison chart here. None of the
23 alternatives that we evaluated complies with
24 the ARAR's.
25 " FROM THE FLOOR: What does that
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stand for?
MR. CONNELLY: ARAR's is what was
the applicable or relevant and appropriate
requirements, regulations. It's the laws,
federal and state laws.
The one it did not meet was
considered Maximum Contaminant Levels for,
it's a drinking water standard well. We have
them for organic compounds, we also have them
for metals and things, but for this site the
concern was for organic compounds.
Our regulations, you know, they
look at, can we meet this within a reasonable
time frame? The regulations don't
specifically state what a reasonable time
frame is, but we started evaluating this as we
got into the feasibility study as we started
looking at the different alternatives because,
again/ threshold means that we have to meet
these two criteria (indicating on chart).
The state, EPA and Tansitor and
Siemens started, well, we had discussions on
this, continued discussions within the law,
within the regulations, that there is a
flexibility for a waiver for this if you can
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1 demonstrate that it's technically impractical
2 to remediate a site, to restore a site within
3 a reasonable time frame (indicating on chart).
4 So, we tasked Tansitor's contractor to develop
5 an argument, a rationale to prove their point
6 that we cannot clean this up within a
7 reasonable time frame.
8 This was done in a document called
9 the Technical Impracticability Evaluation
10 Report or the TI document. This was reviewed
II 'by the state, by me and in the Boston office.
12 People from headquarters are concerned about
13 this, and I had a scientist from one of our
14 labs in Oklahoma who came out and met with
15 people. So, we had several people looking at
16 this and the consensus was, you're right, we
17 cannot clean this up within a reasonable time
18 frame. And I'd be glad to answer questions
19 about that later.
20 So what happens was essentially we
21 then say, okay, well, we'll agree that we'll
22 get a waiver on this issue here, this criteria
23 (indicating on chart.) We then looked at the
24 next five balancing criteria to determine
25 which remedy to propose for which makes sense
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1 for the site. Long-term effectiveness, both
2 two and three (indicating on chart), would be
3 considered effective because through the
4 institutional controls they would prohibit
5 exposure to the contaminated groundwater, and
6 when we don't have exposure, then -there's not
7 a risk because you need both exposure and the
8 toxicity. So, by eliminating the exposure
9 through the institutional controls, you are
10 eliminating the risk.
11 Reduction of MTV stands for
12 mobility, toxicity and volume through
13 treatment. The first two options (MM-1 and
14 MM-2) do not meet it because neither one
15 involves treatments. The third one (MM-3),
16 there would be a reduction as (indicating on
17 chart) I have limited on there because as part
18 of the evaluation of whether it was reasonable
19 to clean up the site, or to restore it within
20 a reasonable time frame. We realize we cannot
21 pump very much water out of the soils. If you
22 cannot pump very much water out of the soils,
23 it's going to take a very long time to remove
24 the contaminants. So it would take a long
25 time to remove the toxicity and reduce the
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volume. We did find short-term effectiveness
as, (indicating on chart) obviously, was MM-1,
we're not doing anything, so short-term
effectiveness is not a problem. Short-term
effectiveness deals with impact to workers,
impact to the community during an
implementation of a remedy, and this one with
no implementation would have no impacts.
Second one, institutional
controls, essentially there's no impacts.
Monitoring, there would be some minimal
exposure potential for the people doing the
monitoring, but that can be controlled through
standard practices.
The third one I've listed as good as
far as short-term effectiveness because there
would be some disturbance of soils through
drilling. But, again/ this could be handled
through standard engineering practices that
would minimize 'the threat to the workers on
site and minimize/ if not completely
eliminate/ any threat to people off site.
Implementability, is not as you
might think. This is a Government word/ so it
doesn't necessarily mean implementation.
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1 It's easy to implement
2 institutional controls, you just need to do a
3 risk, deed restrictions, and things like that.
4 For the third one (indicating MM-3 on chart)
5 it's standard to put in a pump-and-treat type
6 system. When you have contaminated
7 groundwater, it's done throughout the country,
8 throughout the world, so it would not be a
9 problem. Implementing and installing a system
10 like that, there's was on the ground to remove
11 organic compounds in groundwaters, it's a very
12 effective process. But it is not effective
13 because, I mean, we can install it, we can get
14 it up and running, but it would not
15 effectively restore the water to drinking
16 water standards. So implementation, we can
17 install it, yes, but can we use it to restore
18 the groundwater? No. Whereas this one
19 (indicating), we can install it without
20 problems. We can get the monitoring going, we
21 can get the deed restrictions in place, and
22 that's all that deals with. We don't --.and
23 that, again, gets back to installation of the
24 monitoring and the deed restrictions. We've
25 come to protection of human health and the
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environment.
Cost, as you can see (indicating),
cost for the second option $390,000 and the
cost for the institutional controls is 1.5 and
3.3 million dollars, the range varies on what
type of treatment we would have to do.
Michael and I talk about it depends on whether
it's Vermont workers or people from
Massachusetts. So this is, when we look at
these five balancing criteria, it certainly
seems to suggest the second option is the one
that makes sense.
The State has come out, and on
March 8 we received a letter from the State
where they formally concur with MM-2 as the
proposed remedy for the site. And so that's
what we've done in the proposed plan that you
have, most of you have. I hope if you haven't
received a copy, which means you are not on
our mailing list, we would like to get your
name and address so we can put you on the
mailing list and we can send you these. But
this is the r-emedy that we are proposing. So,
we'll try to go through our preferred
alternative in a little more detail.
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1 j .Implementation of institutional
2 | controls, this can be done through deed
3 j restrictions. We don't want to prevent the
4 facility from installing other wells at the
5 site. But our concern is we want to be
6 protective of human health and the
7 environment. There are two plumes, one with
8 extremely high concentrations, organic
9 compounds, so the institutional controls will
10 be designed to prevent anyone from withdrawing
11 I wa.ter from those soils.
12 Long-term monitoring of the site
13 groundwater, they've already started that.
14 The idea is we have a, I think, fairly good
15 understanding of the hydrology of the site,
16 and the groundwater is moving from the
17 disposal area to the fire pond. It discharges
18 into the fire pond. Again, we don't see any
19 contamination moving to either side of the
20 fire pond or underneath it, and so we would
21- monitor the site with the wells that we have
22 on site to make sure there is no change from
23 our current understanding of the property.
24 Third part of the alternative
25 establishment of contingencies that was put in
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there as a, I guess, a conservative safeguard.
We think we understand very well what's going
on at the site with the groundwater, however/
it's our responsibility to meet that first
threshold criteria/ "protection of human
health and the environment." I don't know how
many of you are in the area/ but the only
aquifer in the area as a sole-source aquifer
is the bedrock. So, we want to make sure that
the bedrock aquifer is not impacted by the
contaminants up in the shallow soils. So/ we
would have contingencies for future additional
actions that would be/ somewhat stated,
something similar to that. We won't get into
specifics. Essentially/ we want to have the
option that if our long-term monitoring shows
that the contaminants are moving in a
direction that we did not expect them to move,
either horizontally migrating off the site or
vertically down towards the bedrock, then we
would want to have the option to come back and
say we need to evaluate this because of the
potential of impacting the bedrock aquifer. I
guess I should point out since there are so
many' other people here in the room tonight, at
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the site geology you have approximately 185
feet of soils, glacial till, overlying the
bedrock. The contaminants are to the most
extent limited to the upper 30 feet of the
soils. We have several wells between 40 and
60 feet that have shown no contamination/
whereas the wells placed directly above them
in the shallow soils are again the ones that
are heavily contaminated. So we think we have
in place wells that can detect contamination
and that's what we would base our
contingencies on if we were to see some of the
contaminants in some of the soils.
And, finally, as required by our
regulations, because the contaminants will be
present on the site for an extended period of
time, it requires a review of the site every
five years. Again, the estimated cost for
this alternative is $390,000 over a 30-year
period.
The EPA is proposing this
alternative because we believe it protects
human health and the environment by preventing
exposure of the contaminants through the
institutional controls and through the
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contingencies. Again, it did not meet the
standards for drinking water, but neither did
the other alternatives that we looked at. And
we will in our, what we are proposing in our
record of decision document is to waive that
particular regulation of the EPA and, again,
the State has concurred with this proposed
plan because we think it provides the best
balance of the other evaluation criteria,
long-term effectiveness, cost, and short-term
effectiveness.
If you would like more
information, and I suggest if you're at all
interested, by all means, it's still located
downstairs in the library. We are not sure
how long it's going to be down there because
the library is running out of space, but there
is an administrative record down at the far
end of the library that details the
investigation, the results of the
investigation that we did at the site/ the
feasibility study where we looked at the
different alternatives, the alternatives that
we looked at in detail, as well as other
alternatives that we reviewed and then
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eliminated for not being practical. And then
we have the technical impracticability
document which we think demonstrates why we
cannot clean up the site within a reasonable
time frame.
Again, to reiterate what Mary Jane
said, we're in the midst of the public comment
period to hear from the community. The public
comment period runs to April 10th, and my name
and address is in the proposed plan. If
anyone doesn't have that, I would be glad to
make a copy of that available to anyone. With
that, I guess I'll turn it back to Mary Jane.
MS. O'DONNELL: Thanks, Terry. I,
again, I just want to emphasize what the
purpose of tonight's meeting is basically to
accept comments on the proposed alternative,
and the proposal alternative is hopefully what
Terry showed in his overheads and also what's
described probably most prominently on the
first page of this proposed plan. And that's
basically our reason for being here tonight is
to accept comments on that proposal.
Before I open things to the floor,
I would like to turn things over to Michael
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Smith who would like to make a few comments
relative to the State's perspective on this
proposal.
MR. SMITH: I have very little to
say other than to reiterate that the State
does concur with the proposed plan, the
proposed alternative, and especially with the
decision that the site is technically
impracticable to clean up.
MS. O'DONNELL: Thanks, Michael.
I guess what I would like to do now is open up
the floor for comments. If you please
identify yourself and your association with
the site before you make your comments. Would
anyone like to make comments?
MR. BREITHAUPT: My name is Barton
Breithaupt. I'm a member of the Whipstock
Hill Preservation Society and I have a couple
of questions in regard to the migration of
groundwater and will the EPA impose broader
groundwater monitoring in the area surrounding
Tansitor since the Daley, Incorporated mine
will be located only three-fourths of a mile
away?
MS. O'DONNELL: I guess what we
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1 would like to do is accept comments for the
2 record, and then upon conclusion of accepting
3 everyone's comments we would be more than
4 happy to answer your questions that you might
5 have.
6 ' MR. BREITHAUPT: All right.
7 Another question I might have is has the EPA
8 studied the Daley blasting report?
9 MS. O'DONNELL: We would accept
10 comments and then we'd be more than happy to
11 get back to it.
12 MR. BREITHAUPT: Tonight?
13 MS. O'DONNELL: Tonight. That's
14 the only comment. We'll be happy to answer it
15 right now. Would anyone else like to make any
16 formal comments for the record?
17 MS. HAERER: My name is Carol
1.8 Haerer and I'm also a member of WHIPS and the
19 concern about the blasting at the Daley mine
20 site three-quarters of a mile from Tansitor.
21 We would like to request that monitoring well
22 be drilled along the upper east side of
23 Whipstock Hill to a depth of the final
24 elevation of the mine floor and that the
25 monitoring wells be drilled along the rock
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1 fractures in the same area.
2 MS. O'DONNELL: Thank you. Anyone
3 else?
4 MR. REED: My name is Robert Reed.
5 I drink the water in the area and that's how
6 I'm related to it. One thing I'm concerned
7 about is in this first page it says these
8 recommendations are based on current
9 groundwater and site conditions. I realize
10 the site is just the Tansitor property, but I
11 think when you have a rock mine less than
12 three-quarters of a mile in distance from the
13 contaminated area which is going to last for
14 70-some-odd years with blasting going on/
15 et cetera, and pumping out several hundred
16 thousand gallons of water every day, the
17 existing positions and the current groundwater
18 may change drastically. And my concern is
19 that this report is deficient because of the
20 changes that are upcoming.
21 MS. HAERER: Could I just add to
22 what he said, that the hydrologist that we
23 hired projects that up to 1.2 million gallons
24 of water will be pumped out of the mine site
25 each day, and this can't help but affect the
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groundwater.
MS. O'DONNELL: Thank you. Anyone
else like to make comments?
MR. KILLEN: I'd like to make a
comment. Carroll Killen, CARROLL,
KILLEN. I am a director of Tansitor..
I understand your concern. I
think that Terry didn't mention to you that
the till is so dense the water is not
traveling very fast. There's almost no water
in this area that we're talking about in the
contaminated area. When you get down further
you can find more water. But in the area
we're talking about, there's not.
Now, there has been no dumping at
this site since 1978. The contaminants that
were dumped there have either disappeared or
the remnants are not moving because there's
not water there that they can, that the
contaminants can attach itself to. Now this
material is not soluble in water, but it does
tend to attach itself to soil. So, if there
was a lot of water flowing by, it could affect
it. But the water is going into, whatever
water there, is going into the fire pond as
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has been stated. The fire pond has some very
healthy fish in it. It's been.tested and, as
Terry pointed out, that it's well within the
acceptable standards.
The bedrock aquifer as he talked
about is approximately 180 feet below the
surface of the site and it's protected by
dense overconsolidated clay or silt, glacial
till.
Now we have tested our wells,
we've tested all the wells in the area. All
the wells in the area as far as we know are in
bedrock and none of them show any
contamination. The chemical compounds of
concern as has been pointed out already are in
the uppermost approximately 30 feet of the
glacial till and a risk assessment performed
by the EPA demonstrated that within a one-mile
radius of the site there's no threat to the
supply wells screened in the bedrock aquifer.
Therefore/ the original concern were wells
located within a three-mile radius of the site
was unfounded.
I want to make this point that at
the time that our site was scored, the
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requirement caused the representatives and
contractors for the EPA to count all the wells
in a three-mile radius. The three-mile radius
took us up to North Bennington, took us down
to, on the other side of the mountain to,
well, whatever towns that were there, villages
or whatever, there's several of them. It took
us into North Bennington, I mean to Old
Bennington, it also took us toward Hoosick.
Now, the only place, the only place where
water could flow is toward Hoosick because
that's downhill from us. The area behind,
north of the Tansitor site is uphill. To the
south of us is the mountain. To the east of
us is uphill. So unless the water learned how
to go uphill, the only place it's going to go
is down toward Hoosick.
FROM THE FLOOR: That's where we
all live.
MR. KILLEN: Well, you're north of
there. But, at any rate, it hasn't gone
there.
They did do an extensive study of
the biological -- well, the environments in
that, that little stream that's there. They
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did not find any problem. I think you've got
a slide on that, too.
MS. O'DONNELL: Carroll, we'll try
to address the issue in terms of the blasting,
but we're really here tonight to accept
comments on the proposed alternative. And
during the normal part of the session we'll
attempt to address other questions relative to
our preferred alternative on what's going on
in the site.
MR. BREITHAUPT: Barton
Breithaupt. It sounds to me like the, under
the present conditions that the proposal would
be fine and adequate to take care of the
situation. But we're talking about a very
drastic change in the environment
three-fourths of a mile away. A tremendously
deep hole dug into the ground could cause that
water heading downhill to migrate at a much
faster rate.
MR. FARRARA: My name is Ray
Farrara, I'm from East Hoosick.
My .concern is that we have, we've
been working with this mine issue for a long
time, probably a year now, and I have been
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1 personally involved with this and I have asked
2 our own Department of Environmental
3 Conservation to consider the Superfund Site at
4 the Tansitor plant, and we've asked the State
5 of Vermont to consider the Superfund Site in
6 relation to the mine. And even though I'm
7 really glad to hear, Mr. Killen, that this
8 stuff isn't moving anyplace, I'm really glad,
9 and I'm glad to hear that it's in good soils
10 and all the rest. But I really think that
11 these two projects being so close to each
12 other and such a major impact, somebody needs
13 to really just say, time out, let's take a
14 look at what the two of them are going to do
15 to each other in terms of their geology. And
16 yet, what we're facing here is we're facing a,
17 you know, two states that really don't want to
18 get involved with each other. We're involved
19 with a lot of politics with the DEC that's
20 trying to push it through. And we here are
21 the residents who are very concerned. And
22 it's really good to hear that the stuff is in
23 this kind of soil or whatever it is. But
24 somebody needs to really take a look at the
25 two because when we're talking three-quarters
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1 of a mile, we might be talking about half a
2 mile, really, by the way the crow flies. And
3 when you're talking about water/ whether it is
4 uphill or downhill, you're talking about cones
5 -of influence with water, and water can'
6 migrate. And I just believe that the plan
7 that's been put forth through the seeker
8 process in New York State doesn't talk about
9 Tansitor at all. And we've asked them to talk
10 about that superfund site. And yet this now
11 knows that there's a possibility very shortly
12 of a huge mine, we're not talking about a
13 gravel pit, we're talking about a 77-acre mine
14 up to 500 feet deep, on the same piece of soil
15 where you're going to hear the rocks and the
16 blasting going. The two of them have got to
17 be either talked about together or somehow
18 stayed or something has to be done. It's
19 just, it can't be ignored, you know, and
20 whatnot. And so I really encourage this EPA
21 to contact New York State DEC and say, time
22 out, give us a chance to take a look at this
23 and see what it's doing.
24 MS. O'DONNELL: Thank you very
25 much.
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1 Any other comments?
2 FROM THE FLOOR: Yes, Ma'am.
3 MS. O'DONNELL: Would you please
4 identify yourself?
5 MS. HAERER: Yes. Carroll Haerer.
6 I'm not sure if this is
7 applicable, but we all know about the Burton
8 Iron Works which are in the vicinity, as well.
9 And I was just wondering if the EPA has
10 considered the old mine shafts that are .there
11 from the historic Burton Iron Works which are
12 in the area which may be between, possibly
13 between Tansitor and the mine's underground
14 shafts?
15 MS. O'DONNELL: Thank you.
16 Any other formal comments?
17 - Yes, sir. Would you please
18 identify yourself?
19 MR. KOBELIA: Yes, Ma'am name is
20 Bob Kobelia. I own property quite close to
21 the Tansitor site. And the only reason I
22 stopped in is because there has been a lot of
23 studies done on test wells and I don't see any
24 problems with the results from that. But I
25 have a. well that's 700 feet deep and no one
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has ever asked me for a water sample. And I'm
only, I'm not the closest neighbor, but I'm, I
can throw a rock to their boundary. So I
would think that if somebody wanted a deep
test, I've got probably one of the deepest
wells in the county. I'd be more than happy
to share my water instead of being a guinea
pig.
MS. O'DONNELL: Okay. Any further
comments ?
(No response from audience.)
MS. O'DONNELL: Given that there
aren't any, I would like to declare that the
formal part of tonight's hearing is over. And
what we would like to do is now formally
address some of the questions, particularly
with respect to the blasting, this gentleman's
questions relative to the 700-foot well/ any
questions that people have. So I'm going to
turn things over to Terry in terms of he's
more familiar with the blasting situation than
I am.
Oh, another comment?
MS. FINE: My name is Adelaide
Fine, I live in Shaftsbury.
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1 What is this alternative two? We
2 speak of this as being an alternative plan;
3 what is it an alternative to?
4 . MR. CONNELLY: Well, an .
5 alternative two is what we're proposing. We
6 have labeled that as alternative two, which
7 would be institutional controls on the
8 property --
9 MS. FINE: I don't mean -- when
10 you speak of an alternative, it strikes me,
11 speaking English, that there's something else
12 to which it was an alternative. So, what is
13 the original?
14 MR. CONNELLY: We looked at two
15 other alternatives. One where we did nothing
16 that's required by law. The other alternative
17 that we looked at is in addition to the
18 institutional control, installing wells into
19 the soils to pump out the contaminated
20 groundwater, to treat that contaminated
21 groundwater through a series of technologies,
22 and then to discharge that cleaned water back
23 on site.
24 MS. FINE: Okay. Thank you.
25 ' MS. O'DONNELL: And that was the
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alternative what?
MR. CONNELLY: That was what we
labeled as MM3.
Okay. That concludes our comment
portion and our transcription of this hearing.
{Question and answer portion of
hearing commenced. Comment
portion ended at 6:55 p.m.)
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CERTIFICATE
I, Linda C. O'Brien, Registered
Professional Reporter and Notary Public, do hereby
certify that the foregoing pages, numbered 2 through
34, inclusive, are a true and accurate transcription
of my stenographic notes of the proceedings in the.
matter of the.HEARING IN RE: EPA - PROPOSED PLAN FOR
THE TANSITOR ELECTRONICS SUPERFUND SITE/ taken before
me on Wednesday, March 22, 1995 for use in that
matter.
0-
.
Linda C. O'Brien,
Registered Professional Reporter
and Notary Public
My Commission expires:
February 10th, 1999
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