Superfund Record of Decision Burgess Brothers Landfill Woodford VT


                                    EPA/ROD/R01-98/127
                                    1998
EPA Superfund
     Record of Decision:
     BURGESS BROTHERS LANDFILL
     EPA ID: VTD003965415
     OU01
     WOODFORD, VT
     09/25/1998

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EPA 541-R98-127

                                   U.S. ENVIRONMENTAL PROTECTION AGENCY
                                           REGION  I  -  NEW ENGLAND
                                             RECORD  OF DECISION

                                                  for the

                                      BURGESS BROTHERS SUPERFUND SITE
                                     BENNINGTON AND WOODFORD,  VERMONT

                                               September  1998

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                                 BURGESS BROTHERS SUPERFUND SITE

                                        Table of Contents


I.      SITE NAME, LOCATION AND DESCRIPTION 	1

II.     SITE HISTORY AND ENFORCEMENT ACTIVITIES  	3

III.    COMMUNITY PARTICIPATION 	4

IV.     SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION  	5

V.      SUMMARY OF SITE, CHARACTERISTICS 	6
       A.   Source Area (Landfill and Lagoon Cells) 	6
       B.   Soil 	6
       C.   Groundwater 	7
       D.   Surface Water/Sediments 	9
       E.   Air  	10
       F.   Leachate 	10
       G.   Wetlands 	11

VI.     SUMMARY OF SITE RISKS 	11
       A.   Human Health Risk Assessment 	12
       B.   Baseline Ecological Risk Assessment  	14
       C.   Risk Assessment Conclusions 	16

VII.    DEVELOPMENT AND SCREENING OF ALTERNATIVES 	16
       A.   Statutory Reguirements/Response Objectives  	16
       B.   Technology and Alternative Development and  Screening 	18

VIII.   DESCRIPTION OF ALTERNATIVES  	19
       Alternative 1:  No Action 	20
       Alternative 2 - Capping and Lagoon Treatment/Natural Attenuation ....21
       Alternative 3 - Capping and Lagoon Treatment/Pump and Treat 	25
       Alternative 4 - Capping and Lagoon Treatment/Treatment Wall 	27

IX.     SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 	28
       A.   Evaluation Criteria 	28
       B.   Summary of the Comparative Analysis of Alternatives 	30

X.      THE SELECTED REMEDY 	35
       A.   Interim Groundwater Cleanup Levels  	35
       B.   Performance Levels for Surface Water and Sediment 	39
       C.   Description of Remedial Components  	41
            1.      Multi-Barrier Cap Over the Landfill Area  	42
            2.      Cap Over the Soils in the Marshy Area   	44
            3.      SVE/Air Sparging in the Former Lagoon Area   	45
            4.      Institutional Controls 	46
            5.      Long-Term Monitoring  	46
            6.      Operations and Maintenance   	47
            7.      Five-Year Review  	47
       D.   Contingency for Alternate Response Action 	47

XI.     STATUTORY DETERMINATIONS  	47

XII.    DOCUMENTATION OF SIGNIFICANT CHANGES 	56

XIII.   STATE ROLE 	57

APPENDICES

Appendix A      Tables  and Figures
Appendix B      Applicable or Relevant  and Appropriate  Reguirements (ARARs)
Appendix C      State  of Vermont  Declaration  of Concurrence
Appendix D      Administrative  Record  Index
Appendix E      Responsiveness  Summary

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DECLARATION FOR THE RECORD OF DECISION

BURGESS BROTHERS SUPERFUND SITE
Bennington and Woodford, Vermont

Statement of Purpose

This Decision Document presents the selected remedial action for the Burgess Brothers Superfund Site in
Bennington and Woodford, Vermont, developed in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended, 42 U.S.C. °° 9601 et. seg. , and the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP) as amended, 40 C.F.R. Part 300. The
Administrator for EPA New England has delegated the authority to approve this Record of Decision (ROD) to
the Director of the Office of Site Remediation and Restoration (OSRR).

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 Office of Site Remediation and Restoration Records Center in
Boston, Massachusetts. The Administrative Record Index (Appendix D 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 or to the environment.

Description of the Selected Remedy

This ROD sets forth the selected remedy for the Burgess Brothers Superfund Site which addresses both the
source control and the management of migration of contaminants from the Site. The remedial measures
described in this ROD will minimize further migration of contamination into the groundwater and surface
water, will eliminate the potential for direct contact and/or incidental ingestion of the material within
the landfill, will control landfill gas and prevent exposure to landfill gas containing hazardous
substances, and will replace any portion of wetlands destroyed as a result of implementing the selected
remedy.

The selected remedy consists of operating and maintaining controls to prevent exposure to contaminated
soil and to achieve the restoration of groundwater and the protection of surface water. The major
components of the selected remedy include.

• A multi-barrier (or "composite barrier") cap over the Landfill Area. The need for a gas
collection and treatment system will be evaluated during design.

• A cap over the soils in the Marshy Area. Any wetlands impacted by the installation of the cap
will be restored or replaced, preferably on-site, Cap specifications will be determined
during design.

• Hot spot remediation of the Former Lagoon Cells within the Landfill Area using soil vapor
extraction (SVE) and air sparging.

• Natural attenuation of contaminated groundwater beyond the area of influence of the SVE and
air sparging system.

• The establishment of institutional controls to protect the capped areas and to prevent the
use of groundwater potentially impacted by the Site, and to inform future purchasers of the
groundwater restrictions associated with the property. Restrictions on the use of groundwater
will include the current contaminant plume area and an associated buffer zone.

• Long-term monitoring of the groundwater, surface water, and sediments to evaluate the overall
effectiveness of the remedy.

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       •    A review of the Site every five years after the initiation of the remedial action to assure
            that the remedial action continues to protect human health and the environment.

Declaration

The selected remedy is protective of human health and the environment, attains federal and state
requirements that are applicable or relevant and appropriate for this remedial action, and is cost
effective. This remedy satisfies the statutory preference for remedies that utilize treatment as a
principal element to reduce the toxicity, mobility, or volume of hazardous substances. The selected
remedy is equally protective and more cost effective and implementable than the alternatives evaluated.
This remedy also utilizes permanent solutions and alternative treatment technoloqies to the maximum
extent practicable.

As this remedy will result in hazardous substances remaininq onsite above health-based levels, a review
will be conducted within five years after commencement of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and the environment.

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ROD DECISION SUMMARY
September 1998

I. SITE NAME, LOCATION AND DESCRIPTION

A. General Description

The Burgess Brothers Superfund Site (the "Site") is located in the towns of Woodford and Bennington,
Bennington County, Vermont, between Burgess Road and the Walloomsac Brook. (Appendix A, Figure 1). Access
to the Site is through the Burgess Brothers Construction Company's facility on Burgess Road,
approximately 1.1 miles southeast of the junction of Burgess Road and State Highway 9. The Green Mountain
National Forest borders the Site to the north. The latitude of the Site is 42!52'40" and the longitude is
73!09'00". The Site consists of approximately three acres located in the northeastern section of a
60-acre parcel which is owned by Clyde Burgess, Jr.

The Site includes the following six areas (see Appendix A, Figure 5):

• Landfill Area - which is the waste disposal area.

• Lagoon Area - former lagoon cells which are located within the Landfill Area. This area
consists of two former waste disposal cells where solvent and reserve energizer battery waste
were reportedly disposed.

• Soil Staging Area - located north of the Landfill Area.

• Area West of Landfill - includes the areas to the west of the Landfill Area, downslope of the
landfill, and in the vicinity of a temporary access Landfill Road.

• Marshy Area - located south and southeast downslope of the landfill and consists of several
small wetland areas.

• Hillside Area - includes areas upslope and to the east of the Marshy Area and Landfill Area
on Harmon Hill.

As stated above, the Site consists of approximately three acres. The Landfill Area occupies approximately
two acres which includes the two former Lagoon Cells. The Lagoon Area occupies approximately 4,000 square
feet (0.09 acres) of the landfill. The Marshy Area and area impacted by the contaminated groundwater
plume occupy approximately one acre beyond the Landfill Area. Both the landfill and lagoon cells have
been covered with clean soils from the Burgess Brothers property.

The primary land use in the vicinity of the site is undeveloped forest. Industrial, commercial, and
residential properties are located along Burgess Road, approximately one mile southwest of the Site.
Although Bennington, Vermont contains many historic structures, no cultural resources have been
identified in the immediate vicinity of the Site.

Two municipal water supply systems, Ryder Spring and Morgan Spring, are located within one mile of the
Site. These systems are operated by the Bennington Water Department. Two private drinking water wells
have been identified within one mile of the Site.

A new housing development is being constructed just north of the Site. This construction is not expected
to impact environmental conditions at the Site as the development will be connected to town water and
sewerage (Publicly Owned Treatment Works (POTW)).

Several drainage swales flow down from the Hillside Area into the Marshy Area, then southwesterly into an
unnamed stream. The unnamed stream flows southwesterly into Barney Brook which empties into the
Walloomsac River. Both Barney Brook and the Walloomsac River are classified by the State of Vermont as
Class B waters, which are defined as waters of a quality that consistently exhibit good aesthetic value
and provide high quality habitat for aquatic biota, fish, and wildlife. The uses of Class B waters are
public water supply (with filtration and disinfection), irrigation and other agricultural uses, swimming,
and recreation.

The groundwater at the Site is classified by the State of Vermont as Class III, defined as suitable for
individual domestic drinking water, irrigation, agricultural, and industrial/commercial use. Class I and
II waters are aquifers that are currently in use, or have probability of use, as a public drinking water
supply.

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A more complete description of the Site can be found in Section 1 of the July 1996 Remedial Investigation
Report.

B. Geology and Hydrology

Site geology consists of an unconsolidated overburden comprised of a kame sand and ablation glacial till,
underlain by a lodgement till, underlain by bedrock (Appendix A, Figure 2). Combined, the kame sand and
ablation glacial till are up to 35 feet thick. The lodgement till, which separates the kame sand and
ablation glacial till from the bedrock, is approximately 35 to 90 feet thick. Bedrock consists of shallow
weathered bedrock, deep weathered bedrock, and competent bedrock. The weathered bedrock consists of
weathered schist and gneiss. The competent bedrock, found at upwards of 400 feet in depth, consists of
massive to thickly bedded guartzite with freguent high angle fractures.

The Site contains two groundwater flow paths. Shallow groundwater flow in the kame sand and ablation
glacial till is generally from the landfill to the south-southeastward into the Marshy Area. The shallow
groundwater in the Marshy Area discharges to a drainage Swale (Swale 2) (Appendix A, Figure 3). Deep
groundwater flow in the weathered and competent bedrock is towards the west-southwest, generally
following the hill slope topography.

Groundwater elevation data indicate generally upward gradients in the kame sand and ablation glacial till
in the Marshy Area, with groundwater discharging to surface water. Vertical gradients in the Landfill
Area also appear to be slightly upward.

Additional information about the site geology and hydrology can be found in Section 2 of the July 1996
Remedial Investigation Report.

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. Land Use and Response History

Activities at the Site began as sand and gravel mining operations in the 1940s. Starting in the early
1950's the Site was used as a metal salvage facility and as a disposal area. Metals, sludges, and
rejected small appliance and military speciality batteries were also disposed at the Site. The two Lagoon
Cells (unlined pits) received liguid wastes and sludge from approximately 1967 to 1976. These wastes
consisted of lead sludges, lead contaminated wastewater, spent solvents (primarily PCE and TCE), and
battery waste. Manganese dioxide cells (containing zinc and mercury) were also disposed. Approximately
2,371,100 gallons of liguid waste and 241,090 pounds of solid or semi-solid wastes were disposed of at
the Site from 1971-1976. An unknown guantity of waste, primarily lead sludge, was also disposed of at the
Site from the 1960's through 1971.

Numerous investigations have been performed at the Site to evaluate the environmental impact of the
disposal operation which occurred in the Landfill Area and former Lagoon Cells. A listing of previous
site investigation activities is provided in Appendix A, Table 1.

The Vermont Department of Environmental Conservation (VTDEC) (then Vermont Agency of Environmental
Conservation (VTAEC)) conducted a Preliminary Assessment in 1985 and EPA proposed the Site for listing on
the National Priorities List (NPL) on June 24, 1988. On March 31, 1989 the Site was added to the NPL.

A Remedial Investigation/Feasibility Study (RI/FS) was begun at the Site in 1991 and completed in 1998.
The EPA completed a Baseline Risk Assessment in 1997. A more detailed discussion of the findings of the
investigations is provided in the July 1996 Remedial Investigation Report and the February 1997
Supplemental Remedial Investigation Report.

B. Enforcement History

VTAEC inspected the Site several times during the late 1960's and 1970's to evaluate disposal practices
and environmental impacts. In August 1976, VTAEC disallowed disposal operations at the Site.

From 1984 - 1989, preliminary investigations and periodic monitoring of soil surface water, groundwater,
and leachate were performed by the State, EPA, and Union Carbide Corporation, as identified in Appendix
A, Table 1.

On May 10, 1991, EPA notified five parties of their potential liability with respect to the Site. These
parties either owned or operated the facility, generated wastes that were shipped to the facility,
arranged for the disposal of wastes at the facility, or transported wastes to the facility. These
parties consisted of Clyde Howe, owner, Clyde Burgess, Jr., operator, Union Carbide Corporation, Inc.,

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generator, Eveready Battery Company, Inc., generator, and Burgess Brothers Construction Company, Inc.,
generator and transporter. Negotiations commenced with these potentially responsible parties (PRPs)
regarding performance of a Remedial Investigation/Feasibility Study (RI/FS).

On August 13, 1991, EPA entered into an Administrative Order by Consent, U.S. EPA Region I CERCLA Docket
No. 1-90-1100, with Clyde Burgess, Jr., Burgess Brothers Construction Company, Inc., and Eveready Battery
Company, Inc. for the performance of an RI/FS. These three PRPs also agreed to reimburse EPA and the
State of Vermont for a portion of past costs under a separate Administrative Order by Consent, U.S. EPA
Region I CERCLA Docket No. 1-90-1101.

Pursuant to the Administrative Order by Consent, the settling PRPs retained a contractor and conducted
the RI/FS under EPA oversight.

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 fact sheets,
press releases, and public meetings. On June 10, 1998, EPA issued a Proposed Plan for the cleanup of the
site.

On June 11, 1998, EPA published a notice and brief analysis of the Proposed Plan in the Bennington
Banner. On June 15, 1998 EPA made the Proposed Plan and Administrative Record available to the public by
placing a copy in the Bennington Free Library, Bennington, Vermont, and at EPA's office in Boston. On
June 23, 1998, EPA held an informational meeting/public hearing at the Bennington Free Library to discuss
the results of the Remedial Investigation and the cleanup alternatives presented in the Feasibility
Study. During this meeting EPA presented the Proposed Plan and accepted oral comments. The public comment
period ran from June 15 through July 15, 1998. A transcript of this meeting, the comments EPA received,
and EPA's responses to the those comments are included in the responsiveness summary in Appendix E.

IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION

The entire site has been addressed as a single operable unit, addressing both source control and
management of migration to obtain a comprehensive approach for Site remediation. The selected remedy was
developed by combining various components of different source control and management of migration
alternatives. 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:

• A multi-barrier (or "composite barrier") cap over the Landfill Area. The need for a gas
collection and treatment system will be evaluated during design.

• A cap over the soils in the Marshy Area. Any wetlands impacted by the installation of the cap
will be restored or replaced, preferably on-site. Cap specifications will be determined
during design.

• Hot spot remediation of the Former Lagoon Cells within the Landfill Area using soil vapor
extraction (SVE) and air sparging.

• Natural attenuation of contaminated groundwater beyond the area of influence of the SVE and
air sparging system.

• Long-term monitoring of the groundwater, surface water, and sediments to evaluate the overall
effectiveness of the remedy.

• A review of the Site every five years after the initiation of the remedial action to assure
that the remedial action continues to protect human health and the environment.

Remedial activities at the Site are comprehensive and intended to be a final remedy.

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V. SUMMARY OF SITE CHARACTERISTICS

Sections 2.4 and 2.5 of the Feasibility Study Report contain an overview of the Remedial Investigation.
The significant findings of the Remedial Investigation are summarized below.

A. Source Area (Landfill and Lagoon Cells)

The source of contamination at the Site is a two acre landfill. From the 1950's into the 1970's, the
landfill received municipal type refuse, such as wood, newspaper, steel cardboard, and cinders. Starting
in the 1960's, the landfill also received small appliance batteries and lead sludge from the manufacture
of batteries. The landfilled materials are located within a kame sand deposit primarily above the
groundwater table, however, groundwater contamination does occur through snow melt and rain percolating
through the waste material then into the groundwater table. The primary contaminants are volatile organic
compounds (VOCs) and metals. The surface area of the landfill is approximately 60,000 sguare feet (1.4
acres) and the depth of the landfill ranges from 8 to 14 feet. The landfill's estimated volume is
approximately 27,000 cubic yards.

Within the landfill are two former Lagoon Cells. These former Lagoon Cells consist of two unlined pits
that received wastes such as lead plater sludge, reserve energizer battery processing waste, and spent
solvents. The Lagoon Cells are considered a "hot spot" within the landfill due to significantly elevated
levels of VOCs, semi-VOCs, and metals. Contaminants from the landfill, and specifically the Lagoon Cells,
have impacted the soil and groundwater within the Marshy Area which is located downslope and down
gradient. The areas of former Lagoon Cells 1 and 2 are estimated to be 960 square feet (0.02 acres) and
3,170 sguare feet (0.07 acres), respectively, and the average depth of each lagoon is 15 feet. The Lagoon
Cells combined estimated volume is approximately 2,300 cubic yards.

B. Soil

As stated above, elevated levels of VOCs, semi-VOCs, and metals are found within the landfill and, more
specifically, within the Lagoon Cells which are considered a "hot spot". To determine treatment
viability, a soil vapor extraction (SVE) pilot study was completed during October and November 1996 to
treat the soils within and surrounding the Lagoon Cells. The results of the pilot study indicate that SVE
would be a successful technology for removing contaminants within the unsaturated soils. The volume of
impacted soils from the former Lagoon Cells 1 and 2 is approximately 530 cubic yards and 1760 cubic
yards, respectively.

Outside the source area, the primary area of impacted soils is within the Marshy Area located downslope
and down gradient of the landfill (See Appendix A, Figure 5). Significantly elevated levels of VOCs,
semi-VOCs, and metals are all found within the Marshy Area. The Marshy Area soils appear to have been
impacted from historical disposal practices in the landfill and, specifically, in the Lagoon Cells.
Liguid wastes that were placed into the lagoon cells seeped through the landfill, into the Marshy Area
soils, and into Swale 2.

Small quantities of pesticides and PCBs were detected in surface and subsurface soils, primarily in the
former Lagoon Cell areas. The small quantities of pesticides and PCBs detected do not indicate the
presence of a pesticide or PCB source area that would pose a risk in groundwater, surface water, or
sediments.

C. Groundwater

Groundwater Contamination

Water which percolates through the landfill enters the overburden groundwater system, which is
groundwater above bedrock. Groundwater flow in this strata is generally from the Landfill Area to the
south-southeastward into the Marshy Area. Shallow groundwater in the Marshy Area discharges to Drainage
Swale 2. Topography and current groundwater flow patterns result in groundwater from the landfill and
Harmon Hill converging in the vicinity of Swale 2 (see Appendix A, Figure 4).

Elevated levels of VOCs are found in the overburden groundwater in the Landfill Area, Lagoon Cells,
Marshy Area, and downgradient of the landfill southwesterly towards well cluster W-09. The highest
concentrations of VOCs and metals are found within the Lagoon Cells and Marshy Area. The primary source
of VOCs and metals in shallow groundwater is the Landfill. Area, and in particular, the former Lagoon
Cells. Overall, the shallow groundwater contaminant plume is located within the kame sand/ablation
glacial till and has an areal extent of approximately 700 feet by 300 feet. The southeastern edge of the
plume is slightly east of Drainage Swale 2. The plume also extends slightly south of the W-09 well
cluster. The western limit of the contaminant plume is between a temporary well access road and well

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W-26T (see Appendix A, Figure 5).

Vertical flow paths indicate generally upward gradients in the kame sand and ablation glacial till in the
Marshy Area, with groundwater discharging to surface water. Available data on vertical gradients in the
Landfill Area also indicate a slightly upward gradient. A dense lodgement till separates the kame
sand/ablation glacial till from the deeper bedrock. This dense till along with generally upward
groundwater gradients suggests that dissolved phase contaminant migration from the kame sand/ablation
glacial till into the bedrock is not expected. Sampling has confirmed this as the bedrock groundwater
does not appear to be impacted by site related contaminants.

Two residential drinking water wells and two public water supplies, Ryder Spring and Morgan Spring were
sampled during this remedial investigation. No site related contaminants were detected in any of these
drinking water supplies.

Potential for DNAPL

There is a potential for a dense, non-agueous phase liguid (DNAPL) to be present at the Site.
Concentrations of trichloroethylene (TCE) were detected in the Lagoon Cell sludges above the solubility
limit for TCE, suggesting the potential for a DNAPL. Concentrations of VOCs were detected in groundwater
at up to 14% of their solubility which may be indicative of a DNAPL, however, it was not observed at any
well locations.

Concentrations of VOCs were up to two orders of magnitude lower in the ablation glacial till than in the
upper strata of kame sand and were significantly lower than the solubility limit. The lower levels of
VOCs detected in the ablation glacial till indicate that if a DNAPL is present, it is limited to the
upper layer of kame sand. Based on the distribution of VOCs, the potential for DNAPL appears to be
localized within the immediate vicinity of the former Lagoon Cells and the northeast portion of the
Landfill Area near well SBW-21. (Appendix A, Figure 5)

Contaminant Migration

VOC migration in groundwater is primarily through dissolved phase transport. The primary direction of VOC
contaminant migration is from the Landfill Area towards the south-southeast into the Marshy Area. The
extent of the groundwater VOC plume in the south-southeast direction appears to be constrained by
discharge of contaminated groundwater to surface water in Marshy Area sediments. Limited migration of
VOCs is observed towards the west, which is likely associated with dispersion because groundwater flow is
generally towards the south southeast.

As stated above, the concentrations of VOCs detected in groundwater indicate the potential of DNAPL. If
present, DNAPL migration in the kame sand would be downward under gravity. Lateral dispersion and
adsorption of DNAPL, in conjunction with downward migration, would continue until the ablation glacial
till is encountered, which would serve as a confining layer. Based on till contour maps (see Appendix A
Figure 6) a DNAPL in the Landfill Area or former Lagoon Cells would be directed towards the Marshy Area.

The source of metals in shallow groundwater is the landfill, primarily the Lagoon Cell areas. Low flow
groundwater sampling indicates that metals in soils, with the exception of iron, manganese and thallium,
are generally insoluble and immobile in groundwater. The groundwater metals plume, with the exception of
iron, manganese, and thallium, is limited to the immediate vicinity of the landfill.

The dense lodgement till layer between the overburden material and bedrock is likely a barrier to
vertical migration of contaminants. In addition, vertical gradients in the kame sand and ablation glacial
till appear to be upward. Therefore, migration of dissolved phase contaminants into the shallow and deep
weathered bedrock and competent bedrock is not expected.

D. Surface Water/Sediments

Surface Water

Elevated levels of VOCs were found in the surface water in Swale 2 next to the Landfill Area and Marshy
Area. VOC concentrations decreased downstream in Swale 2 and the Unnamed Stream. VOCs were not detected
in Barney Brook above State and Federal water guality standards.

Metal concentrations above State and Federal water guality standards were highest in Swale 2 next to the
Landfill Area and Marshy Area. Metal concentrations also decreased downstream in Swale 2, the Unnamed
Stream, and Barney Brook. Concentrations of lead, mercury, nickel, and zinc were detected above the
National Oceanic and Atmospheric Administration (NOAA) Effects Range Low (ER-L) concentrations; in

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surface water samples next to the Landfill Area and Marshy Area. The impacts to surface water quality is
reduced, however, as the stream flows toward Barney Brook.

The source of VOCs and metals in surface water is from landfill leachate seeps and groundwater discharge
to surface water.

Sediments

VOCs were also detected in sediments with concentrations being the highest next to the Landfill Area and
Marshy Area and decreasing downstream. The concentrations of VOCs detected in groundwater and surface
water were generally higher than those detected in sediment suggesting that the VOCs detected in sediment
samples are likely associated with groundwater entrained in soil particles.

Metal concentrations have been compared with NOAA ER-Ls. Metals were not detected in the downstream
sample locations above these levels, indicating that the extent of impacts to sediment is limited to
within the Marshy Area downslope and downgradient of the landfill. The likely source of metals in
sediment is from landfill leachate seeps and from surface transport of soils downslope from the landfill
via surface water runoff.

Contaminant Migration

VOCs in surface water likely volatilize to the atmosphere or undergo biodegradation or photodegradation.
The downstream edge of the VOC plume in surface water is between sampling locations SW-15 and SW-04 in
the unnamed stream. Because VOCs in surface water tend to volatilize rapidly, they are not likely to
partition to sediments.

The concentrations of metals in surface water were highest in the Landfill Area and decrease downstream
in Swale 2 and the Unnamed Stream and Barney Brook. A similar suite of metals were detected in soil
samples from the Landfill Area and former Lagoon Cells, and Marshy Area soils. This trend suggests that
the impact to surface water quality originates in the Landfill Area and is reduced as the stream flows
toward Barney Brook. However, some metals, including antimony, lead and silver are present at all
locations at similar concentrations. A contributing source of these metals may be natural and not related
to impacts from the landfill.

VOCs were detected in sediment samples from drainage Swale 2, however, they are likely associated with
groundwater entrained in the soil particles. Concentrations of lead, mercury, nickel, and zinc were
detected above NOAA ER-L concentrations in stream sediments from the Landfill Area. Metals were not
detected in downstream sampling locations above NOAA ER-L levels, indicating that these metals are
relatively immobile. The source of metals is likely from leachate seeps in the landfill.

A complete discussion of Site characteristics can be found in the July 1996 Remedial Investigation Report
in Sections 2, 3, 4, and 5 and in the February 1997 Supplemental Remedial Investigation Report, Sections
3, 4, and 5.

E. Air

An air quality assessment was performed as part of the RI. This included the use of field instruments to
provide an initial screening of potential gas emissions on December 30, 1991 and a quantitative analysis
of ambient air using an eight hour sampling device on October 14, 1992. These air studies confirmed that
no significant concentrations of site-related residues were being transported from the Site via air
transport at concentrations that would impact public health.

F. Leachate

VOCs and metals were detected in leachate above State and Federal water quality standards. These VOCs and
metals were also detected in the Landfill Area and particularly in the Lagoon Area soils and groundwater
samples. The highest concentrations were at a location immediately downslope and down gradient of the
former Lagoon Cells at leachate seep LS-03. (see Appendix A, Figure 5). The source of VOCs and metals in
leachate is the Landfill Area, and particularly the former Lagoon Cells.

G. Wetlands

Ecological studies at the Site included a cover type analysis, wildlife receptor and habitat evaluation,
wetland delineation, a water quality survey, and a bioassessment of benthic macroinvertebrates. Habitats
at the Burgess Brothers Site consist of mixed deciduous forest with limited shrub cover, palustrine
forested wetlands, and streams.

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Several shallow intermittent drainage swales are present along the steep upgradient areas of the Hillside
Area to the east of the Site. These swales flow towards the eastern edge of the landfill then southerly
to the unnamed stream. One of the drainage swales, Swale 2, had deposits of orange oxides evident where
landfill leachate enters the swale. The swales converge in a low lying area to create several small
wetland areas.

The wetlands are primarily mixed deciduous/conifer forest but with a more open canopy and associated
shrub cover than found in the forested area surrounding the site. The wetlands and swales flow into a
perennial unnamed stream, then into Barney Brook.

Significant natural communities or threatened and endangered species are not known to be present at the
Burgess Brothers Site or in nearby Barney Brook.

A complete discussion of Site characteristics can be found in the Remedial Investigation Report in
Sections 2, 3, 4, and 5.

VI. SUMMARY OF SITE RISKS

EPA performed both a human health and ecological baseline Risk Assessment to estimate the probability and
magnitude of potential adverse human health and ecological effects from exposure to contaminants
associated with the Site. The human health risk assessment followed a four step process: 1) contaminant
identification, which identified those hazardous substances which, given the specifics of the Site, were
of significant concern; 2) exposure assessment, which identified actual or potential exposure pathways,
characterized the potentially exposed populations, and determined the extent of possible exposure; 3)
toxicity assessment, which considered the types and magnitude of adverse health effects associated with
exposure to hazardous substances; and 4) risk characterization, which integrated the three earlier steps
to summarize the potential and actual risks posed by hazardous substances at the Site, including
carcinogenic and non-carcinogenic risks. The results of the human health risk assessment for the Burgess
Brothers Site are discussed below followed by the conclusions of the ecological risk assessment.

A. Human Health Risk Assessment

The 79 Contaminants of Concern (COCs) presented in Table 2, Appendix A, constitute a representative
subset of a the contaminants identified at the Site during the Remedial Investigation (RI). These include
11 surface soil, 14 subsurface soil, 16 shallow groundwater, 4 deep groundwater, 7 sediment, 13 surface
water, 11 leachate, and 3 ambient air COCs. The COCs were selected to represent potential Site related
hazards based on toxicity, concentration, freguency of detection, and mobility and persistence in the
environment. A summary of the health effects of each COG is located in Appendix, C of the Final Risk
Assessment Report (April 1997).

Potential human health effects associated with exposure to the COCs were estimated guantitatively or
gualitatively through the development of several hypothetical exposure pathways. These pathways were
developed to reflect the potential for exposure to hazardous substances based on present uses, potential
future uses, and the location of the Site. At present, the site consists of a landfill that includes two
former waste lagoons. Sand and gravel mining and metal salvage operations are conducted on an area
abutting the Site. The Site is also used by hunters of small game as it abuts a state forest and access
is not restricted. Conseguently, current exposure to site contaminants is believed to be to site
trespassers, hunters, and site employees. These receptor populations are thought to have occasional
contact with surface soils, sediments and surface water. Quantitative assessments of exposure via
incidental ingestion of surface soils and sediments were performed whereas gualitative assessments were
performed for dermal contact with surface soils, sediments, and incidental ingestion and dermal contact
with surface water. Incidental ingestion by site workers of sub-surface soils was also evaluated
guantitatively in the risk assessment.

Although future site use is not expected to change, portions of the site may support residential
development in the future (areas beyond the landfill and wetlands). Thus, surface soils at the site
(beyond the landfill and wetlands) were also considered as sources of potential exposure via incidental
ingestion by a young child (0-6 yrs) and guantitatively evaluated in the risk assessment.

While groundwater is used as a potable water supply by residents in the area, sampling of private wells
to date has not indicated that site contaminants are currently impacting nearby water supplies. Since the
potential exists for site contaminants to impact drinking water supplies in the future, ingestion of
contaminated groundwater was considered as a future potential exposure and guantitatively evaluated in
the risk assessment. Dermal contact and inhalation of VOCs from domestic use of contaminated groundwater
were also evaluated as a future potential exposure pathway but only gualitatively in the risk assessment.

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Qualitative evaluations of exposure were performed for dermal exposure to soils and sediments, inhalation
of VOCs and SVOCs from soils and surface water, and exposures to leachate because of the lack of an EPA
endorsed approach to measure such exposure or the highly intermittent nature of the exposure.

For each exposure pathway quantitatively evaluated, an average and a reasonable maximum exposure estimate
was generated corresponding to exposure to the average and the maximum concentration detected in that
particular medium. Complete exposure pathway assumptions can be found in Tables 3-3 through 3-8 of the
Final Risk Assessment Report.

Excess lifetime cancer risks were determined for each exposure pathway by multiplying the exposure level
with the chemical-specific cancer potency factor. Cancer potency factors have been developed by EPA from
epidemiological or animal studies to reflect a conservative "upper bound" of the risk posed by
potentially carcinogenic compounds. That is, the true risk is unlikely to be greater than the risk
predicted. The resulting risk estimates are expressed in scientific notation as a probability (e.g, 1 x
10 -6 for 1/1,000,000) and indicate that an average individual is not likely to have greater than a one
in a million chance of developing cancer over 70 years as a result of site-related exposure to the
compound at the stated concentration. Current EPA practice considers carcinogenic risks to be additive
when assessing exposure to a mixture of hazardous substances.

A hazard quotient (HQ) was also calculated for each pathway as EPAs measure of the potential for
non-carcinogenic health effects. A hazard quotient is calculated by dividing the exposure level by the
reference dose (RfD) or other suitable benchmark for non-carcinogenic health effects for an individual
compound. Reference doses have been developed by EPA to protect sensitive individuals over the course of
a lifetime and they reflect a daily exposure level that is likely to be without an appreciable risk of an
adverse health effect. RfDs are derived from epidemiological or animal studies and incorporate
uncertainty factors to help ensure that adverse health effects will not occur. The hazard quotient is
often expressed as a single value (e.g. 0.3) indicating the ratio of the stated exposure as defined to
the reference dose value (in this example, the exposure as characterized is approximately one third of an
acceptable exposure level for the given compound). The hazard quotient is only considered additive for
compounds that have the same or similar toxic endpoint and the sum is referred to as the hazard index
(HI). (For example: The hazard quotient for a compound known to produce liver damage should not be added
to a second whose toxic endpoint is kidney damage).

Risk estimates developed in the Risk Assessment were considered by EPA in light of the Agency's mission
to protect public health and the environment. EPA generally considers cancer risks in excess of 10 -4 and
noncarcinogenic hazards in excess of unity in determining the need for remedial action at a Site. Tables
3 & 4 (in Appendix A) depict the carcinogenic and noncarcinogenic hazard summary for the contaminants of
concern, the mediums evaluated, and the present and potential future exposure pathways corresponding to
the average and the Reasonable Maximum Exposure (RME) scenarios. Appendix B of the Final Risk Assessment
report presents the chemical-specific risk estimates for each exposure pathway.

The greatest risks were projected for the future ingestion of shallow groundwater at the Site. Both
average (1 x 10 -3) and maximum (7 x 10 -2) cancer risk estimates exceed EPAs benchmark of 10 -4. Vinyl
chloride, tetrachloroethene, trichloroethene, and 1,1-dichloroethene are some of the key contributors to
these risk estimates.

The highest noncarcinogenic hazard potential (HI=300) was also projected with the ingestion of maximum
concentrations of shallow groundwater from wells at the Site. Both average (HI=20) and maximum (HI=300)
noncancer hazard estimates exceed EPAs benchmark of unity. Trichloroethene, 1,2-dichloroethene (total),
benzene, and tetrachloroethene as some of the key contributors to these risk estimates.

Inhalation of VOCs from domestic use of contaminated shallow groundwater would increase any risk
associated with residential groundwater use. Although no established toxicity value is available for
lead, a National Interim Primary Drinking Water Regulation (NIPDWR) is available (15 ug/1) and was used
as a comparison for risk evaluation purposes. Both average (30 ug/1) and maximum (72 ug/1) shallow
groundwater concentrations of lead exceeded the NIPDWR.

All carcinogenic and noncarcinogenic risk values estimated for consumption of groundwater from deeper
aquifers were below 10 -4 or a HK1 and were not determined to warrant a remedial action. Exposure to
surface and subsurface soils outside of the landfill boundary were below 10 -4 or a HK1 and were not
determined to warrant a remedial action. All carcinogenic and noncarcinogenic risk values estimated for
exposure to stream sediments and surface water were also below 10 -4 or a HK1. Low levels of VOCs were
measured in the air at the Site during invasive activities. Limited sampling precluded reliable estimates
of risks to receptor populations. Due to the isolated and inaccessible location and intermittent nature
of leachate areas, exposure of receptor populations to leachate was estimated qualitatively and was
determined to be within an acceptable risk range.

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B. Baseline Ecological Risk Assessment

An ecological risk assessment was also produced as part of the Burgess Brothers risk assessment,
beginning on page 4-1 of the Final Risk Assessment Report.

The ecological assessment analyzed potential risks associated with exposure of Site biota to contaminants
in four mediums of concern: surface waters of the swales and unnamed stream, leachate, stream sediments,
and surface soils. Available criteria and guidelines were reviewed for use as benchmark values for
evaluating chemical toxicity to ecological receptors. These guidelines include EPA Ambient Water Quality
Criteria (AWQC) and the Ontario Ministry of the Environment (MOE) sediment guidelines for comparison to
Site surface waters and sediment contaminant concentrations. Surface soil risk was evaluated by comparing
estimated exposure doses received by selected indicator species with applicable wildlife chronic no
observable effect level (NOEL) toxicity values.

Surface water and leachate COCs for which no criteria exist were evaluated by searching the Aguatic
Information Retrieval (AQUIRE) database for applicable toxicity information. In the absence of a MOE
sediment guideline for a particular organic contaminant, a sediment guality value was calculated using
the eguilibrium partitioning method. Inorganics lacking MOE sediment guidelines were assessed by
comparing detected concentrations with the National Oceanic and Atmospheric Administration (NOAA)
sediment guidelines. Surface soils were evaluated by estimating exposure doses received by indicator
species (meadow vole, short-tailed shrew, and American robin). These doses were then compared with
toxicity data obtained in the scientific literature.

Overall evaluation of potential risk to ecological receptors is estimated in the ecological risk
assessment through the calculation of risk indexes. If the total risk index is greater than one, this
indicates that exposure to all COCs within that medium may pose a risk to organisms. The risk indexes for
the four mediums can be found in Tables 4-9 through 4-14 of the Final Risk Assessment Report.

The conclusions of the ecological risk assessment were as follows. Surface water guality in the unnamed
stream is impacted by elevated concentrations of silver and antimony, however, neither of these
inorganics, were found at elevated levels near the disposal area and may not be site related. Elevated
levels of organics (TCE and PCE) were found at a leachate seep. Sediment concentrations of nickel,
cadmium, manganese, and lead are elevated resulting in a slightly elevated risk (mean HI=7, max HI=22).
Concentrations of iron were also elevated in sediments, however, it appears that these levels may be
naturally occurring.

Risks to terrestrial species exposed to contaminants in surface soil was assessed by modeling exposure to
three indicator species. Concentrations of metals in the surface soils from outside the landfill area may
have a slight impact on shrews (insectivores) (HI=29) and meadow vole (herbivores) (HI=9). Higher trophic
levels (American robin) (HI=130) were found to have greater risks associated with soil contaminants at
the Site.

C. Risk Assessment Conclusions

In summary, the human health and ecological risk assessments indicate that 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, welfare, or the
environment. Specifically, the human health risk assessment identified future ingestion of shallow
groundwater as posing probable health risks exceeding EPA risk management criteria. In addition, exposure
to contaminants in surface soils outside of the landfill boundary may impact some wildlife species
foraging in those areas.

The response action selected in this ROD addresses the risks at the Site by minimizing the potential for
transfer of hazardous substances from the soil and solid waste into the groundwater, surface water, and
sediment; preventing direct contact with hazardous substances in the soil or solid waste; preventing
further migration of contaminated groundwater; restoring contaminated groundwater to drinking water
standards; and preventing ingestion of contaminated groundwater.

VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES

A. Statutory Requirements/Response Objectives

Under its legal authorities, EPA's primary responsibility at Superfund sites is to undertake remedial
actions that are protective of human health and the environment. In addition, Section 121 of CERCLA
establishes several other statutory reguirements and preferences, including: a reguirement that EPA's
remedial action, when complete, must comply with all federal and more stringent state environmental

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standards, requirements, criteria or limitations, unless a waiver is invoked; a requirement that EPA
select a remedial action that is cost effective and that utilizes permanent solutions and alternative
treatment technoloqies or resource recovery technoloqies to the maximum extent practicable; and a
preference for remedies in which treatment which permanently and siqnificantly reduces the volume,
toxicity or mobility of the hazardous substances is a principal element over remedies not involvinq such
treatment. Response action alternatives were developed to be consistent with these Conqressional
mandates.

Based on preliminary information relatinq to types of contaminants, environmental media of concern, and
potential exposure pathways, remedial action objectives were developed to aid in the development and
screeninq of alternatives. These remedial action objectives were developed to mitiqate existinq and
future potential threats to public health and the environment. These response objectives were:
Landfill:
       •     Prevent, to the extent practicable, the potential for water to contact or infiltrate throuqh
            the debris mass and laqoon.

       •     Prevent, to the extent practicable, the qeneration of landfill seeps and the miqration of
            landfill impacted surface water into the unnamed streams adjacent to the landfill (Marshy
            Area).

       •     Control landfill qas emissions so methane qas does not present an explosion hazard;  prevent,
            to the extent practicable, the inhalation of landfill qas containinq hazardous substances,
            pollutants or contaminants; and meet state and federal air standards.

       •     Prevent, to the extent practicable, the miqration of contaminated qroundwater/ leachate
            beyond the points of compliance by controllinq the source of the contamination.

       •     Minimize the potential for slope failure of the debris mass associated with the landfill cap.

       •     Prevent, to the extent practicable, direct contact with and inqestion of soil/debris within
            the landfill and beneath the landfill.

       •     Control, to the extent practicable, surface water runoff to minimize erosion.

       •     Prevent, to the extent practicable, the miqration of contamination from the laqoon area.

       •     Prevent, to the extent practicable, the saturation of the landfill debris mass from
            upqradient qroundwater.

Groundwater:

       •     Prevent, to the extent practicable, the inqestion of landfill impacted bedrock qroundwater
            exceedinq MCLs, Vermont Primary Groundwater Quality Standards, or in their absence,  the more
            strinqent of an excess cancer risk of 1 x 10 -6 for each compound or a hazard quotient of
            unity for each noncarcinoqenic compound by any individual who may use the bedrock qroundwater
            or within an area that the qroundwater could become impacted as a result of pumpinq
            activities.

       •     Restore the bedrock qroundwater at the edqe of the Waste Manaqement Unit to: MCLs, Vermont
            Primary Groundwater Quality Standards, or in their absence, the more strinqent of an excess
            cancer risk of 1 x 10 -6 for each compound or a hazard quotient of unity for each
            noncarcinoqenic compound.

Surface Water:

       •     Protect off-site surface water by preventinq the occurrence of landfill impacted seeps.

       •     Prevent, to the extent practicable, ecoloqical impacts from contaminants in the Marshy Area.

       •     Meet federal and state applicable or relevant and appropriate requirements  (ARARs) for any
            surface water discharqe.

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Ecological:

• Protect surface water, to the extent practicable, from exceedances of the Ambient Water
Quality Criteria (AWQC) Acute and Chronic Standards.

• Protect sediments, to the extent practicable, from exceedances of the Aquatic Sediment
Quality Guidelines of the Ontario Ministry of 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 ranqe of alternatives was developed for the Site.

EPA has established the concept of a presumptive remedy as a mechanism to streamline Site studies and
cleanup actions. The objective of the presumptive remedies approach is to use cleanup techniques shown to
be effective in the past at similar sites. Presumptive remedies are expected to be used at all
appropriate sites except under unusual circumstances. EPA's "Presumptive Remedy for CERCLA Municipal
Landfill Sites" establishes containment as the presumptive remedy for CERCLA municipal landfills and this
guidance was evaluated during the screening of alternatives for this Site.

Because the Site does not fall into the definition of a municipal landfill, the Feasibility Study
included an evaluation of excavation/disposal as well as containment as potential remedies for the
landfill. Excavation/disposal was considered due to the relatively small size of the landfill
(approximately 27,000 yd 3), however, this alternative was eliminated in the initial screening process
due to high costs and short term hazards. The containment alternative was carried throughout the
Feasibility Study. The two lagoons, which accepted principally industrial wastes, were determined to be
hot spots that require additional remedial responses to reduce the toxicity, mobility, or volume of
hazardous substances.

As discussed in Section 4 of the Feasibility Study, the RI/FS identified, assessed, and screened
technologies based on implementability, effectiveness, and cost. These technologies were combined into
remedial alternatives which included source control and management of migration components. 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. Section 5 of the Feasibility Study presented the remedial
alternatives developed by combining the technologies identified in the previous screening process in the
categories identified in Section 300.430(e)(3) of the NCP.

In summary, the various source control and management of migration remedial alternatives presented and
screened in Section 5 of the Feasibility Study were combined to obtain four comprehensive alternatives
for detailed analysis. Section 6 of the Feasibility Study Report presents the detailed analysis of these
four alternatives.

VIII. DESCRIPTION OF ALTERNATIVES

This Section provides a narrative summary of each alternative evaluated. A detailed assessment of each
alternative can be found in Section 6.0 of the Feasibility Study Repot.

The remedial alternatives that underwent detailed analysis for the Site are the following:

Alternative 1 - No Action
• Groundwater, surface water and leachate monitoring

Alternative 2 - Capping and Lagoon Treatment/Natural Attenuation
• Groundwater, surface water and sediment monitoring
• Institutional controls, such as a deed notice
• Capping and Lagoon Treatment
• Natural Attenuation

Alternative 3 - Capping and Lagoon Treatment/Pump and Treat
• Groundwater, surface water and sediment monitoring
• Institutional controls, such as a deed notice
• Capping and Lagoon Treatment
• Pump and Treat

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Alternative 4 - Capping and Lagoon Treatment/Treatment Wall
• Groundwater, surface water and sediment monitoring
• Institutional controls, such as a deed notice
• Capping and Lagoon Treatment
Treatment Wall

All of the alternatives include long-term environmental monitoring and five-year reviews. All of the
alternatives, except for Alternative 1 (No Action), include institutional controls to prevent the use of
contaminated groundwater and to protect the containment system.

Alternative 1: No Action

The no action alternative was evaluated in detail in the Feasibility Study to serve as a baseline for
evaluating other remedial alternatives under consideration. Under this alternative, no treatment or
containment of the landfill, lagoons, or wetland areas would occur and no effort would be made to treat
or prevent the further migration of contaminated groundwater. There would also be no access restrictions
or institutional controls to prevent the use of contaminated groundwater. Groundwater, surface water, and
leachate would be periodically monitored at the Site for a period of 30 years and would undergo an
evaluation of data every five years.

Estimated Time for Design and Construction: Not Applicable
Estimated Capital Cost: $0
Estimated Operation and Maintenance Cost (net present worth): $930,000
Estimated Total Cost (net present worth): $930,000

1 Note: Estimated costs for each alternative are based on 30 years of operation and a 7%
interest rate.

Alternative 2 - Capping and Lagoon Treatment/Natural Attenuation

Alternative 2 would consist of the following components:
• Construction and maintenance of a multi-barrier cap over the Landfill Area.
• Construction and maintenance of a cap over soils in the Marshy Area.
• Implementation of SVE/air sparging in the former Lagoon Cells.
• Institutional controls, such as a deed notice and the installation of a perimeter industrial
fence.
• Natural Attenuation: modeling and evaluation of contaminant degradation rates and pathways.

Each component is discussed below:

Multi-barrier Cap Over the Landfill Area

The multi-barrier cap would consist of covering the landfill and lagoons (approximately 2 acres) with
multi-layer caps, consistent with the RCRA Subtitle C reguirements listed in 40 CFR (Part 264). A typical
multi-layer cap, as would be reguired at this Site, would consist of (from top to bottom) :

• six inches of topsoil to support a vegetative cover.
• 30 inches of soil fill to provide a root zone and protection for the underlying components or
18 inches of soil if using sand for drainage.
• a nonwoven geotextile filter fabric to minimize fill material from clogging the drainage
layer.
• a geonet/geotextile drainage layer or 12 inches of sand to prevent ponding of water over the
synthetic barrier.
• a 60 mil very low density polyethylene (VLDPE) or eguivalent to act as the main barrier that
prevents water from infiltrating into the landfill.
• a low hydraulic conductivity geosynthetic clay liner to minimize potential leakage throughout
the low hydraulic conductivity geomembrane into the landfill.
• a base layer of six inches of silt or silty sand to establish a base grade for the landfill
cap.

The above cap would be utilized for all areas having slopes of less than or egual to 5%. For all side
slope areas, designed with a 3:1 slope, a minor variation of the base liner design would be implemented.
From top to bottom, the side slope cap would consist of

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• a nonwoven geotextile filter fabric to minimize fill material from clogging the drainage
layer.
• a geonet/geotextile drainage layer or 12 inches of sand to prevent ponding of water over the
synthetic barrier.
• a textured geomembrane, 60 mil very low density polyethylene (VLDPE) or eguivalent to act as
the main barrier which prevents water infiltration from entering the landfill.
• a base layer of six inches of silt or silty sand to establish a base grade for the landfill
and enhance side slope stability.

Landfill gas system reguirements for the landfill have been evaluated in accordance with USEPA's New
Source Performance Standards (NSPS) for Municipal Solid Waste (MSW) Landfills (40 CFR Part 60 Subpart
WWW). Although not directly applicable, the NSPS test method was employed as a preliminary screen to
evaluate whether a passive or an active gas system should be used.

Emission rates of three compounds versus the VTDEC action levels were evaluated using the NSPS method and
soil gas data collected as part of the RI. These compounds were TCE, PCE, and toluene. The highest
concentration detected in soil gas within the landfill, but outside of the former Lagoon Cells, were used
as parameters. Data collected from within the former Lagoon Cells was excluded because the SVE system
would collect and treat all soil gas generated in this area.

The preliminary screening found emission rates for the three compounds were a minimum of three orders of
magnitude below the action levels for each compound. If confirmed, a passive gas management system would
likely be a component of the multi-barrier cap. Further evaluation of landfill gas generation will
determine the need for a passive or an active landfill gas management system. Post-construction sampling
pursuant to a Demonstration of Compliance Plan, to be prepared during the remedial design, will determine
whether treatment of landfill gas will be reguired.

Capping of the Soils in the Marshy Area

The cap over the marshy area soils would be constructed using either an impermeable or permeable barrier.
For costing purposes, the evaluation of the single-barrier cap was performed based on the following
cross-section (from top to bottom) described below. The specific type of cap would be determined during
design.

• Approximately four inches of topsoil
• Approximately twelve inches of drainage sand
• 40 mil HOPE geomembrane
• Geocomposite drainage material
• Approximately two feet of soil as a subbase

Again, the type of cap would be determined during design. Factors such as constructability, maintenance,
and ability to achieve remedial action objectives would be used in the selection process.

The cap would cover approximately one-half acre area of wetlands, eliminating the potential for direct
contact and providing a barrier against animals burrowing into the Marshy Area soils. To stabilize the
topsoil cover, the area would be completed with approximately 4-inches of topsoil and hydroseeded. To
promote positive drainage from the area, existing soils would be shaped to achieve a minimum 3% grade
toward drainage swales that would be constructed as part of the multi-layer landfill cap.

All wetlands reguired to be capped would be replicated. The wetlands would be constructed on the Burgess
Brothers property, if feasible. The exact location and construction of wetlands replication would be
determined during design under a site specific Wetlands Mitigation Plan.

SVE and Air Sparging in Lagoon Cells

An SVE system, in conjunction with an air sparging system, would be used to remediate soils in the Lagoon
Cells. The air sparging system would remediate saturated zone soils by forcing air into the groundwater
beneath the lagoons. The induced air flow produced by the air sparging system would accelerate the
volatilization of the VOCs in the saturated zone, pushing the VOCs upwards into the soils in the
unsaturated zone.

Air extraction wells would then be used to remove VOCs from the unsaturated zone as part of the SVE
system. VOCs would be removed by inducing an air flow in the subsurface, producing, in effect, a
subsurface vacuum. VOCs contained within the unsaturated zone would be pulled into the air extraction
wells where they would be removed from the subsurface for treatment.

An SVE pilot study was performed at the site in 1996 which consisted of six extraction wells and two

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vapor extraction units. The off-gas treatment was activated carbon which proved to be sufficient. While
the type of off-gas treatment for the SVE/air sparging system would be selected during design, for
costing purposes it was assumed to be activated carbon.

It is anticipated that it would be necessary to operate the SVE/air sparging system continuously for a
period of six months to two years, then periodically over a period of perhaps several years to remove the
estimated guantity of VOCs from the former Lagoon Cells. Once contaminant levels were adeguately reduced,
the system would be shut down for a period of time, then restarted to ensure contaminant levels had not
increased. This shutting down and restarting process would be done several times over a period of time to
ensure contaminant levels were not increasing during periods of shut down. Over time, contaminant levels
would be expected to decrease to levels where the SVE/air sparging system could be discontinued. If DNAPL
is determined to be present, however, the SVE/air sparging may not completely remove the VOC source and
an alternate treatment approach would be evaluated.

Institutional Controls

A deed notice or other institutional controls would be used to ensure future site uses are consistent
with potential risks, do not endanger the integrity of the remedy, and restrict impacted groundwater from
being used as a drinking water source until the remedial action objectives have been met. Access to the
Site would also be restricted, reducing potential risks from contact with the landfill and to protect the
cap from damage that could be caused by unauthorized vehicles traveling over the landfill.

Natural Attenuation: Modeling and Evaluation of Contaminant Degradation Rates and Pathways

Natural attenuation is the naturally occurring processes in the environment which act without human
intervention to reduce the mass, toxicity, mobility, volume, or concentration of contaminants. These in
situ processes include biodegradation, dispersion, dilution, sorption, volatilization, and/or chemical
and biological stabilization or destruction of contaminants. All of these processes play an integral role
in natural attenuation.

The natural attenuation portion of this alternative includes a guantitative evaluation to estimate the
time frame for achieving the remedial action objectives. Three-dimensional modeling was performed to
simulate how contaminants in groundwater would react to source control activities, Future groundwater
monitoring data would be used to recalibrate the model as necessary. The modeling effort used to evaluate
natural attenuation is presented in Appendix A of the Feasibility Study Report.

The results of the model simulations indicate that remedial action objectives would be achieved within
seven years of instituting source control measures. If DNAPLs are present, however, the time frame for
achieving the remedial action objectives could be longer.

Groundwater, surface water, and sediment would be periodically monitored at the Site for a period of 30
years and would undergo an evaluation of data every five years.

Estimated Time for Designated Construction 1 year
Estimated Capital Cost: $1,633,000
Estimated Operation and Maintenance Cost (net present worth): $1,941,000
Estimated Total Cost (net present worth): $3,600,000

Alternative 3 Capping and Lagoon Treatment/Pump and Treat

Alternative 3 would include a multi-barrier cap over the landfill, a cap over the soils in the Marshy
Area, an SVE/air sparging system for the Lagoon Area soils, institutional controls, and the installation
and operation of a system to extract and treat contaminated groundwater from the landfill area. The
groundwater treatment system would prevent further migration of contaminants and allow for the
restoration of downgradient aguifers to federal and state drinking water standards.

The source control measures consisting of a multi-barrier cap over the landfill, cap over the soils in
the Marshy Area, SVE/air sparging system for the Lagoon Area soils, and institutional controls are the
same as those described under Alternative 2. The management of migration measures for this Alternative,
however, would be different. Alternative 3's groundwater treatment system, pump and treat, would include
a collection trench, pretreatment for inorganics, treatment for organics, and discharge to surface water.
These elements are described below.

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Collection trench

Groundwater would be collected using a collection trench. The trench would be constructed to the depth of
the lodgement till (approximately 10-30 feet). Piping along with filter fabric, impermeable barriers, and
groundwater collection structures (i.e., manholes) would be installed through a biodegradable slurry'
placed into the trench to maintain the trench walls. Once installed, the trench would be backfilled with
crushed stone, displacing the majority of the biodegradable slurry. Due to the high water table in the
Marshy Area traditional trench construction would not be feasible. Biopolymer trenching technigues would
be used which would eliminate the need for shoring and dewatering, along with associated groundwater
treatment.

Pretreatment for Inorganics

Groundwater from the collection trench would first be treated for the removal of inorganics to improve
system efficiency as well as to satisfy discharge limits for metals. Groundwater would be pumped into an
egualization/settling tank then pass through a particle filter to remove large suspended solids (See
Figure 7, Appendix A). Inorganics would precipitate in a sludge that would be processed, characterized,
and appropriately disposed off-site.

Treatment for Organics (VOCs)

After inorganic treatment, organics would be treated using an air stripper. Groundwater would be pumped
to the top of an air stripper and a blower would be used to force ambient air counter to the water flow.
The water would then be pumped through liguid-phase carbon to reduce the concentrations of residual VOCs
as well as inorganics.

The ambient air forced through the treated groundwater would be treated prior to discharge. The type of
off-gas treatment would be selected during pre-design. For costing purposes, it was assumed that
activated carbon would be used to treat the off-gas.

Discharge to Surface Water

Treated groundwater would be discharged to the unnamed stream. The exact point of surface water discharge
would be determined during the design phase. For cost estimating purposes, a discharge point located 100
feet from the treatment plant was assumed.

Modeling indicates that the groundwater remedial objectives would be achieved in approximately seven
years. The treatment system was, therefore, anticipated to operate for seven years or less. During that
time, residual VOCs and inorganics in groundwater would be treated to prevent migration beyond the
compliance boundary. However, if DNAPLs are present, the groundwater pump and treat system could need to
be operated indefinitely to achieve the remedial action objectives.

Groundwater, surface water, and sediment would be periodically monitored at the Site for a period of 30
years and would undergo an evaluation of data every five years.

Estimated Time for Design and Construction 2 years
Estimated Capital Cost: $3,112,000
Estimated Operation and Maintenance Cost (net present worth): $2,838,000
Estimated Total Cost (net present worth): $6,000,000

Alternative 4 - Capping and Lagoon Treatment/Treatment Wall

Alternative 4 would include a multi-barrier cap over the landfill, a cap over the soils in the Marshy
Area, an SVE/air sparging system for the Lagoon Area soils, institutional controls, and the installation
of a treatment wall to treat contaminated groundwater from the Landfill Area. The groundwater treatment
system would prevent migration of contaminants from the Landfill Area and allow for the restoration of
down gradient aguifers to federal and state drinking water standards.

The multi-barrier cap over the landfill, cap over the soils in the Marshy Area, SVE/air sparging system
for the Lagoon Area soils, and institutional controls are all the same as those described under
Alternative 2. This Alternative differs from the others in that the groundwater treatment system, a
treatment wall, would include the construction and maintenance of a subsurface permeable treatment wall
for the passive treatment of groundwater using in-situ iron materials to degrade VOCs.

-------
Treatment Wall

A treatment wall is an innovative technology consisting of a permeable granular iron material installed
across the groundwater flow path. As groundwater flows through the treatment wall, the granular iron
would degrade halogenated organics into nontoxic by-products, such as hydrogen gas, ethenes, ethane, and
chloride in solution. The degradation would occur under natural groundwater flow conditions and would not
have any associated mechanical components.

The treatment wall would be constructed to the depth of the lodgement till (approximately 10-30 feet) and
would be approximately 150 foot-wide and three feet thick. An additional 100 feet of slurry wall would be
installed at each end of the treatment wall to provide an "funnel and gate" effect (see Figure 8,
Appendix A). The actual dimensions would be determined during design.

Modeling indicates that after seven years the treatment wall would no longer be necessary to maintain
because the remedial action objectives will have been achieved upgradient of the treatment wall. If
additional time is reguired to obtain remedial action objectives, however, the effectiveness of the
treatment wall may diminish. If this occurs, the granular iron would be replaced in order maintain
effective groundwater treatment. If DNAPLs are present, the treatment wall would need to be maintained
indefinitely to achieve remedial action objectives.

Groundwater, surface water, and sediment would be periodically monitored at the Site for a period of 30
years and would undergo an evaluation of data every five years.

Estimated Time for Design and Construction 2 years
Estimated Capital Cost: $3,962,000
Estimated Operation and Maintenance Cost (net present worth): $1,875,000
Estimated Total Cost (net present worth): $5,800,000

IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

A. Evaluation Criteria

Section 121(b)(1) of CERCLA presents several factors that, at a minimum, EPA is reguired to consider in
its assessment of alternatives. Building upon these specific statutory mandates, the NCP articulates nine
evaluation criteria to be used in assessing the individual remedial
alternatives.

A detailed analysis was performed on the alternatives using the nine evaluation criteria in order to
select a Site remedy. The following is a summary of the comparison of each alternative's strength and
weakness with respect to the nine evaluation criteria. These criteria are summarized as follows:

Threshold Criteria

The two threshold criteria described below must be met in order for the alternatives to be eligible for
selection in accordance with the NCP.

1. Overall protection of human health and the environment addresses whether or not a remedy provides
adeguate 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 reguirements (ARARs) addresses whether or not a
remedy will meet all of the ARARs of Federal and State environmental laws and/or provide grounds for
invoking a waiver.

Primary 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. Implementitbility 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 and Maintenance (O&M) costs, as well as present-worth
costs.

Modifying Criteria

The modifying criteria are used in the final evaluation of remedial alternatives generally after EPA has
received public comment on the RI/FS and Proposed Plan.

8. State acceptance addresses the State's position and key concerns related to the preferred alternative
and other alternatives, and the State's comments on ARARs or the proposed use of waivers.

9. Community acceptance addresses the public's general response to the alternatives described in the
Proposed Plan and RI/FS report.

A detailed tabular assessment of each alternative according to the nine criteria can be found in Appendix
A, Table 5 of this Record of Decision.

Following the detailed analysis of each individual alternative, a comparative analysis, focusing on the
relative performance of each alternative against the nine criteria, was conducted. This comparative
analysis can be found in Section 6.0 of the Feasibility Study Report.

The section below presents the nine criteria and a brief narrative summary of the alternatives and the
strengths and weaknesses according to the detailed and comparative analysis.

B. Summary of the Comparative Analysis of Alternatives

1. Overall Protection of Human Health and the Environment

EPA's "Presumptive Remedy for CERCLA Municipal Landfill Sites" establishes containment as the presumptive
remedy for CERCLA municipal landfills. Although the Burgess Brothers landfill is not primarily a
municipal landfill, it did receive municipal type waste co-disposed with industrial waste. While the FS
evaluated other alternatives, it was found that containment would be the only practical alternative for
addressing the landfill.

All of the alternatives, except for the No Action Alternative, provide a similar level of protection for
human health and the environment concerning the potential for direct contact with soil, sediments, and
solid waste. Consistent with the Presumptive Remedy, all of the action alternatives include the
construction of caps and institutional controls to protect the integrity of the caps. The caps would
prevent ingestion and dermal contact of soil or solid waste. Capping would also prevent further transport
of contaminants into stream sediments. The No Action Alternative would not be protective of human health
or the environment because it would allow a continued release of contaminants and a possible spreading of
contamination to currently uncontaminated areas.

Capping would effectively reduce infiltration and thereby halt the leaching of contaminants from the soil
and solid waste into shallow groundwater and surface waters. This would ultimately result in an
improvement of down gradient groundwater guality and a reduction of the risks to human health associated
with future ingestion of shallow groundwater.

Installation and operation of an air sparging/soil vapor extraction system within the Lagoon Area
(Alternatives 2, 3, and 4) would significantly contribute to the protection of human health risks, since
the system would reduce the toxicity, mobility, or volume of hazardous substances within the landfill
that could impact groundwater.

With respect to exposure to contaminated groundwater, all of the alternatives, except for the No Action
Alternative, would provide overall protection to human health and the environment as long as
institutional controls are in place. In the long-term, alternatives that address the contaminants within
the Landfill Area and Lagoon Area (Alternatives 2, 3, and 4) would be protective of human health by
preventing further migration of contaminants beyond the compliance boundary and allowing for the
restoration of the downgradient aguifer.

-------
The expected timeframes for all action alternatives to achieve the chemical-specific groundwater remedial
objectives at the compliance boundary are similar. Alternative 2 (natural attenuation) would take
approximately 7 years to meet remedial action objectives (RAOs). Alternatives 3 (pump and treat) and 4
(treatment wall) would take approximately 2 years to meet RAOs, however, the treatment systems in both
alternatives would have to be operated for an additional 5 years (for a total of 7 years) before RAOs
were maintained without the aid of continued ground water treatment. (See Figure 9, Appendix A) The
difference in these expected timeframes of Alternatives 2, 3, and 4 are not considered significant. If
DNAPLs are present, however, the time frame for achieving the remedial action objectives for all
alternatives would be longer.

In summary, all of the alternatives, except for the No Action Alternative, would provide similar levels
of protection of human health and the environment. Alternative 3 (pump and treat) and 4 (treatment wall)
would be slightly more protective than Alternative 2 (natural attenuation) because the remedial action
objectives would be achieved in a slightly shorter time frame.

2. Compliance with ARARs

Tables 6-1 through 6-4 of the Feasibility Study Report provide a listing of all chemical-specific,
action-specific, and location-specific ARARs for each alternative. Contained within Appendix B of this
Record of Decision is a table (Table 6-2) of all chemical-specific, action specific, and
location-specific ARARs for EPA's selected alternative.

Alternative 1 (No Action) would not comply with federal and state hazardous waste regulations and federal
and state drinking water standards. The landfill would not be capped in accordance with RCRA reguirements
and groundwater impacts would continue indefinitely beyond the compliance boundary.

All of the alternatives, except for No Action, would meet the federal and state hazardous waste
regulations by complying with the closure and post-closure reguirements for hazardous waste facilities
within the 30 year evaluation period. These alternatives will also meet federal and state wetlands ARARs
by minimizing adverse effects to wetlands and mitigating any unavoidable impacts.

Each of the action alternatives would lead to compliance with the chemical-specific groundwater remedial
objectives in a reasonable time frame. As stated in the previous section, the time to achieve the
chemical-specific groundwater remedial action objectives is similar, varying from two to seven years,
depending on the alternative selected.

3. Long-Term Effectiveness and Permanence

The No Action Alternative would not be effective or permanent in reducing long-term risk; soil and solid
waste would continue to be available for exposure to human and ecological receptors and contaminants
would continue to leach into groundwater and migrate beyond the compliance boundary.

The residual risk following the completion of remedial actions for Alternatives 2, 3, and 4 would be
egual. Each alternative, therefore, would be egually effective and reliable in the long term as the
remedial action objectives would be achieved under all three alternatives. The risks associated with the
landfill material would be the same because all three alternatives have the same source control measures
(SVE/air sparging, and capping). Although the management of migration remedial activities for the three
action alternatives vary, they would have similar long-term effectiveness.

In summary, Alternatives 2, 3, and 4 would be egually effective and reliable in the long term in
preventing exposure to contaminated soil solid waste, and sediment.

4. Reduction of Toxicitv, Mobility and Volume through Treatment

Alternative 1 (No Action) would not provide a reduction in contaminant toxicity, mobility, or volume
because it provides only for continued monitoring of site contaminants without any remedial activities.

All of the action alternatives (Alternatives 2 (natural attenuation), 3 (pump and treat), and 4
(treatment wall)) provide for an SVE/air sparging system in the Lagoon Area combined with ground water
remediation. Each of these three alternatives meet the remedial action objectives and offer a similar
amount of reduction in mobility, toxicity, and volume of contaminants through treatment. Alternative 3
would transfer toxicity to residual materials from the treatment processes, such as sludge and carbon
filters, which would be disposed at an appropriate facility or recycled. Alternative 4 may reguire the
replacement and disposal of the granular iron in the treatment wall over time as efficiency decreases.
Alternative 2 would not create any wastes for disposal and would reduce the toxicity and volume of the
contaminants through naturally occurring treatment processes, such as biodegradation. An exception to
this may be the potential for biotransformation of chlorinated compounds such as TCE and PCE to vinyl

-------
chloride which is more toxic. However, the effects of this are expected to be minor due to source
control, dilution, dispersion, and sorption, all of which would reduce concentrations of vinyl chloride.

If DNAPL is found to be present, however, the degree to which the toxicity and volume would be reduced
under all alternatives is uncertain.

5. Short-Term Effectiveness

Alternative 1 (No Action) would pose the lowest risks to Site workers during implementation since there
is no construction involved, however, short-term protection of human health and the environment would not
be achieved since exposure to contaminated soil, solid waste, or groundwater would not be prevented.
Potential short-term risks associated with implementing and installing the SVE/air sparging systems and
caps (Alternatives 2, 3 and 4) would be relatively small. Site workers would be potentially exposed to
contaminants during implementation and installation of the SVE/air sparging system, regrading, and
construction of the caps, however, these exposures can be controlled through routine monitoring and
implementing health and safety measures.

Alternative 2 would have fewer short-term risks than the other two action alternatives since construction
for ground water treatment would not be reguired. All action alternatives would achieve similar
short-term protection of human health and the environment through capping and institutional controls to
prevent the use of contaminated groundwater.

6. Implementabilitv

All of the Alternatives evaluated are implementable. Alternative 1 (No Action) would be the easiest to
implement as it does not involve any construction. Alternative 2 would also be easy to implement as
construction would include only the SVE/air sparging system and caps which would utilize standard
materials and construction technigues. Alternatives 3 and 4 would be the most difficult to implement as
the ground water treatment systems would reguire speciality contractors and construction technigues.

Alternative 3 (pump and treat) would be the most difficult to implement. It would reguire speciality
contractors to install a collection trench which, because of a high ground water table, could not be
constructed conventionally. Biopolymer trenching technigues would be necessary which would include the
introduction of a biodegradeable slurry during excavation. The installation of piping, filter fabric,
impermeable barriers, and ground water collection structures would take place through the slurry itself
Alternative 3 would also reguire the construction of a water treatment system, installation of electric
and other utilities, and meeting effluent standards for a surface water discharge which may be difficult
to attain for inorganics, even with pretreatment. While this alternative is implementable, it would be
the most difficult to implement.

Alternative 4 (treatment wall) would be more difficult to implement than Alternative 1 and 2 as it would
reguire construction of a treatment wall that would have to be installed by speciality contractors. Only
a few contractors have installation experience with the technology as very few full scale systems have
been installed. The depth of the treatment wall is estimated at 30 feet which would reguire speciality
shoring during installation.

Alternative 2 would be the easiest of the action alternatives to implement as the construction of a
ground water treatment system would not be reguired.

7. Cost

A table summarizing the present worth costs of each of the alternatives is provided below.

Summary of Estimated Remedial Costs

Alternative Total Projected Cost

1 - No Action $930,000

2 - Capping and Lagoon Treatment/Natural Attenuation $3,600,000

3 - Capping and Lagoon Treatment/Pump and Treat $6,000,000

4 - Capping and Lagoon Treatment/Treatment Wall $5,800,000

Note: Costs include construction and operation and maintenance costs over the 30 year evaluation period,
using a 7% discount rate.

-------
As listed above, Alternative 1 (No Action) would be the least costly alternative. The only associated
costs would be the semi-annual monitoring of site conditions.

Alternative 2 (Natural Attenuation) is the least costly of the action alternatives. Associated costs for
the construction and maintenance of caps over the Landfill Area and Marshy Area are roughly egual to
those associated with the operation and maintenance of the SVE/air sparge system. After the SVE/air
sparging is complete, the only associated costs would be semi-annual monitoring of site conditions and
periodic re-evaluation of the groundwater modeling results.

Costs associated with Alternatives 3 (Pump and Treat) and Alternative 4 (Treatment Wall) are on the same
order of magnitude with each other. However, if a longer O&M period is reguired than the estimated seven
year period to meet remedial action objectives, the costs associated with Alternative 3 would increase at
a faster rate than Alternative 4.

8. State Acceptance

The Vermont Department of Environmental Conservation (VT DEC) has been involved with the study and
oversight of the Burgess Brothers Superfund Site since the mid-1980s. The VT DEC has reviewed the
Remedial Investigation, Feasibility Study, and Risk Assessment reports. The public comment period, and
the EPA's responses to their comments are summarized in the Responsiveness Summary in Appendix E to this
Record of Decision.

In general the state has supported the preferred alternative set forth in the Proposed Plan. The State's
declaration of concurrence with this Record of Decision is attached as Appendix C.

9. Community Acceptance

The comments received from the community on the RI/FS and the Proposed Plan during the public comment
period, and EPA's responses to the comments, are summarized in the Responsiveness Summary in Appendix E
of this document. Although very few comments were received, there was overall support of EPA's selected
remedy. The focus of the comments included access restrictions, impacts to the community during
construction activities, and overall environmental impacts. EPA's responses can be found in Appendix E.

X. THE SEIiECTED REMEDY

The remedy selected to address contamination at the Burgess Brothers Superfund Site is Alternative 2,
which includes construction of a multi-barrier cap on the Landfill Area, construction of a cap over the
soils in the Marshy Area, SVE/air sparging in the former lagoon cells, institutional controls, natural
attenuation, long-term monitoring, and five-year reviews. This remedy addresses all of the contamination
at the Site. A detailed description of the cleanup levels and the selected remedy is presented below.

A. Interim Groundwater Cleanup Levels

Interim cleanup levels have been established in groundwater for all contaminants of concern identified in
the Baseline Risk Assessment found to pose an unacceptable risk to either human health or the
environment. Interim cleanup levels have been set based on the ARARs (e.g., non-zero Federal Drinking
Water Maximum Contaminant Level Goals (MCLGs) and MCLs, and Vermont Primary Groundwater Quality Standards
(VPGQS)) as available, or other suitable criteria described below. Periodic assessments of the protection
afforded by remedial actions will be made as the remedy is being implemented and at the completion of the
remedial action.

At the time that Interim Groundwater Cleanup Levels identified in this ROD, newly promulgated ARARs, and
modified ARARs have been achieved and have not been exceeded for a period of three consecutive years, a
risk assessment shall be performed on the residual groundwater contamination to determine whether the
remedial action is protective. This risk assessment of the residual groundwater contamination shall
follow EPA procedures and will assess the cumulative carcinogenic and non-carcinogenic risks posed by
ingestion of groundwater and inhalation of VOCs from domestic water usage.

If, after review of the risk assessment, the remedial action is not determined to be protective by EPA,
the remedial action shall continue or be modified until either protective levels are achieved and are not
exceeded for a period of three consecutive years, or until a remedy is otherwise deemed protective. Once
the remedy is deemed protective, the levels achieved shall constitute the final cleanup levels for this
Record of Decision and shall be considered performance standards for this Site.

Because the aguifer at and beyond the compliance boundary for the Landfill is a potential source of
drinking water, MCLs and non-zero MCLGs established under the Safe Drinking Water Act are ARARs. The

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State of Vermont has classified the aquifer under and beyond the compliance boundary for the Landfill as
Class III, suitable as a source of water for individual domestic drinking water supply, irrigation,
agricultural use, and general industrial and commercial use. Vermont Primary Groundwater Quality
Standards established under the Groundwater Protection Rule and Strategy are also ARARs.

Interim cleanup levels for known, probable, and possible carcinogenic compounds  (Classes A, B, and C,
respectively) have been established to protect against potential carcinogenic effects and to conform with
ARARs. Because the MCLGs for Class A & B compounds are set at zero and are thus not suitable for use as
interim cleanup levels, MCLs have been selected as the interim cleanup levels for these Classes of
compounds. Because the MCLGs for the Class C compounds are greater than zero, and can readily be
confirmed, MCLGs have been selected as the interim cleanup levels for Class C compounds.

Interim cleanup levels for Class D and E compounds  (not classified, and no evidence of carcinogenicity)
have been established to protect against potential non-carcinogenic effects and to conform with ARARs.
Because the MCLGs for these Classes are greater than zero and can readily be confirmed, MCLGs have been
selected as the interim cleanup levels for these classes of compounds.

In situations where a promulgated State standard is more stringent than values established under the Safe
Drinking Water Act, the State standard was used as the interim cleanup level. In the absence of an MCLG,
an MCL, a proposed MCLG, proposed MCL, State standard, or other suitable criteria to be considered  (i.e.,
health advisory, state guideline), an interim cleanup level was derived for each compound having
carcinogenic potential  (Classes A, B, and C compounds) based on a 10 6 excess cancer risk level per
compound considering the ingestion of groundwater from domestic water usage.

In the absence of the above standards and criteria, interim cleanup levels for all other compounds
(Classes D and E) were established based on a level that represent an acceptable exposure level to which
the human population including sensitive subgroups may be exposed without adverse affect during a
lifetime or part of a lifetime, incorporating an adequate margin of safety  (hazard quotient = 1)
considering the ingestion of groundwater from domestic water usage. If a value described by any of the
above methods was not capable of being detected with good precision and accuracy, or was below what was
deemed to be the background value, then the practical quantification limit or background value was used
as appropriate for the Interim Groundwater Cleanup Level.

Table 1 below summarizes the Interim Cleanup Levels for carcinogenic and non-carcinogenic contaminants of
concern identified in groundwater.

                                TABIiE 1:  INTERIM GROUNDWATER CIiEANUP IiEVELS

                                         Carcinogenic Contaminants
Carcinogenic Contaminants
   of Concern  (Class)
1,1 -Dichloroethene  (C)
1,2-Dichloroethane   (B2)
Benzene (A)
Chloroform  (B2)
Methylene Chloride(B2)
Tetrachloroethene  (B2-C)
Trichloroethene  (B2-C)
Vinyl Chloride  (A)
1,4-Dichlorobenzene  (C)
Bis (2-Ethylhexyl)Phthalate(B2)
Arsenic  (A)
Lead  (B2)
Interim
Cleanup
Level (Ig/1)
7
5
5
6
5
5
5
2
75
6
50
15
Basis

MCLG
MCL
MCL
MCL
MCL
MCL
MCL
MCL
MCLG
MCL
MCL
NIPDWR
                                                           Level  of Risk *1
7x10 -5
8x10 -6
3x10 -6
6x10 -7
7x10 -7
5x10 -6 *2
1x10 -6 *2
7x10  -5  *2
3x10 -1 *2
1x10 -6
9x10 -4
TOTAL
                                                                   1x10 -3

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                          TABIiE 1:  INTERIM GROUNDWATER CIiEANUP IiEVELS - Continued
                                       Noncarcinogenic Contaminants
Noncarcinogenic Contaminants          Interim
    of Concern  (Class)                Cleanup
                                    Level(Ig/1)

1,1-Dichloroethene(C)                    7
1,2-Dichloroethane  (B2)                  5
1,2-Dichloroethene - cis(D)             70
1,2-Dichloroethene - trans(D)          100
Benzene(A)                               5
Chlorobenzene,(D)                      100
Chloroform(B2)                           6
Methylene Chloride(B2)                   5
Tetracnloroethene(B2-C)                  5
Trichloroethene(B2-C)                    5
Vinyl Chloride(A)                        2
1,4-Dichlorobenzene(C)                  75
Bis (2-Ethylhexyl)Phthalate(B2)           6
Arsenic(A)                              50
Lead(B2)                                 15
Manganese(D)                           840
Basis
             Target
           Endpoint of
            Toxicity
MCL
MCL
MCLG
MCLG
MCL
VPGQS *3
VPGQS *3
MCL
MCL
MCL
MCL
MCL
MCL
MCL
NIPDWR* 5
Hazard
Potential
liver
-
blood
blood
-
liver
liver
liver
liver
liver
-
liver
liver
skin
CNS
CNS

 Hazard
Quotient
   -1

  0.02
no data
  0.19 *2
  0.14
no data
  0.14
  0.02
 0.002
  0.01
  0.02 *2
no data
  0.01 *2
  0.008
   4.5
 no data
   1.0
Thallium(D)
MCL
             blood
                             0.7 *4
                             TOTAL HAZARD INDEX:
    Liver  0.4
    Blood  1.0
     CNS   1.0
     Skin  4.5
TABLE 1 FOOTNOTES:
*1    Based on consumption of 2 liters water/day, 350 days/year, for 30 years. Risk attributed
      to inhalation of VOCs from domestic use of contaminated water are estimated to be no more
      than risks attributed to their direct ingestion.
*2     Provisional risk estimates as compound undergoing toxicological review at time of ROD.
*3     Vermont Primary Groundwater Quality Standard - Enforcement Standard, Vermont
      Groundwater Protection Rule and Strategy, Subchapter 7, 12-702
*4     Based on reference dose or thallium sulfate
*5     National Interim Primary Drinking Water Regulation (NIPDWR)
While these interim cleanup levels are consistent with ARARs or suitable to be considered  (TBC) criteria
for groundwater, a cumulative risk that could be posed by these compounds may exceed EPA's goals for
remedial action. Conseguently, these levels are considered to be interim cleanup levels for groundwater
until a final determination of protectiveness is made. The final determination of protectiveness will be
based on the Interim Groundwater Cleanup Levels identified in the ROD, newly promulgated ARARs and
modified ARARs which call into guestion the protectiveness of the remedy, and a risk assessment of
residual contamination. A determination of protectiveness must be obtained at the completion of the
remedial action at the points of compliance. The points of compliance are identified in Figure 10  (in
Appendix A) and defined by monitoring wells W-05, W-03, W-03T, W-04S, W-041), W-04T, W-25S1, W-25S1,
W-25B and any new monitoring wells installed in this area.
B.
       Performance Levels for Surface Water and Sediment
Groundwater from the Landfill Area and former Lagoon Area discharges directly to the surface water and
sediments. To evaluate the effectiveness of both the source control and groundwater cleanup measures,
"performance levels" have been established for contaminants detected in surface water and sediments.
These performance levels are based on State and Federal regulatory standards and/or utilized guidelines.

The Baseline Risk Assessment concluded that surface water and sediments may pose an unacceptable risk to
some forms of wildlife. Therefore, the performance levels will also be used to determine if further
action, at a later time, may be necessary to address any risks from surface water and sediments.

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Contaminants for which performance levels have been set include VOCs and metals. The cleanup and
performance levels set for contaminants in surface water and sediments are listed in Tables 2 and 3,
respectively.
     Contaminant of
        Concern

1,1-Dichloroethlene
Dichlorobromomethane
Tetrachloroethene
Trichloroethene
Vinyl Chloride
Aluminum
Antimony
Arsenic
Cobalt
Copper
Cyanide
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
                          TABIiE 2: SURFACE IflATER PERFORMANCE IiEVELS

                               Performance Level                   Basis
                                      (ppb)

                                      0.057                         AWQC *1
                                      0.27                         AWQC *1
                                       0.8                         AWQC *1
                                       2.7                         AWQC * 1
                                         2                          AWQC *1
                                         87                         AWQC *1
                                         14                         AWQC *1
                                      0.018
                                         10
                                       5.2
                                      1000
                                       1.5
                                      4100
                                     0.012
                                       108
                                        5
                                       1.2
                                       1.7
                                      58.9
                AWQC *1
             Risk Based *3
                VTWQS *2
                AWQC *1
                VTWQS *2
                VTWQS *2
             Risk Based *3
                AWQC *1
                VTWQS *2
                AWQC *1
                AWQC *1
                AWQC *1
                VTWQS *2
FOOTNOTES FOR TABLE 2:
 *1   Federal Clean Water Act - Ambient Water Quality Criteria  (AWQC)
 *2   State of Vermont Water Quality Standards  (VTWQS), effective April 21, 1997
 *3   Biesinger & Christensen, 1972

                     TABIiE 3:  SEDIMENTS PERFORMANCE IiEVELS
       Contaminant of
          Concern

      Arsenic
      Cadmium
      Chromium
      Copper
      Iron
      Lead
      Manganese
      Mercury
      Nickel
      Zinc
                        Performance Level
                              (ppm)

                               6
                              0.6
                               26
                               16
                              20000
                               31
                              460
                              0.2
                               16
                              120
                                                  Basis 1
MOE
MOE
MOE
MOE
MOE
MOE
MOE
MOE
MOE
MOE
FOOTNOTES FOR TABLE 3:

#1 Ontario Ministry of the Environment  (MOE) Sediment Quality Guidelines
C.
Description of Remedial Components
The selected remedy for the site includes construction and maintenance of a multi-barrier cap over the
Landfill Area, construction and maintenance of a cap over the soils in the Marshy Area, SVE/air  sparging
in the former Lagoon Area, institutional controls such as a deed notice, long term monitoring, operation
and maintenance, and a review of the Site conditions every five years.

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1. Multi-Barrier Cap Over the Landfill Area

Capping of the Landfill: The top slope of the Landfill Area will be graded at approximately three percent
and the side slopes will be graded at three horizontal to one vertical (3:1) or flatter. No side slope
will be graded more steeply than 3:1. Prior to any intrusive activity, erosion and sedimentation controls
will be implemented to protect the swales, unnamed stream, and wetlands adjacent to and south of the
Landfill Area. These controls will be inspected on a routine basis and maintained until soil
stabilization is established.

Grading of the Landfill Area will take into account the adjacent swales, unnamed stream, and wetlands and
minimize adverse effects to these areas. As grading of the landfill will reguire the loss of some
wetlands, these wetlands will be replicated. The adjacent swales will be re-routed through a conduit
beneath or adjacent to the landfill and Marshy Area cap. The exact approach will be determined during
remedial design.

A continuous multi-layer (or "composite barrier") cap will be constructed over the Landfill Area. The
cap will be designed, constructed, operated, and maintained to meet the performance reguirements of the
Resource Conservation and Recovery Act ("RCRA") Subtitle C regulations specified in ARARs Table 6-2 of
Appendix B. The cap shall also be designed to meet the reguirements of the following EPA technical
guidance documents: "Final Covers on Hazardous Waste Landfills and Surface Impoundments"
(EPA/530-SW-89-047, July 1989) ; "Construction Quality Management for Remedial Action and Remedial Design
Waste Containment Systems" (EPA/540/R-92/073, October 1992); "QA and QC for Waste Containment Facilities"
(EPA/600R-93/182, September 1993) and Alternative Cap Design Guidance for Unlined Hazardous Waste
Landfills, EPA Region I, September 30, 1997. The multi-barrier cap, from bottom to top, will achieve the
following minimum reguirements:

a. The base layer will be comprised of fill material. This material will be used to establish the
base grade of the Landfill. Given the steep eastern slope of the Landfill, the base grade of
this slope is expected to be a maximum of 3:1 (horizontal: vertical). This layer will be a
minimum of six inches on the top slopes and a minimum of 6 inches on the 3:1 side slopes.

b. The bottom low hydraulic conductivity layer will be installed to minimize potential leakage
through the low hydraulic conductivity geomembrane into the Landfill. This layer will act as a
safeguard to the geomembrane, and will consist of compacted clay or a reinforced geosynthetic
clay liner (GCL). This layer will have a hydraulic conductivity no greater than 1 x 10 -7
cm/sec. Because the interface frictional resistance between the GCL and the geomembrane can be
very low, particularly when the GCL becomes hydrated, this layer will only be utilized on areas
having slopes less than 6:1 to ensure cap slope stability. On slopes greater than 6:1, a silty
sand or sandy silt layer will be placed beneath the geomembrane to enhance side slope
stability. This soil is anticipated to be at least 12 inches in thickness and will have a
hydraulic conductivity no greater than 1 x 10 -4 cm/sec.

3. The top low hydraulic conductivity layer will be a synthetic barrier. This will be the main
barrier which prevents water infiltration from entering the Landfill. This synthetic barrier
will be a type of flexible geomembrane, 60 mil linear low density polyethylene (LLDPE) or
eguivalent, selected to prevent infiltration. The geomermbrane on the slopes greater than 6:1
must be textured to minimize the potential for sliding.

d. A drainage layer will be installed above the synthetic barrier to prevent the ponding of water
over the synthetic barrier. This layer will be composed of either 12 inches of sand or gravel
with a minimum hydraulic conductivity of 1 x 10 -1 cm/sec, or a geocomposite drainage material
with an eguivalent transmissivity of at least 3 x 10 -4 m 2/sec.

e. The filter layer will be composed of nonwoven geotextile filter fabric to minimize fill
material from clogging the granular drainage layer. A filter layer may not be reguired if the
drainage layer is a geocomposite.

f. The top layer will be the vegetative cover. This layer, will: (1) provide frost protection; (2)
provide adeguate water-holding capacity to attenuate rainfall infiltration to the drainage
layer and to sustain vegetation through dry periods; and (3) provide sufficient thickness to
allow for expected long-term erosion losses. The side slope will be terraced to minimize
erosion of the multi-layer caps so that no more than 2 tons per acre per year of soil loss
occurs. The thickness of the top layer is anticipated to be a minimum of 36 inches and will be
based on local maximum frost depth penetrations. No deep-rooted plants will be allowed, to
become established on the capped area.

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Air: A landfill gas management system will be implemented to insure that landfill gas does not build up
beneath the caps or migrate laterally. In addition, a collection system may be needed to ensure that
gases containing VOCs are properly treated prior to venting. The appropriate gas management system for
the Landfill Area will be determined during design and will be based on the compliance criteria discussed
below.

The point of compliance for air, consistent with the NCP, shall be the point(s) of the maximum exposed
individual, considering reasonable expected use of the Site and surrounding area. The maximum exposed
individuals include: (1) adjacent residents; (2) operation and maintenance personnel; and (3) individuals
working at the Burgess Brothers facility. The gas collection system shall prevent an unacceptable risk of
exposure to the maximum exposed individuals by controlling the release of landfill gas and treating
collected landfill gas, if necessary. Any gas collection and treatment system shall also comply with the
federal and state air ARARs.

Surface Water/Wetlands: Surface water drainage controls will be constructed to minimize erosion of the
caps. As determined by the final design, drainage channels will be installed in certain areas on the top
and perimeter of the Landfill Area to control runoff. The Landfill Area will also be revegetated and the
vegetation maintained to prevent erosion. Stormwater runoff from the Landfill will be managed in
accordance with Vermont Water Quality Standards. The drainage system of the caps must be capable of
handling a 25 year, 24 hour storm event.

Mitigation for wetlands impacts, which will be unavoidable due to necessary grading for the cap over the
Landfill Area, will be accomplished consistent with State and Federal laws and guidance. Potential
successful mitigation sites will be identified on the basis of topographic location, water source and
transport, hydrodynamics, and site morphometry and soils. On site and in-kind mitigation is preferable
where achievable. Creation of any wetlands will need to take into account buffer zones and upland
transition zones. A reference wetland may be identified and used to monitor and evaluate the impact of
natural fluctuations on the mitigation success.

Long-term monitoring: Long-term monitoring of the surface water, shallow and deep groundwater,
sediments, and residential water supplies will be performed. This monitoring will focus on establishing
long-term trends in each media and confirming the restoration of the media. The Long-Term Monitoring
Program will develop a method for tracking the restoration of the groundwater to confirm that the cleanup
model was accurate. The Long Term Monitoring Plan will also include goals to evaluate the effectiveness
of the selected remedy.

Operation and Maintenance: The integrity of the cap, the gas collection system, surface water controls,
and wetlands replication will also be monitored regularly and maintained to meet the objectives set forth
in this ROD. Access to the capped areas will be controlled by the installation and maintenance of an
industrial fence.

2. Cap Over the Soils in the Marshy Area

A cap over the marshy area soils will be constructed using either an impermeable or permeable barrier.
The type of barrier will be based on factors such as constructability, maintenance, and ability to
achieve remedial action objectives. The specific type of cap will be determined during design.

The cap will have the following cross-section, at a minimum, from top to bottom:

• A top layer of 24 inches that includes a minimum of four inches of topsoil
• An impermeable or permeable barrier
• A geocomposite drainage material, if necessary
• Two feet of soil as a subbase, if necessary

The cap will cover the approximately one-half acre area, minimizing potential contact with and providing
a barrier against burrowing animals into the Marshy Area soils. To stabilize the topsoil cover, the area
will be completed with approximately 4 inches of topsoil and hydroseed. To promote positive drainage from
the area, existing soils will be shaped to achieve a minimum 3% grade toward drainage swales that will be
constructed as part of the multi-barrier cap over the Landfill Area.

Reguirements for landfill gas generation, surface water drainage, mitigation for wetlands impacted by the
capping of the Marshy Area, and long-term maintenance will be the same as those reguirements reguired for
the capping of the Landfill Area.

3. SVE/Air Sparging in the Former Lagoon Area

An SVE system, in conjunction with an air sparging system, will be used to remediate soils in the Lagoon

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Area. The air sparging system will remediate saturated zone soils by forcing air into the groundwater
beneath the lagoon area. This induced air flow will accelerate the volatilization of VOCs in the
saturated zone, forcing them upwards into the soils in the unsaturated zone.

The SVE system will include air extraction wells to remove VOCs from the vadose zone soils. The VOCs will
be removed by pulling air through the extraction wells producing a vacuum in the subsurface. VOCs
contained within the vadose zone will migrate toward the air extraction wells, where they will be removed
from the subsurface for treatment. Any condensate collected from system operation will be characterized
and treated off-site, as appropriate.

Based on the results of a pilot study that was performed at the site, an SVE system consisting of six
extraction wells and two vapor extraction units will be used to remediate the lagoon soils. The type of
off-gas treatment for the SVE/air sparging system will be selected during pre-design. Installation and
start-up of the system will be performed in such a way as to prevent, to the extent practicable,
mobilization of DNAPL if it is present. Specific actions to address potential DNAPL will be defined
during design.

It is anticipated that it would be necessary to operate the SVE/air sparging system continuously for a
period of six months to two years, then periodically over a period of perhaps several years to remove
sufficient guantities of VOCs from the former Lagoon Cells. Once contaminant levels are adeguately
reduced, the system will be shut down for a period of time, then restarted to ensure contaminant levels
do not increase. This shutting down and restarting process will be done several times over a period of
time to ensure contaminant levels do not increase during periods of shut down. Over time, contaminant
levels are expected to decrease to levels where the SVE/air sparging system can be discontinued. If DNAPL
is determined to be present, however, the SVE/air sparging may not sufficiently remove the VOC source and
an alternate treatment approach may be evaluated.

During operation, the system's performance will be monitored on a regular basis and adjusted as warranted
by the performance data collected during operation.

4. Institutional Controls

Institutional controls will be established to protect the capped areas, to prevent the use of groundwater
potentially impacted by the Site, and to inform future purchasers of the groundwater restrictions
associated with the property. These institutional controls will consist of deed restrictions which are
enforceable and reliable for long-term protection. Restrictions to protect the Landfill Area and Marshy
Area caps will include controlling access to these areas and prohibiting excavation or other disturbances
which may adversely affect the integrity of the caps.

The restrictions on use of groundwater will extend from the upgradient perimeter of the Landfill Area to
at least all down gradient boundaries of the contaminant plume in both overburden and bedrock. The
restrictions will also include a buffer zone around the contaminated area adeguate to insure that new
private or public water supply wells in the vicinity would not induce movement of the contaminants into
uncontaminated areas or interfere with any remedial action at the Site. Groundwater use restrictions
beyond the point of compliance will remain in effect until contaminant levels reach and maintain
groundwater cleanup levels in both the downgradient bedrock and overburden aguifers. Groundwater use
restrictions for the area upgradient of the point of compliance, including the Landfill Area, will remain
in effect until contaminant levels reach and maintain groundwater cleanup levels in both the downgradient
bedrock and overburden aguifers

5. Long-Term Monitoring

An environmental monitoring program will be implemented to evaluate the overall effectiveness of the
remedy. The monitoring program will include selected groundwater monitoring wells, and surface water and
sediment from the adjacent wetlands. In addition, groundwater in overburden and bedrock monitoring wells
immediately downgradient of the Landfill Area will be monitored on a regular basis to insure that the
contaminant plume is not spreading into previously uncontaminated areas.

6. Operations and Maintenance

Operations and maintenance (O&M) activities will be conducted to insure the proper operation of the
remedy. O&M will include periodic monitoring and necessary maintenance of the capped areas, maintenance
of perimeter fence, landfill gas collection system and treatment system, if necessary, and any wetland
replication areas associated with the remedy.

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7. Five-Year Review

To the extent required by law, EPA will review the Site at least once every five years after initiation
of the remedial action at the Site since hazardous substances, pollutants or contaminants will remain at
the Site to assure that the remedial action continues to protect human health and the environment. EPA
will also review the Site before the Site is proposed for deletion from the National Priorities List
(NPL).

D. Contingency for Alternate Response Action

EPA has estimated that interim ground water cleanup levels will be obtained within 7 years after
initiation of the source control components. Modeling of the contaminant source and plume to confirm the
effectiveness of the selected remedy and to refine the predicted timeframe for achieving remedial action
objectives will be done, at a minimum, two years after the initiation of the source control components
and again prior to any five year review. If, at any time, EPA determines that the selected remedy is not
effective and that remedial action objectives will not be attained within an acceptable timeframe, an
alternate remedial action will be evaluated and implemented.

XI. STATUTORY DETERMINATIONS

The remedial action selected for implementation at the Burgess Brothers Superfund Site is consistent with
CERCLA and, to the extent practicable, the NCP. The selected remedy is protective of human health and the
environment, attains ARARs and is cost effective. The selected remedy also partially satisfies the
statutory preference for treatment which permanently and significantly reduces the mobility, toxicity or
volume of hazardous substances as a principal element. Additionally, the selected remedy utilizes
alternate treatment technologies or resource recovery technologies to the maximum extent practicable.

A. 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 ecological receptors through treatment,
engineering controls, and institutional controls; more specifically, the SVE/air sparging system will
treat and reduce the volume of hazardous substances at the Site. The installation of Landfill and Marshy
Area caps will prevent ingestion and dermal contact of soil or solid waste. Capping will also prevent
further transport of contaminants into the wetland and swales and unnamed stream sediments. Capping will
effectively eliminate infiltration and thereby halt the leaching of contaminants from the soil and solid
waste into groundwater. This will ultimately result in an improvement of downgradient groundwater quality
and a reduction of the risks to human health associated with ingestion of contaminated groundwater.
Institutional controls will be implemented to prevent the use of contaminated groundwater until cleanup
goals have been met. Long-term monitoring will insure that the remedy remains protective of human health
and the environment.

Moreover, the selected remedy will achieve potential human health risk levels that attain the 10-4 to
10-6 incremental cancer risk range and a level protective of noncarcinogenic endpoints, and will comply
with ARARs. At the time that the Interim Groundwater Cleanup Levels identified in the ROD and newly
promulgated ARARs and modified ARARs which call into question the protectiveness of the remedy have been
achieved and have not been exceeded for a period of three consecutive years, a risk assessment shalt be
performed on the residual groundwater, contamination to determine whether the remedial action is
protective. This risk assessment of the residual groundwater contamination shall follow EPA procedures
and will assess the cumulative carcinogenic and non-carcinogenic risks posed by ingestion of groundwater
and inhalation of VOCs from domestic water usage. If, after review of the risk assessment, the remedial
action is not determined to be protective by EPA, the remedial action shall continue or be modified until
protective levels are achieved and have not been exceeded for a period of three consecutive years, or
until the remedy is otherwise deemed protective. Once the remedy is deemed protective, the levels
achieved shall constitute the final cleanup levels for this Record of Decision and shall be considered
performance standards for this Site.

B. The Selected Remedy Attains ARARs

This remedy will meet or attain all applicable or relevant and appropriate federal and state
environmental requirements that apply to the Site. A detailed listing of the specific ARARs can be found
in Appendix B of this ROD. These tables give a brief synopsis of the ARARs and an explanation of the
actions necessary to meet the relevant and appropriate actions at the Site. In addition to ARARs, the
tables describe standards that are not ARARs but are To-Be-Considered (TBC) with respect to remedial
actions. The specific ARARs include the following:

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Chemical-Specific

  Medium
Requirements
Groundwater   Vermont Groundwater Protection Regulations (EPR 12-
              702)
          Status

Applicable, for Enforcement
Standards
              Vermont Health Advisories

              Federal Safe Drinking Water Act - Maximum
              Contaminated Levels  (MCLs) for Organic and Inorganic
              Chemicals  (40 CFR 141 Subparts B, G and I)

              Federal Safe Drinking Water Act - Maximum
              Contaminant Level Goals  (MCLGs) for Organic and
              Inorganic Chemicals  (40 CFR 151 Subpart F)

              EPA Reference Doses  (RfDs) and EPA Carcinogen
              Assessment Group Potency Factors
              EPA Health Advisories

Action-Specific

  Medium                            Requirements

Air           Vermont Air Pollution Control Regulations (10 VSA
              Section 551 et. seq.; EPR 5-101, 5-211, 5-231 to 5-252,
              5-253.20, 5-261, 5-301 to 5-311, 5-501 to 5-502, and 5-
              1010)
                                     To Be Considered

                                     Relevant and Appropriate
                                     Relevant and Appropriate if non-
                                     zero
                                     To Be Considered
                                     To Be Considered
                                               Status
                                     Applicable
              Federal RCRA Air Emission
              Standards for Equipment Leaks, 40 CFR Part 264,
              Subpart BB

              Federal RCRA Air Emission Standards for Process
              Vents, 40 CFR Part 264, Subpart AA

              Federal Clean Air Act - Non-Methane Organic
              Compounds (40 CFR Part 60 Subpart WWW)

Action-Specific  (continued)

Groundwater   Vermont Groundwater Protection Regulations (10 VSA
              Chapter 48;  EPR 12-704 and 12-705)

Surface       Vermont Water Quality Standards  (10 VSA Chapter 47;
Water         EPR Sections 1 - 04, 2-01, 2-02, 2-03, 2-05,  3-01, 3-03,
              3-04, and Appendix C and D)

              Federal Clean Water Act - Ambient Water Quality
              Criteria
                                     Applicable,  if threshold limits
                                     are exceeded
                                     Applicable,  if threshold limits
                                     are exceeded

                                     Relevant and appropriate,  if
                                     threshold limits are exceeded
                                     Applicable
                                     Relevant and Appropriate
                                     Relevant and Appropriate
Sediment      Ontario Ministry of the Environment Sediment Quality
              Guidelines
                                     To Be Considered
Landfill      Federal RCRA Subtitle C, Regulations, 40 CFR Part 264
Material      Subpart N - Landfills, Section 264.310*

              Federal RCRA Subtitle C Regulations, 40 CFR Part 264
              Subpart B - General Facility Standards, Section 264.19*

              Federal RCRA Subtitle C Regulations, 40 CFR Part 264
              Subpart F - Releases from Solid Waste Management
              Units, Sections 264.95, 264.96(a) and  (c),  264.97, 264.98
              and 264.99*
                                     Relevant and Appropriate
                                     Relevant and Appropriate
                                     Relevant and Appropriate

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              Federal RCRA Subtitle C Regulations, 40 CFR Part 264
              Subpart G - Closure and Post Closure, Sections 264.111,
              264.114, and 264.177*

              USEPA Technical Guidance Document: Final Covers on
              Hazardous Waste Landfills and Surface Impoundments
              (EPA/530-SW-89-047)

              USEPA Technical Guidance Document: Construction
              Quality Management for Remedial Action and Remedial
              Design Waste Containment Systems  (EPA/540/R-92/073,
              October 1992)

              USEPA Technical Guidance Document: QA and QC for
              Waste Containment Facilities (EPA/600/R-93/182,
              September 1993)

              USEPA Technical Guidance Document: Alternative Cap
              Design Guidance for Unlined Hazardous Waste Landfills,
              EPA Region I, September 30, 1997.
Applicable
To Be Considered
 To Be Considered
  To Be Considered
  To Be Considered
Notes: * RCRA reguirements are made effective by the Vermont Hazardous Waste Regulations  (EPR7-502).

Location-Specific

  Medium                            Reguirements                           Status

Wetlands      Federal Executive Order on Protection of Wetlands  (E.O.      Applicable
              11990, 40 CFR Part 6, Appendix A)

              Federal Fish and Wildlife Coordination Act  (16 USC 661       Applicable
              et seg.)  40 CFR Part 6

              Federal Clean Water Act (33 USC 1344), US Army               Applicable
              Corps of Engineers Nationwide Permit Program  (33 CFR
              Part 330),  and Federal Guidelines for Specification of
              Disposal Sites" (40 CFR Part 230)

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Principal Hazardous Waste ARARs

RCRA regulations and the current State of Vermont Hazardous Waste Regulations are ARARs for this remedy.
In those limited instances where these regulations may conflict, the more stringent regulation will be
followed.

Principal ARARs for Groundwater Protection

It has been determined by EPA that the groundwater in the overburden and bedrock aguifers beyond the
points of compliance is a potential future drinking water source. While Maximum Contaminant Levels (MCLs)
and non-zero Maximum Contaminant Level Goals (MCLGs) promulgated under the federal Safe Drinking Water
Act are not applicable to groundwater, they are relevant and appropriate to groundwater cleanup because
the groundwater may be used in the future as a drinking water source. The NCP reguires that usable
groundwaters be restored to their beneficial uses whenever practicable. See 40 CFR 300.430(a) (iii) (F) .

Primary Enforcement Groundwater Standards, contained in the State of Vermont Groundwater Protection Act
Regulations are applicable. The aguifer is classified by the State of Vermont as a Class III aguifer,
suitable as a source of water for individual domestic drinking water supply, irrigation, agricultural use
and industrial/commercial use. A management objective for Class III groundwaters is compliance with the
Vermont Groundwater Standards.

Principal ARARs/TBCs for Wetland Protection

The federal Clean Water Act and Executive Order 11990 (Protection of Wetlands) are ARARs for the portion
of the remedy constructed in or affecting the wetlands at the Site. These rules (i) prohibit activity
that adversely affects wetlands unless there is no practicable alternative to such adverse effect, and
(ii) reguire that all practicable measures be taken to minimize harm to wetlands. Because of the
landfill's proximity to the wetlands and because soils within the Marshy Area are contaminated, it will
be necessary to cap a portion of the wetlands that are adjacent to the Landfill Area. The capping and the
resulting filling of the wetlands are reguired for source control for all alternatives considered. The No
Action alternative does not reguire the filling of wetlands, but that alternative is not protective of
human health and the environment. Alternatives to the filling - such as excavating the wetlands,
replacing the excavated area with clean soil, then restoring the wetland - were considered and rejected.
The RI included a delineation and assessment of the wetlands. The FS contains more detail regarding the
necessity of filling the Marshy Area wetland and alternatives considered.

Construction will be conducted to avoid or minimize any damage to flora and fauna within the portions of
the wetland that will not be capped. Measures will also be taken in constructing the cap to control
erosion and runoff. Any wetlands lost will be replaced through replication efforts, either off-site or
on-site. EPA will coordinate any wetlands replication with U.S. Fish and Wildlife and with the Vermont
DEC. The wetlands in the Marshy Area are Class III wetlands and are not protected by State regulations.

Accordingly, EPA has determined that there is no practicable alternative to filling wetlands in a portion
of the Marshy Area and that the selected remedy includes all practicable measures to minimize harm to
wetlands. EPA notified the public of the wetlands impacts in a Progress Update in April 1998 and in the
Proposed Plan. EPA did not receive any comments regarding wetlands during the public comment period.

Principal ARARs for Air Quality Protection

State Air Pollution Control Regulations establish air guality standards and allowable discharges, list
hazardous contaminants, and set Hazard Limiting Values and Action Limits. RCRA reguirements for air
emissions from process vents and eguipment leaks are also included as potential ARARs. The remedy,
specifically the VOC emissions from the SVE/air sparging system, will attain these ARARs. Federal air
regulations also reguire the collection, control, and monitoring of Non-Methane Organic Compounds (NMOCs)
such as benzene and ethane from landfills. The landfill gas venting system will be designed to satisfy
these performance standards, if threshold limits are exceeded. Landfill construction will address State
reguirements regarding particulates and odors through engineering controls.

Principal ARARs for Surface Water Protection

Several different ARARs address the protection of surface water bodies (including wetlands which are
addressed separately in this section). ARARs include the Vermont Water Quality Standards and the Ambient
Water Quality Criteria (AWQC) pursuant to the Clean Water Act. Source control measures will control
erosion, runoff, and contaminant migration and thereby improve surface water guality over time. Water
guality standards will be used to measure the effectiveness of source control measures.

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C. The Selected Remedial Action is Cost-Effective

In the Agency's judgment, the selected remedy (Alternative 2) is cost effective, i.e., the remedy affords
overall effectiveness proportional to its costs. In selecting this remedy, once the alternatives were
identified that are protective of human health and the environment and that attain 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 relationship of the overall effectiveness of the selected remedial alternative
was determined to be proportional to its costs.

The present worth costs of this remedial alternative, as presented in the Proposed Plan, are:

Estimated Capital Cost $1,633,000
Estimated Operations and Maintenance Cost: $1,941,000
Estimated Total Cost: $3,600,000

For comparison, the estimated total costs for the other alternatives that meet the threshold criteria for
protection of human health and the environment and compliance with ARARs are:

Alternative 3 $6,000,000
Alternative 4 $5,800,000

The selected remedy (Alternative 2) is the least expensive of those alternatives that meet the threshold
criteria. The additional costs for Alternative 3 are related to extraction and treatment of groundwater
down gradient of the landfill. Because extraction and treatment of the down gradient plume would not
appreciably reduce the time for groundwater restoration to drinking water standards, EPA believes that
these additional costs are not justified.

Alternative 4 includes the construction of a treatment wall to restrict contaminant transport into the
shallow groundwater aguifer. Restricting contaminant transport, however, will primarily be accomplished
through the source control components included for all Alternatives, specifically, capping the landfill
and by performing SVE/air sparging in the former Lagoon Area. The treatment wall would not provide
significant additional benefits in restricting contaminant transport beyond these source control
measures. The treatment wall would also not appreciably reduce the time reguired for groundwater
restoration to drinking water standards. For these reasons, EPA believes that additional costs for the
construction of a treatment wall are not justified.

D. The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable.

Once the Agency reviewed those alternatives that attain ARARs and that are protective of human health and
the environment, EPA identified which alternatives utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable. This determination was
made by deciding which one of the identified alternatives provides the best balance of trade-offs among
alternatives in terms of: 1) long-term effectiveness and permanence; 2) reduction of toxicity, mobility
or volume through treatment; 3) short-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 evaluating the alternatives, the presumptive remedy for municipal landfills, which acknowledges
removal of the landfill contents as an impractical alternative, was used as a guidance document.
Consistent with the presumptive remedy guidance document, containment was identified as the presumptive
approach for source control. Treatment options for areas other than hot spots were determined not to be
cost effective as only insignificant risk reduction could be obtained from significant increases in
remediation costs.

All of the alternatives (except the No Action Alternative) have the same approach for treatment of the
contaminant source. They all provide long-term effectiveness and permanence by capping the Landfill Area
and Marshy Area to prevent exposure to contaminated soil and solid waste and by performing SVE/air
sparging in the Lagoon Area soils to treat the hot spot. Both capping and SVE/air sparging will prevent
continued migration of contaminants to groundwater, surface water, and sediments in the long-term. The
differences in the alternatives, and what has been evaluated in the balancing test, is the way
groundwater would be remediated.

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The selected remedy (Alternative 2) utilizes natural attenuation for groundwater remediation which offers
the same degree of long-term effectiveness and permanence as the other alternatives. Natural attenuation
also offers a similar level of reduction of toxicity, mobility and volume of contaminants. The short-term
effectiveness of achieving drinking water standards of the selected remedy (7 years) is relatively equal
to that of the other alternatives (2 years) and EPA considers these time frames to be reasonably similar.
Of all the alternatives, the selected remedy is the easiest to implement and has the lowest costs.

Both the community and the State of Vermont support Alternative 2 (natural attenuation) as the selected
remedy.

E. The Selected Remedy Satisfies the Preference for Treatment Which Permanently and Significantly
Reduces the Toxicity, Mobility, or Volume of the Hazardous Substances as a Principal Element

All of the alternatives offer at similar degree of reduction of toxicity, mobility or volume through
treatment within a reasonably similar time frame. Alternative 2 will achieve drinking water standards
within 7 years, Alternatives 3 and 4 achieve drinking water standards within 2 years. Both Alternatives
3 and 4, however, would create additional wastes. Alternative 3 would generate sludge as a by-product of
the water treatment process and Alternative 4 would require replacement and disposal of the granular iron
contents of the treatment wall once metal precipitation and biofouling affected performance.

As stated previously, the Burgess Brothers landfill is not primarily a municipal landfill, however, it
did receive municipal type waste co-disposed with industrial waste and is characteristically similar.
Because of this, EPA's guidances on CERCLA Municipal Landfill Sites have been considered in determining
the selection of a remedy.

CERCLA and the NCP set forth the process by which remedial actions are evaluated and selected. Because
many CERCLA municipal landfill sites share similar characteristics, they lend themselves to remediation
by similar technologies. EPA has established a number of expectations as to the types of technologies
that should be considered and alternatives that should be developed; they are listed in the National
Contingency Plan (40 CFR 300.430 (a) (1) and the EPA guidance document for municipal landfill sites
"Conducting Remedial Investigation/Feasibility Studies for CERCLA Municipal Landfill Sites"
EPA/540/P-91/001).

For CERCLA municipal landfill sites, it is expected that:

1. The principal threats posed by a site will be treated wherever practical, such as in the case of
remediation of a hot spot.

2. Engineering controls such as containment will be used for waste that poses a relatively low
long-term threat or where treatment is impractical.

3. A combination of methods will be used as appropriate to achieve protection of human health and the
environment. An example of combined methods for municipal landfill sites would be treatment of hot
spots in conjunction with containment of the landfill contents.

4. Institutional controls such as deed restrictions will be used to supplement engineering controls, as
appropriate, to prevent exposure to hazardous wastes.

5. Innovative technologies will be considered when such technologies offer the potential for superior
treatment performance or lower costs for performance similar to that of demonstrated technologies.

6. Groundwater will be returned to beneficial uses whenever practical, within a reasonable time, given
the particular circumstances of the site.

The remedy selected in this ROD partially satisfies the preference set forth in CERCLA and the NCP for
treatment. Potential exposure to and ingestion of contaminated groundwater is the principal threat posed
by the site. The selected remedy is a containment remedy which includes the treatment of hot spots as
well as engineering controls supplemented by institutional controls. EPA has determined that capping,
hot spot remediation, and natural attenuation will be effective in the restoration of groundwater and
that a more aggressive groundwater treatment strategy would not provide additional benefits at this site.

The selected remedy partially satisfies the statutory preference for treatment as a principal element by
treating the soils in the Lagoon Area which result in the removal of contaminants. This action will
reduce the toxicity, mobility, and volume of the contaminants in the source area. The remaining contents
of the landfill will be contained under the multi-layer cap.

-------
XII. DOCUMENTATION OF SIGNIFICANT CHANGES

EPA presented a Proposed Plan that described the preferred alternative for remediation of the Site on
June 15, 1998. EPA did not receive any significant comments on the proposed remedy.

EPA has changed performance levels for some constituents in surface water from those presented in the
Proposed Plan. Specifically, copper, lead, nickel, and zinc have performance levels of 6.5, 1.3, 87.7,
and 58.9 ppb, respectively. These values are specified in Table 2 of this ROD and have been changed based
on an assumed water hardness of 50 mg/1 CaCO 3.

The performance level for silver has also changed to 1.2 ppb. This value is based on EPA's Ambient Water
Quality Criteria.

The selected remedy in this ROD is consistent with the proposed plan.

XIII. STATE ROIiE

The Vermont Department of Environmental Conservation has reviewed the various alternatives and has
indicated its support for the selected remedy. The State has also reviewed the Remedial Investigation,
Baseline Risk Assessment and Feasibility Study 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 Burgess Brothers Superfund Site. A copy of the
declaration of concurrence is attached as Appendix C.

-------
APPENDIX A

TABIiES AND FIGURES

TABIiE 1

Summary of Previous Investigation Activities
Date
6/1976
1984
1985
1985
Lead Org<
VTAEC
VTAEC
VTAEC
Eveready
2/89
3/89
3/89
EPA
EPA
Eveready
4/89
EPA
5/91 VTDEC

12/91-1/92 Settling Parties

9/92-8/94 Settling Parties
11/94-11/96 Settling Parties
6/96-2/97 Settling Parties
Purpose/Activity

Site inspection; collected three surface water samples and one leachate
sample.

Sampled surface water, leachate, and private drinking water supplies.

Completed Preliminary Assessment and Site Investigation (PASI).

Installed groundwater monitoring wells and test pits to
characterize the shallow subsurface conditions. Sampled
groundwater, soil, and surface water.

Site inspection; sampled surface water.

Site listed on NPL.

Sampled existing monitoring wells, collected surface water,
and soil samples

Conducted soil gas survey, soil sampling in lagoon and
marshy areas, and surface water sampling.

Sampling of private drinking water supplies.

Conducted Limited Field Investigation consisting of records review,
ground-penetrating radar, air sampling and soil vapor screening.

Conducted Phase 1A and IB RI consisting of seismic refraction survey,
soil gas sampling, installation of test pits, air monitoring, installation of
monitoring wells and an ecological assessment. In addition, sampled
and analyzed soils, surface water, sediments, leachate/seeps and
groundwater.

Long Term Monitoring Program (LTMP) sampling of groundwater,
surface water, and leachate sampling. Groundwater sampling
conducted using conventional purging and sampling technigues.

Supplemental RI conducted to re-evaluate groundwater sampling
results found during the RI and LTMP sampling.
3/1998 Settling Parties
Completed Feasibility Study for the Site.

-------
                                                                   TABIiE 2

                                             CONTAMINANTS  OF POTENTIAL CONCERN FOR EACH MEDIUM AT
                                                     THE BURGESS BROTHERS SUPERFUND SITE
VOCs
Benzene
2-Butanone
Carbon Bisulfide
Carbon tetrachloride
Chlorobenzene
Chloroform
1,4-Dichlorobenzene
1,2-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethene  (total)
Methylene Chloride
4-Methyl-2-pentanone
Tetrachloroethene
Trichloroethene
ylChloride
BNAs
Acenaphthylene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Bis (2-ethylhexyl)phthalate
Inden(l,2,3-cd)pyrene
Phenanthrene
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Iron
Lead
Manganese
Thallium
Shallow
Ground
 Water
   x
   x
   x
   x
   x
   x
   x
   x

   x
   x
   x
                                            Deep
                                           Ground
                                            Water
Surface
 Soils
                            x
                            x
                            x

                            x
                            x
   x
   x
                            x
                            x
                            x
                            x
 Surface
   and
Subsurface
  Soils
                 x
                 x
                 x
                 x

                 x
                 x
                 x
                 x
                 x
                 x
Surface
 Water
                               x
                               x

                               x
                               x
                               x
                               x
                                                     x
                                                     x
                                                     x
                   x
                   x
                   x
Sediments
Leachate     Air
                 x
                 x
                 x
                 x
                                              x
                                              x
                    x
                    x

                    x
                    x
                    x
                    x
                    x
                                         x
                                         x

-------
Scenario


SHALLOW GROUND WATER

Ingestion

DEEP GROUND WATER

Ingestion

SURFACE SOILS

Ingestion
Dermal Contact
Receptor
SUMMARY OF CARCINOGENIC RISK ESTIMATED FOR THE BURGESS
                    BROTHERS  SITE

             Present/          Total  Risk          Reasonable
             Future            Average             Maximum
                          (Central Tendency)
Adjacent Resident
Adjacent Resident
Youth Trespasser
Youth Trespasser
Ingestion
Detmal Contact

SURFACE AND SUBSURFACE SOILS

Ingestion
Dermal Contact

SURFACE WATER

Ingestion
Dermal Contact

SEDIMENTS

Ingestion
Dermal Contact
Adjacent Resident
Adjacent Resident
Excavation Worker
Excavation Worker
Youth Trespasser
Youth Trespasser
Youth Trespasser
Youth Trespasser
                                IE-OS*               7E-02*
                                2E-07                1E-06
P/F
P/F
Total
F
F
Total
F
F
Total
P/F
P/F
Total
P/F
P/F
Total
5E-07
N-C,
5E-07
2E-05
NC,
2E-05
2E-07
NC,
2E-07
NC,
2E-07
2E-07
7E-08
NC,
7E-08
2E-06
NC,
2E-06
1E-04
NC,
1E-04
1E-06
NC,
1E-06
NC,
2E-06
2E-06
2E-07
NC,
2E-07
*Exceeds 10 -4 risk
NC, -Not calculated. EPA guidance calls for assessment of dermal exposure of cadmium. PCBs, and dioxins only, none of which
are Soil COCs at the Burgess Brother's Site.
NC, - Not calculated because drainage swale surface water bodies are too shallow for swimming, thus limiting the likelihood of
incidental ingestion

-------
                                                                   TABIiE 4

                                               SUMMARY OF NONCARCINOGENIC HAZARD INDICES  (His)
                                                   ESTIMATED FOR THE BURGESS BROTHERS SITE
Scenario

SHALLOW GROUND WATER

Ingestion

DEEP GROUND WATER

Ingestion

SURFACE SOILS
Receptor
Adjacent Resident
Adjacent Resident
                            Present/
                            Future
               Chronic HI
               Average
            (Central Tendency)
                 2E+01-*
                 6E-02
                  Reasonable
                  Maximum
                                     3E+02
                                     4E-01
Ingestion
Dermal Contact

Ingestion

Dermal Contact
Youth Trespasser             P/F
Youth Trespasser             P/F

Adjacent Resident  (child)     F
Adjacent Resident  (adult)     F
Adjacent Resident  (child)
Adjacent Resident  (adult)
      Total
2E-03
NC,
2E-03
6E-01
2E-02
NC,
NC,
1E-02
NC,
1E-02
6E-01
7E-02
NC,
NC,
SURFACE AND SUBSURFACE SOILS
Ingestion
Dermal Contact
Excavation Worker
Excavation Worker
                                                                Total
                 5E-02
                 NC,
                 5E-02
                    2E-01
                    NC,
                    2E-01
SURFACE WATER

Ingestion
Dermal Contact

SEDIMENTS
Youth Trespasser
Youth Trespasser
P/F
P/F
                                    Total
NC,
2E-03
2E-03
NC,
3E-02
3E-02
Ingestion
Dermal Contact
Youth Trespasser
Youth Trespasser
P/F
P/F
                                                                Total
1E-03
NC,
1E-03
3E-03
NC,
3E-03
*HI and/or HQ exceeds one  (1)
NC, - Not calculated. EPA guidance calls for assessment of dermal exposure of cadmium,  PCBs,  and  dioxins  only.
NC, - Not calculated because drainage swale surface water bodies are too  shallow  for  swimming,  thus  precluding  incidental
ingestion.

-------
TABLE 5

BURGESS BROTHERS SUPERFUND SITE
COMPARATIVE ANALYSIS SUMMARY

Compliance Long-Term
Alternative Protectiveness with ARARs Effectiveness &
Permanence

Human Health: No reduction of risks Will not achieve Federal or State Residual risks unchanged.
associated with direct contact with soil and groundwater ARARs.
ingestion of groundwater. No long-term effectiveness.
Will not achieve Federal or State
wetlands ARARs.

2. Capping and Lagoon Human Health: Reduces risks associated with Will achieve Federal and State
Treatment/Natural Attenuation direct contact with soil and ingestion of groundwater ARARS.
control.
groundwater. Institutional controls reduce
risks associated with ingestion of
groundwater. management ARARs.

Will achieve Federal and State wetlands
ARARs.

Will achieve Federal and State
groundwater ARARS.

groundwater. Institutional controls reduce
risks associated with ingestion of Will achieve State hazardous waste
groundwater. management ARARs.
4. Capping and Lagoon Human Health: Reduces risks associated with Will achieve Federal and State Residual risks reduced. Capping and groundwater
Treatment/Treatment Wall direct contact with soil and ingestion of groundwater ARARS. extraction reliable and effective for long term
control.
groundwater. Institutional controls reduce
risks associated with ingestion of
groundwater.
Long term improvement of ground water quality.
Will achieve Federal and State wetlands
ARARs.

-------
4. Capping and Lagoon
Treatment/Treatment Wall
TABLE 5

BURGESS BROTHERS SUPERFUND SITE
COMPARATIVE ANALYSIS SUMMARY

Short-Term Implementability
Effectiveness

No reduction of TMV through Lowest potential risk to community and Easiest to implement
treatment. workers.
No impact to wetlands.
No short term exposure protection
Minimal implementation time.

Minimal short-term risks to workers and
community during cap construction.

Reduction of mobility through capping. Some wetlands impacts - will require
replacement.
Reduction of TMV of groundwater
Short term exposure protection through
capping and institutional controls.

12 month implementation time.

Minimal short-term risks to workers and
community during cap construction.

Reduction of mobility through capping. Some wetlands impacts - will require
replacement.
Reduction of TMV of groundwater
through treatment, however, wastes Short term exposure protection through Specialty contractors required to
would be generated as part of the capping and institutional controls. construct GW collection trench.
Reduction of mobility through capping. Some wetlands impacts - will require Institutional controls require
replacement. cooperation of landowners.
Reduction of TMV of groundwater
through treatment, however, wastes Short term exposure protection through Specialty contractors required to
would be generated as part of the capping and institutional controls. construct treatment wall.
treatment process (replacement of spent
granular iron) 2 year implementation time.

-------









                                                APPENDIX B






                                  APPLICABLE OR REIiEVANT AND APPROPRIATE
                                           REQUIREMENTS  (ARARS)
                                                APPENDIX C
                                             STATE OF VERMONT
                                        DECLARATION OF CONCURRENCE

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                APPENDIX D

       ADMINISTRATIVE RECORD  INDEX
        Burgess Brothers Landfill
                 NPL Site

          Administrative  Record

                   Index

          Compiled: May 7,  1998
         Updated: August 28, 1998

                Prepared by
              EPA-New  England
Office of Site Remediation and Restoration

           With Assistance From
                    ads
          2070 Chain Bridge Road
             Vienna, VA 22182

-------
                                               Introduction

This document is the Index to the Administrative Record for the remedial action at the Burgess Brothers
Landfill Superfund Site. The citations in the Index are for those documents that EPA relied upon in
selecting a response action at the Site. Site-specific documents are cited in Section I of the Index, and
EPA guidance documents are cited in Section II. Documents cited in Section I of the Index arc ordered by
the Document Number that appears at the end of each citation.

The Administrative Record is available for public review at the EPA Region I Office of Site Remediation
and Restoration  (OSRR) Records Center in Boston,  Massachusetts  [(617)573-5729], and the Bennington Free
Library, 101 Silver Street, Bennington, Vermont [(802)442-9051]. The EPA guidance documents cited in
Section II are available for review only at the OSRR Records Center. The Staff of the OSRR Records Center
recommends that you set up an appointment prior to your visit.

Questions concerning the Administrative Record should be addressed to the Project Manager for the Burgess
Brothers Landfill Superfund Site.

An Administrative Record is reguired by the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) ,  as amended by the Superfund Amendments and Reauthorization Act (SARA.) .

-------
                                      Burgess Brothers Landfill Site
                                  NPL Site Remedial Administrative Record

                                             Table of Contents
Volume I

      Documents 000001-000020

Volume II

      Documents 000021-000022

Volume III

      Document 000023

Volume IV

      Document 000024

Volume V

      Document 000025

Volume VI

     Documents 000026-000029

Volume VII

     Documents 000030-000042

Volume VIII

     Documents 000043-000058

Volume IX

     Documents 000059-000062

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                                                 Section I
1.02
                                    ADMINISTRATIVE RECORD INDEX
                                     BURGESS BROTHERS LANDFILL
                                                                          08/28/98
                                                                        Page     1
        SITE ASSESSMENT - PRELIMINARY ASSESSMENT
        Title:    Potential Hazardous Waste Site Preliminary Assessment Form.
        Authors:  US EPA REGION I
        Date:     April 4, 1984
        Format:   FORM                         No. Pgs:  4
        AR No.    01.02.1                      Document No.  000001
1.03
SITE ASSESSMENT - SITE INSPECTION/INVESTIGATION
        Title:     Site Analysis, Burgess Brothers Landfill, Bennington County, Vermont.
        Authors:   US EPA REGION I
        Date:      May 1991
        Format:    REPORT, STUDY               No. Pgs:  38
        AR No.     01.03.1                     Document No.  000002
1.05
        SITE ASSESSMENT - CORRESPONDENCE RELATED TO SITE ASSESSMENT
        Title:     Burgess Brothers Landfill, Woodford, VT, National Priorities List Form.
        Authors:   US EPA RI REMEDIAL RESPONSE PROGRAM
        Date:      November 1988
        Format:    FORM                        No. Pgs:  1
        AR No.     01.05.1                     Document No.  000003
3.01
        REMEDIAL INVESTIGATION - CORRESPONDENCE
        Title:     Reguest to Revise the Remedial Investigation Work Plan.
        Addressee: SHEILA M. ECKMAN - US EPA RI WASTE MANAGEMENT DIVISION
        Authors:   CHERYL, L. CUNDALL - O'BRIEN & GERE ENGINEERS, INC.
        Date:      September 25, 1992
        Format:    CORRESPONDENCE              No. Pgs:  5
        AR No.     03.01.1                     Document No.  000004

        Title:     Transmittal of Remedial Investigation Documents.
        Addressee: SUSAN PAJU - BENNINGTON FREE LIBRARY
        Authors:   RONALD JENNINGS - US EPA REGION I
        Date:      October 1, 1992
        Format:    CORRESPONDENCE              No. Pgs:  1
        AR No.     03.01.2                     Document No.  000005

        Title:     Review of Chromium Data for Sediment Sampling.
        Addressee: RONALD JENNINGS - US EPA REGION I
        Authors:   CHERYL L. CUNDALL - O'BRIEN & GERE ENGINEERS, INC.
        Date:      October 14, 1992
        Format:    CORRESPONDENCE              No. Pgs:  4
        AR No.     03.01.3                     Document No.  000006

        Title:     Evaluation of Soil Vapor Study Results.
        Addressee: RONALD JENNINGS - US EPA REGION I
        Authors:   CHERYL L. CUNDALL - O'BRIEN & GERE ENGINEERS, INC.
        Date:      October 19, 1992
        Format:    CORRESPONDENCE              No. Pgs:  7
        AR No.     03.01.4                     Document No.  000007
        Title:     Proposal to Modify Sampling Parameters.
        Addressee: RONALD JENNINGS - US EPA REGION I
        Authors:   CHERYL L. CUNDALL - O'BRIEN & GERE ENGINEERS, INC.
        Date:      October 20, 1992
        Format:    CORRESPONDENCE               No. Pgs:  3
        AR No.     03.01.5                      Document No.  000008

-------
        Title:
Approval to Modify Sampling Activities.
        Addressee: RONALD JENNINGS - US EPA REGION I
        Authors:   CHERYL L. CUNDALL - O'BRIEN & GERE ENGINEERS, INC.
        Date:      October 21, 1992
        Format:    CORRESPONDENCE               No. Pgs:   2
        AR No.     03.01.6                      Document No.  000009

        Title:     Conditional Approval of work plan revision.
        Addressee: CHERYL L. CUNDALL - O'BRIEN & GERE ENGINEERS, INC.
        Authors:   RONALD JENNINGS - US EPA REGION I
        Date:      October 23, 1992
        Format:    CORRESPONDENCE               No. Pgs:   2
        AR No.     03.01.7                      Document No.  000010

        Title:     Road Construction Approval.
        Addressee: CHERYL L. CUNDALL - O'BRIEN & GERE ENGINEERS, INC.
        Authors:   RONALD JENNINGS - US EPA REGION I
        Date:      December 8, 1992
        Format:    CORRESPONDENCE               No. Pgs:   3
        AR No.     03.01.8                      Document No.  000011

        Title:     Conditional Permission to Construct a Stream Crossing.
        Addressee: ROBERT GANLEY - O'BRIEN & GERE ENGINEERS, INC.
        Authors:   RONALD JENNINGS - US EPA REGION I
        Date:      March 29, 1993
        Format:    CORRESPONDENCE               No. Pgs:   2
        AR No.     03.01.9                      Document No.  000012

        Title:     Sampling Reguirements Between Phase 1A & Phase IB.
        Addressee: ROBERT GANLEY - O'BRIEN & GERE ENGINEERS, INC.
        Authors:   MARY J 0'DONNELL - US EPA REGION I
        Date:      October 26, 1993
        Format:                                 No. Pgs:   2
        AR No.     03.01.10                     Document No.  000013

        Title:     Conditional Approval of Phase 1A Deliverables.
        Addressee: GEOFF SEIBEL - DE MAXIMUS, INC.
        Authors:   MARY  J 0'DONNELL - US EPA REGION I
        Date:      April 14, 1994
        Format:    CORRESPONDENCE               No. Pgs:   3
        AR No.     03.01.11                     Document No.  000014
3.02
        REMEDIAL INVESTIGATION - SAMPLING & ANALYSIS DATA
        Title:
        Format:
        AR No.
Sampling and Anaysis Data.
                   03.02.1
                             No. Pgs:  1
                             Document No.  000015
        Title:     Ground Penetrating Radar Survey, Burgess Brothers Landfill Site, Woodford and
                   Bennington, Vermont.
        Addressee: US EPA REGION I
        Authors:   HAGER-RICHTER GEOSCIENCE, INC.
        Date:      January 1992
        Format:    REPORT, STUDY                No. Pgs:  14
        AR No.     03.02.2                      Document No. 000016
        Title:

        Addressee:
        Authors:
        Date:
        Format:
        AR No.
Soil Vapor Extraction System Pilot Study Summary Report, Burgess Brothers Landfill
Site.
US EPA REGION I
ENVIRONMENTAL RESOURCES MANAGEMENT
May 12, 1997
REPORT, STUDY
                   03.02.3
No. Pgs:  14
Document No. 000017

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03.04
        REMEDIAL INVESTIGATION - INTERIM DELIVERABLES
        Title:      Health and Safety Plan, Limited Field Investigation, Burgess Brothers Landfill
                   Superfund Site, Woodford/Bennington, Vermont.
        Addressee: US EPA REGION I
        Authors:    O'BRIEN & GERE ENGINEERS, INC.
        Date:      December 1991
        Format:     REPORT, STUDY                No. Pgs:   20
        AR No.      03.04.1                      Document No. 000018

        Title:      Final Health and Safety Plan, Remedial Investigation/Feasibility Study, Burgess
                   Brothers Site.
        Addressee: US EPA REGION I
        Authors:    O'BRIEN & GERE ENGINEERS, INC.
        Date:      September 1992
        Format:     REPORT, STUDY                No. Pgs:   39
        AR No.      03.04.2                      Document No. 000019

        Title:      Quality Assurance Project Plan, Remedial Investigation, Burgess Brothers Site,
                   Woodford and Bennington, Vermont.
        Addressee: US EPA REGION I
        Authors:    O'BRIEN & GERE ENGINEERS, INC.
        Date:      September 1992
        Format:     REPORT, STUDY                No. Pgs  243
        AR No.      03.04.3                      Document No. 000020

        Title:      Quality Assurance Project Plan, Addendum No. 1, Phase IB Investigation, Burgess
                   Brothers Superfund Site.
        Addressee: US EPA REGION I
        Authors:    O'BRIEN & GERE ENGINEERS, INC.
        Date:      April 1994
        Format:     REPORT, STUDY                No. Pgs:   33
        AR No.      03.04.4                      Document No.  000021
03.06
        REMEDIAL INVESTIGATION - REMEDIAL INVESTIGATION REPORTS
        Title:      Final Remedial Investigation Report, Volume I - Text, Tables, and Figures, Burgess
                   Brothers Superfund Site, Woodford and Bennington, Vermont.
        Addressee: US EPA REGION I
        Authors:    O'BRIEN & GERE ENGINEERS, INC.
        Date:      July 1996
        Format:     REPORT, STUDY                No. Pgs: 413
        AR No.      03.06.1                      Document No.  000022

        Title:      Final Remedial Investigation Report, Volume II - Appendices, Burgess Brothers
                   Superfund Site.
        Addressee: US EPA REGION I
        Authors:    0' BRIEN & GERE ENGINEERS, INC.
        Date:      July 1996
        Format:     REPORT, STUDY                No. Pgs: 747
        AR No.      03.06.2                      Document No.  000023

        Title:      Final Remedial Investigation Report, Volume 3 - Appendices, Burgess Brothers Superfund
                   Site.
        Addressee: US EPA REGION I
        Authors:    O'BRIEN & GERE ENGINEERS, INC.
        Date:      July 1996
        Format:     REPORT, STUDY                No. Pgs: 645
        AR No.      03.06.3                      Document No.  000024
        Title:      Draft Supplemental Remedial Investigation Report, Volume I, Revision 2, Burgess
                   Brothers Superfund Site with Transmittal Letter.
        Addressee: US EPA REGION I
        Authors:    ERM-NEW ENGLAND, INC.
        Date:      February 21,  1997
        Format:     REPORT,  STUDY                No. Pgs: 228
        AR No.      03.06.4                       Document No.  000025

-------
        Title:

        Addressee:
        Authors:
        Date:
        Format:
        AR No.
Draft Supplemental Remedial Investigation Report, Volume II, Revision 2, Burgess
Brothers Superfund Site.
US EPA REGION I
ERM-NEW ENGLAND, INC.
             1997
                             No. Pgs: 276
                             Document No.  000026
February 21,
REPORT,  STUDY
03.06.5
03.07   REMEDIAL INVESTIGATION - WORK PLANS AND PROGRESS REPORTS

        Title:      Work Plan,  Limited Field Investigation, Burgess Brothers Superfund Site.
        Addressee:  US EPA REGION I
        Authors:   O'BRIEN & GERE ENGINEERS, INC.
        Date:       December 1991
        Format:     WORK PLAN                    No. Pgs:  61
        AR No.      03.07.1                      Document No.  000027

        Title:      Work Plan,  Final, Remedial Investigation, Burgess Brothers Superfund Site.
        Addressee:  US EPA REGION I
        Authors:   O'BRIEN & GERE ENGINEERS, INC.
        Date:       September 1992
        Format:     REPORT, STUDY                No. Pgs: 114
        AR No.      03.07.2                      Document No.  000028
        Title:
Well Drilling Program Modification.
        Addressee:  RONALD JENNINGS - US EPA REGION I
        Authors:    ROBERT GANLEY - O'BRIEN & GERE ENGINEERS, INC.
        Date:       April 8,  1993
        Format:     CORRESPONDENCE               No. Pgs: 5
        AR No.      03.07.3                      Document No. 000029

        Title:      Work Plan Phase IB Investigation, Burgess Brothers Superfund Site.
        Addressee:  US EPA REGION I
        Authors:    O'BRIEN & GERE ENGINEERS, INC.
        Date:       April 1994
        Format:     WORK PLAN                    No. Pgs: 50
        AR No.      03.07.4                      Document No. 000030

        Title:      Final Long-Term Monitoring Plan, Remedial Investigation, Burgess Brothers Superfund
                   Site.
        Addressee:  US EPA REGION I
        Authors:    O'BRIEN & GERE ENGINEERS, INC.
        Date:       April 1994
        Format:     WORK PLAN                    No. Pgs: 15
        AR No.      03-07.5                      Document No. 000031

        Title:      Risk Assessment Work Plan, Burgess Brothers Superfund Site, Woodford and Bennington,
                   Vermont.
        Addressee:  US EPA, REGION I
        Authors:    TRC COMPANIES, INC.
        Date:       June 1994
        Format:     REPORT, STUDY                No. Pgs: 21
        AR No.      03.07.6                      Document No. 000032

        Title:      Risk Assessment Work Plan, Addendum, Burgess Brothers Superfund Site.
        Addressee:  US EPA REGION I
        Authors:    ERM-NEW ENGLAND, INC.
        Date:       July 1996
        Format:     REPORT, STUDY                No. Pgs: 3
        AR No.      03.07.7                      Document No.  000033
        Title:      Soil Vapor Extraction Pilot Study, Burgess Brothers Superfund Site.
        Addressee:  US EPA REGION I
        Authors:    ERM-NEW ENGLAND, INC.
        Date:       September 20, 1996
        Format:     WORK PLAN                    No. Pgs: 90
        AR No.      03.07.8                      Document No.  000034

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        Title:     Risk Assessment Work Plan, Addendum, Burgess Brothers Superfund Site.
        Addressee: US EPA REGION I
        Authors:   ERM-NEW ENGLAND, INC.
        Date:      October 1996
        Format:    REPORT, STUDY                No. Pgs:  3
        AR No.     03.07.9                      Document No.  000035

        Title:     Comments Concerning the Soil Vapor Extraction Pilot Study Work Plan.
        Addressee: RONALD JENNINGS - US EPA REGION I
        Authors:   PATRICE SVETAKA - METCALF & EDDY, INC.
        Date:      October 8, 1996
        Format:    CORRESPONDENCE               No. Pgs:  2
        AR No.     03.07.10                     Document No.  000036

        Title:     Reguest for Approval to Modify the SVE Pilot Study Off-Gas Treatment.
        Addressee: RONALD JENNINGS - US EPA REGION I
        Authors:   GEOFF SEIBEL - DE MAXIMUS, INC.
        Date:      October 14, 1996
        Format:    CORRESPONDENCE               No. Pgs:  5
        AR No.     03.07.11                     Document No.  000037

        Title:     Response to EPA Approval of SVE Work Plan and Addendum 1.
        Addressee: RONALD JENNINGS - US EPA REGION I
        Authors:   MARK WHITE - STATE OF VERMONT
        Date:      November 15, 1996
        Format:    CORRESPONDENCE               No. Pgs:  3
        AR No.     03.07.12                     Document No.  000038

        Title:     Risk Assessment Work Plan, Addendum, Burgess Brothers Superfund Site.
        Addressee: US EPA REGION I
        Authors:   ERM-NEW ENGLAND, INC.
        Date:      March 1997
        Format:    REPORT, STUDY                No. Pgs:  3
        AR No.     03.07.13                     Document No.  000039
3.09
        REMEDIAL INVESTIGATION - HEALTH ASSESSMENTS
        Title:     Preliminary Health Assessment for Burgess Brothers Landfill, Woodford, Bennington
                   County, Vermont with Transmittal Letter.
        Addressee: US EPA REGION I
        Date:      December 27, 1991
        Format:    REPORT, STUDY                No. Pgs: 17
        AR No.     03.09.1.                     Document No.  000040

03.10  REMEDIAL INVESTIGATION - ENDANGERMENT/BASELINE RISK ASSESSMENTS

       Title:      Risk Assessment Addendum, Burgess Brothers Superfund Site Bennington/Woodford,
                   Vermont.
       Addressee:   US EPA REGION I
       Format:     REPORT, STUDY                No. Pgs: 13
       AR No.      03.10.:!                     Document No.  000041

       Title:      Risk Assessment, Volume 1, Burgess Brothers Superfund Site, Woodford, Vermont.
       Addressee:   US EPA REGION I
       Date:       April 1997
       Format:     REPORT, STUDY                No. Pgs: 189
       AR No.      03.10.2                      Document No.  000042
       Title:      Risk Assessment, Volume 2, Burgess Brothers Superfund Site, Woodford, Vermont,
       Addressee:  US EPA REGION I
       Date:       April 1997
       Format:     REPORT,  STUDY                No. Pgs: 181
       AR No.      03.10.3                      Document No.  000043

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       Title:      Risk Assessment - Addendum 2, Burgess Brothers Superfund Site, Bennington and
                   Woodford, Vermont.
       Authors:    US EPA REGION I
       Date:       May 1997
       Format:      REPORT,  STUDY                No. Pgs: 3
       AR No.      03.10.4                       Document No.  000044

04.06  FEASIBILITY STUDY -  FEASIBILITY STUDY REPORTS

       Title:      Final Feasibility Study Report, Burgess Brothers Superfund Site, Woodford and
                   Bennington,  Vermont.
       Addressee:  US EPA RI WASTE MANAGEMENT DIVISION
       Authors:    ERM-NEW ENGLAND, INC.
       Date:       March 20, 1998
       Format:      REPORT,  STUDY                No. Pgs: 393
       AR No.      04.06.1                       Document No.  000059

04.09  FEASIBILITY STUDY -  PROPOSED PLANS FOR SELECTED REMEDIAL ACTION

       Title:      Proposed Plan for the Burgess Brothers Superfund Site.
       Authors:    US EPA REGION I
       Date:       June 1998
       Format:      REPORT,  STUDY                No. Pgs: 13
       AR No.      04.09.1                       Document No.  000060

5.03   RECORDS  OF DECISION - RESPONSIVENESS SUMMARIES
       Title:      Comments on Proposed Plan.
       Addressee:  US EPA REGION I
       Authors:    JANET THOMPSON
       Date:       July 1998
       Format:      MEMORANDUM
       AR No.      05.03.1
No. Pgs: 2
Document No.  000061
       Title:      Comments on Proposed Plan.
       Addressee:  US EPA REGION I
       Authors:    DONALD DAVIS
       Date:       July 1998
       Format:      MEMORANDUM
       AR No.      05.03.2
No. Pgs: 2
Document No.  000062
09.01 STATE COORDINATION - CORRESPONDENCE

      Title:       Comments on the Limited Field Investigation Work Plan.
      Addressee:   SHEILA M. ECKMAN - US EPA REGION I
      Authors:      DAVE SHEPARD - STATE OF VERMONT
      Date:        November 1, 1991
      Format:      CORRESPONDENCE               No. Pgs: 9
      AR No.       09.01.1                      Document No.  000045

      Title:       Comments on the Final Limited Field Investigation Work Plan.
      Addressee:   SHEILA M. ECKMAN - US EPA REGION I
      Authors-      DAVE SHEPARD - STATE OF VERMONT
      Date:        December 31, 1991
      Format:      MEMORANDUM                   No. Pgs: 2
      AR No.       09.01.2                      Document No.  000046
      Title:       Comments Concerning the Design of the Proposed Soil Vapor Extraction.
      Addressee:   RONALD JENNINGS -  US EPA REGION I
      Authors:      LYNDA PROVENCHER -  STATE OF VERMONT
      Date:        October 16,  1996
      Format:      CORRESPONDENCE            No. Pgs: 1
      AR No.       09.01.3                   Document No.  000047

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10.01 ENFORCEMENT/NEGOTIATION - CORRESPONDENCE

      Title:        Request for a Copy of the Proposed Administrative Settlement.
      Addressee:    RONA GREGORY - US EPA REGION I
      Authors:      WILLIAM A. SHIRLEY
      Date:         June 18, 1992
      Format:       LETTER                    No. Pgs:  3
      AR No.        10.01.1                   Document No.  000055

      Title:        Request for Copy of Proposed Administrative Settlement.
      Addressee:    RONA GREGORY - US EPA REGION I
      Authors:      EVELYN BROWN - COHEN, SHAPIRO, POLISHER, SHIEKMAN, AND
      Date:         July 6, 1992
      Format:       LETTER                    No. Pqs:  2
      AR No.        10.01.2                   Document No.  000056

      Title:        Proposed Administrative Settlement Request.
      Addressee:    RONA GREGORY - US EPA REGION I
      Authors:      KELLY E. GALE COLL DAVIDSON CARTER SMITH SALTER & BRAG
      Date:         Auqust 3, 1992
      Format:       LETTER                    No. Pqs:  2
      AR No.        10.01.3                   Document No.  000057

      Title:        Transmittal of Proposed Administrative Settlement Docket No. 1-91-1101.
      Addressee:    KINSEL LIBRARIAN - METCALF & EDDY,  INC.
      Authors:      RONA GREGORY - US EPA REGION I
      Date:         September 11, 1992
      Format:       LETTER                    No. Pqs:  1
      AR No.        10-01.4                   Document No.  000058

10.07 ENFORCEMENT/NEGOTIATION - EPA ADMINISTRATIVE ORDERS

      Title:        Administrative Order by Consent for Remedial Investiqation/Feasibility Study, US EPA
                   Docket No. 1-91-1101.
      Authors:      US EPA REGION I
      Date:         Auqust 27, 1991
      Format:       LITIGATION                No. Pqs:  53
      AR No.        10.07.1                   Document No.  000048

      Title:       Administrative Aqreement for Cost Recovery, US EPA Reqion I CERCLA Docket No. 1101.
      Authors:     US EPA REGION I
      Date:        Auqust 20, 1992
      Format:      LITIGATION                 No. Pqs:  12
      AR No.       10.07.2                    Document No.  000049

10.09 ENFORCEMENT/NEGOTIATION - PLEADINGS

      Title:       Complaint, Eveready Battery Company, Inc.,  Plaintiff v. United States of America,
                  et al.
      Authors:     US EPA REGION I
      Date:        Auqust 11, 1994
      Format:      LITIGATION                 No. Pqs:  24
      AR No.       10.09.1                    Document No.  000050

13.02 COMMUNITY RELATIONS - COMMUNITY RELATIONS PLANS

       Title:     Community Relations Plan, Burqess Brothers Site, Benninqton, VT.
       Authors:  US EPA REGION I
       Date:      February 1995
       Format:    REPORT, STUDY                      No. Pqs:  15
       AR No.     13.02.1                            Document No.  000051

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16.01  NATURAL RESOURCE TRUSTEE - CORRESPONDENCE

       Title:     Contaminant Release Notification.
       Addressee: KENNETH FINKLESTEIN - NATIONAL OCEANIC & ATMOSPHERIC ADMINISTRATION
       Authors:   MERRILL S. HOHMAN - US EPA REGION I
       Date:       April 29,  1991
       Format:    CORRESPONDENCE                    No. Pgs:  2
       AR No.     16.01.1                           Document No.  000052

       Title:     Contamination Release Notification.
       Addressee: WILLIAM PATTERSON - US DEPARTMENT OF THE INTERIOR
       Authors:   MERRILL S. HOHMAN - US EPA REGION I
       Date:       April 29,  1991
       Format:    CORRESPONDENCE                    No. Pgs:  2
       AR No.     16.01.2                           Document No.  000053

17.05  SITE MANAGEMENT RECORDS - SITE DESCRIPTIONS/CHRONOLOGIES
       Title:
       Authors:
       Date:
       Format:
       AR No.
Site Description, Burgess Brothers Landfill, Woodford, Vermont.
US EPA REGION I
MISCELLANEOUS
17.05.1
No. Pgs: 2
Document No.  000054

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                                                Section II

                                            GUIDANCE DOCUMENTS

The EPA guidance documents listed below were considered during the process of selecting the response
action for the Burgess Brothers Landfill Superfund Site. These EPA guidance documents may be reviewed at
the EPA Region I Office of Site Remediation and Restoration Records Center, 90 Canal Street, Boston, MA
02114.

1.     Air Stripper Control Guidance,  Gitto,  Louis F.  OSWER # 9355.0-28. July 12, 1989. [C110]

2.     ARARs Fact Sheet: Compliance with the Clean Air Act and Associated Air Quality Reguirements.
       September 1, 1992.  [C281]

3.     ARARs Q's and A's (Quick Reference Fact Sheet).  OSWER # 9234.2-01FS. May 1, 1989. [3006]

4.     ARARs Q's and A's: Compliance with Federal Water Quality Criteria, Office of Solid Waste and
       Emergency Response. OSWER # 9234.2-09/FS.  June 1, 1990. [C192]

5.     CERCLA Compliance with Other Laws Manual (Draft), Office of Emergency and Remedial Response.  OSWER
       # 9234.1-01. August 8, 1988. [3002]

6.     CERCLA Compliance with Other Laws Manual Part II: Clean Air Act and Other Environmental Statutes
       and State Reguirements. OSWER # 9234.1-02. August 1, 1989. [3013]

7.     Comprehensive Environmental Response,  Compensation and Liability Act of 1980 as Amended by
       PL-99-499, October 17, 1986. October 17, 1986.  [C018]

8.     Conducting Remedial Investigations/Feasibility Studies for CERCLA Municipal Landfill Sires. OSWER
       # 9355.3-11. February 1, 1991.   [C177]

9.     Interim Final Guidance For Conducting Remedial  Investigations and Feasibility Studies Under
       CERCLA, Office of Solid Waste and Emergency Response/Office of Emergency and Remedial Response.
       OSWER # 9355.3-01.  [2002]

10.    National Oil and Hazardous Substances Pollution Contingency Plan. [C063]

11.    Presumptive Remedy for CERCLA Municipal Landfill Sites. OSWER # 9355.049FS. September 1,  1993.
       [C157]

12.    Risk Assessment Guidance for Superfund, Volume  I. Human Health-Evaluation Manual (Part A) .  Interim
       Final.  (EPA/540/1-89/002). December 1, 1989. [C174]

13.    Risk Assessment Guidance for Superfund, Volume  II,  Environmental Evaluation Manual.
       (EPA/540/1-89/001). March 1, 1989. [5024]

14.    Streamlining the RI/FS for CERCLA Municipal Landfill Site. OSWER # 9355.3-11FS. September 1,  1990.
       [C176]

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                                                APPENDIX E

                                           RESPONSIVENESS SUMMARY

                                      BURGESS BROTHERS SUPERFUND SITE

                                               SEPTEMBER  1998

                                             TABLE OF CONTENTS


I.     OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE  FS AND
       PROPOSED PLAN 	2

II.     BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS  	4

III.    SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES	8

IV.     CHANGES IN SELECTED REMEDY BASED ON PUBLIC CONCERNS  	10


Attachments

A      List of Formal Community Relations Activities Conducted  to  Date  at  the  Burgess
       Brothers Superfund Site 	A-l

B      Transcript From the June 23, 1998 Public Hearing  	B-l

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                               BURGESS BROTHERS DRAFT RESPONSIVENESS SUMMARY

                                                  PREFACE

The U.S. Environmental Protection Agency  (EPA) held a 30-day public comment period from June 15 to July
15, 1998 to provide an opportunity for public comment on the Proposed Plan to address contamination at
the Burgess Brothers Superfund Site in Bennington and Woodford, Vermont  (the "Site"). The 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 June 10, 1998, presented the EPA's preferred
alternative for the site before the start of the public comment period. All documents which were used in
the EPA's selection of the preferred alternative were placed in the site Administrative Record, which is
available for public review at the EPA Records Center, 90 Canal Street, Boston, Massachusetts, and at the
Bennington Free Library, 101 Silver Street, Bennington, Vermont.

The purpose of this Responsiveness Summary is to document the EPA's responses to the guestions and
comments raised during the public comment period. The EPA considered all of the comments summarized 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 FS and Proposed Plan, including the
       Preferred Alternative - This section briefly outlines the remedial alternatives evaluated in the
       FS and the Proposed Plan,  including the 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.

III.   Summary of Comments Received During the Public Comment Period - This section summarizes and
       provides the EPA's responses to the oral and written comments received from the public during the
       comment period.

IV.    Changes in Selected Remedy Based on Public Comments - This section summarizes changes that  were
       made to the preferred remedy in the Proposed Plan based on EPA' s consideration of the comments
       received during the public comment period.

In addition, two attachments are included with this Responsiveness Summary. Attachment A lists community
participation activities conducted by the EPA and VT DEC to date at the site. Attachment B contains a
copy of the transcript from the public hearing held on Tuesday, June 23, 1998 in Bennington, Vermont.  The
original comments submitted by citizens, the State of Vermont, and PRPs are available in the
Administrative Record.

I.     OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE FS AND PROPOSED PLAN

Using information gathered during the RI and the Risk Assessment, the EPA identified several cleanup
objectives for the Burgess Brothers Site.

The primary cleanup objectives are to reduce risks to public health and the environment by 1) preventing
direct exposures to contaminated materials on site; 2) minimizing the movement of contamination away from
the site; and 3) preventing use of groundwater which might pose a risk to human health. Cleanup levels
for groundwater are set at levels that the EPA and VT DEC consider protective of human health and the
environment.

After identifying the cleanup objectives, the EPA developed and evaluated potential cleanup alternatives
to address site contamination. The FS describes the cleanup alternatives and the criteria the EPA used to
narrow the list of four potential alternatives to control sources of contamination and address migration
of contaminants off site.

The EPA's Proposed Alternative, Alternative 2, includes the following features:

       •    A multi-barrier  (or "composite barrier") cap over the Landfill Area.

       •    A cap over the soils in the Marshy Area;

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• Hot spot remediation of the Former Lagoon Cells within the Landfill Area using soil-vapor
extraction (SVE) and air sparging;

• Natural attenuation of contaminated groundwater beyond the area of influence of the SVE and
air sparging system;

• Long-term monitoring of the groundwater, surface water, sediments, and soil gas to evaluate
the overall effectiveness of the remedy;

• A review of the Site every five years after the initiation of the remedial action to assure
that the remedial action continues to protect human health and the environment.

In the Feasibility Study Report, the estimated net present worth of the remedy is $3,600,000. This
alternative was selected because it achieved the best balance among the criteria with which EPA is
reguired by law to evaluate clean-up options. The selected remedy provides an effective reduction in
human health risk through a combination of source control (capping and SVE/air sparging) and management
of contaminant migration (natural attenuation of groundwater) technologies. The remedy will attain
Federal and State cleanup standards, reduce the toxicity of contaminated groundwater, and utilize
permanent solutions to the extent possible.

The following other alternatives were evaluated in detail in the FS:

• Alternative 1: No Action - Under this alternative, no containment or treatment of the
landfill or lagoon soils would occur and no effort would be made to control the migration of
contaminated groundwater.

• Alternative 3: Capping and Lagoon Treatment/Pump and Treat - Alternative 3 is similar to
Alternative 2, with the exception of the approach to address contaminated groundwater. This
Alternative includes the extraction of groundwater and construction of a water treatment
facility to actively address groundwater contamination. The groundwater would be treated and
discharged.

• Alternative 4 - Capping and Lagoon Treatment/Treatment Wall - Alternative 4 is also similar
to Alternative 2, with the exception of the approach to address contaminated groundwater.
This Alternative includes the construction of a subsurface treatment wall that would allow
groundwater to flow through under natural flow conditions. The materials in the treatment
wall would treat the contaminated groundwater.

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 FS.

II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

Site Description/History

The Burgess Brothers Superfund Site (the "Site") is located in the towns of Woodford and Bennington,
Bennington County, Vermont, between Burgess Road and the Walloomsac Brook. Access to the Site is through
the Burgess Brothers Construction Company's facility on Burgess Road, approximately 1.1 miles southeast
of the junction of Burgess Road and State Highway 9. The Green Mountain National Forest borders the Site
to the north. The latitude of the Site is 42552'40" and the longitude is 73509'00". The Site consists of
approximately three acres located in the northeastern section of a 60-acre parcel which is owned by Clyde
Burgess, Jr.

The Site includes the following six areas:

• Landfill Area - which is the waste disposal area.
• Lagoon Area - former lagoon cells which are located within the Landfill Area. This area
consists of two former waste disposal cells where solvent and reserve energizer battery waste
were reportedly disposed.
• Soil Staging Area - located north of the Landfill Area.
• Area West of Landfill - includes the areas to the west of the Landfill Area, downslope of the
landfill, and in the vicinity of a temporary access Landfill Road.

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• Marshy Area - located south and southeast downslope of the landfill and consists of several
small wetland areas.
• Hillside Area - includes areas upslope and to the east of the Marshy Area and Landfill Area
on Harmon Hill.

As stated above, the Site consists of approximately three acres. The Landfill Area occupies approximately
two acres which includes the two former Lagoon Cells. The Lagoon Cells occupy approximately 4,000 sguare
feet (0.09 acres) of the landfill. The marshy area and area impacted by the contaminated groundwater
plume occupy approximately one acre beyond the Landfill Area. Both the landfill and lagoon cells have
been covered with clean soils from the Burgess Brothers property.

Activities at the Site began as sand and gravel mining operations in the 1940s. Beginning in the early
1950's the site was used as a metal salvage facility and as a disposal area for construction debris.
Starting in the 1960's metals, sludges, and rejected small appliance batteries were also disposed at the
Site. The two Lagoon Cells (unlined pits) received liguid wastes and sludge from approximately 1967 to
1976. These wastes consisted of lead sludges, lead contaminated wastewater, spent solvents (primarily PCE
and TCE) , and battery waste. Manganese dioxide cells (containing zinc and mercury) were also disposed.
Approximately 2,371,100 gallons of liguid waste and 241,090 pounds of solid or semi-solid wastes were
disposed of at the Site from 1971-1976. An unknown guantity of waste, primarily lead sludge, was also
disposed of at the Site from the 1960's through 1971.

Numerous investigations have been performed at the Site to evaluate the environmental impact of the
disposal operation which occurred in the Landfill Area and former Lagoon Cells. VTAEC inspected the Site
several times during the late 1960's and 1970's to evaluate disposal practices and environmental impacts.
In August 1976, VTAEC disallowed disposal operations at the Site.

From 1984 - 1989, preliminary investigations and periodic monitoring of soil, surface water, groundwater,
and leachate were performed by the State, EPA, and Union Carbide Corporation.

VTDEC (then VTAEC) conducted a Preliminary Assessment in 1985 and EPA proposed the Site for listing on
the NPL on June 24, 1988. On March 31, 1989 the Site was added to the National Priorities List.

On May 10, 1991, EPA notified five parties who either owned or operated the facility, generated wastes
that were shipped to the facility, arranged for the disposal of wastes at the facility, or transported
wastes to the facility, of their potential liability with respect to the Site. Negotiations commenced
with these potentially responsible parties (PRPs) regarding the PRPs' performance of an RI/FS at the
Site.

On August 13, 1991, EPA, entered into an Administrative Order by Consent with three of the PRPs for the
performance of a Remedial Investigation and Feasibility Study (RI/FS). These three PRPs agreed to conduct
and pay for the RI and FS, and to reimburse EPA for the cost of overseeing the investigations. These PRPs
also agreed to pay for a portion of past costs at the site. The EPA will continue to negotiate with all
of the PRPs to fund the site cleanup.

The RI consisted of a series of field investigations to further evaluate the nature and extent of
contamination related to the site. Consistent with the EPA's "presumptive remedy approach," EPA
determined that the landfill would be covered with a cap to contain the waste materials; therefore,
extensive sampling of the landfill was not necessary. The RI confirmed that the Landfill Area, Lagoon
Area, and Marshy Area soils were contaminated with VOCs, semi-volatile organic compounds (SVOCs), and
metals. The highest contaminant concentrations in soil were detected in the Lagoon Area. Groundwater
samples from overburden monitoring wells also contained a variety of VOCs, SVOCs, and metals; many of
these contaminants were detected at levels above Federal and State drinking water standards Private wells
located downgradient of the site and two public water, supply sources, Ryder Spring and Morgan Spring,
were sampled and determined to not be affected by site related contamination. The RI also indicated that

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surface water and sediments hi the swales and unnamed stream that runs along the eastern side of the
landfill contained concentrations of VOCs and metals.

Studies of the site hydrogeology indicated that contaminated groundwater beneath the landfill enters the
soils in the Marshy Area and empties into the swales and unnamed stream. The zone of contamination, or
plume, is gradually spreading to the south and west as the groundwater flows through the overburden. The
area of contamination is slightly south of well cluster W-09.

The 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 health risks to people currently exposed to contamination at the landfill. However,
the EPA has determined that if in the future, residential development were to occur closer to the
landfill area and new drinking water wells were installed, unacceptable cancer and noncancer health
effects would be associated with household use of the contaminated groundwater.

The ecological risk assessment indicated that levels of contaminants in leachate, soils, and sediments in
the Marshy Area, swales, and unnamed stream pose an unacceptable risk to some types of wildlife.

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 fact sheets,
press releases, and public meetings. On June 10, 1998, EPA issued a Proposed Plan for the cleanup of the
site.

On June 11, 1998, EPA published a notice and brief analysis of the Proposed Plan in the Bennington
Banner. On June 15, 1998 EPA made the Proposed Plan and Administrative Record available to the public by
placing a copy in the Bennington Free Library, Bennington, Vermont, and at EPA's office in Boston. On
June 23, 1998, EPA held an informational meeting/public hearing at the Bennington Free Library to discuss
the results of the Remedial Investigation and the cleanup alternatives presented in the Feasibility
Study. During this meeting EPA presented the Proposed Plan and accepted oral comments. Approximately 12
people attended the meeting. The public comment period ran from June 15 through July 15, 1998.

Public Reaction to the EPA' s Preferred Alternative

There was general support for EPA's Proposed Plan, although very few comments were received. Specific
issues raised are discussed below.

III.   SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES

This Responsiveness Summary addresses comments pertaining to the Proposed Plan and FS which were received
by the EPA during the public comment period  (June 15 to July 15, 1998).  Approximately twelve
individuals, including representatives of VT DEC, PRPs, a local newspaper, EPA, and area residents
attended the meeting. No oral comments were provided during the public hearing. Two sets of written
comments were received by the EPA during the comment period. These comments are presented and addressed
below:

Comment #1: A citizen raised a concern related to site access. He had seen children fishing in the
streams very near the site and felt that this should not be allowed.

Response: Institutional controls proposed in the selected alternative will include restricting site
access. This will include a chain link fence or similar device surrounding the perimeter of the site
which should address this type of activity as well as other trespassers.

Comment #2: A citizen guestioned how the contamination at the Site would be contained and remediated.

Response: The selected remedy will reguire capping the landfill area and marshy area soils which will
adeguately contain the contamination within the site boundary. Remediation will include soil vapor
extraction and air sparging to remove VOCs from the lagoon area soils as well as natural attenuation of
groundwater.

Comment #3: A citizen asked where the contamination from the site was to be transported.

Response: There will be no transportation of site contamination. All site contamination will be contained
and treated on-site. Transportation of some material used in a treatment processes, such as spent organic
carbon, may occur depending on the treatment, method determined during design. Any transportation of

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these types of material is expected to be done by a truck and is expected to be minimal.

Comment #4: A citizen questioned the amount of additional traffic expected that would be related to
construction activities. This concern also included whether the process would cause excess noise or odors
as well as when the activities would be performed.

Response: Negligible additional traffic is expected. The construction activities will occur during normal
working hours which is consistent with the activities that are typical at the Burgess Brothers
Construction Company. All activities with be performed on-site which is in a remote area. No adverse odor
or noise impacts are expected to impact any nearby residences.

Comment #5: A citizen was concerned whether the presence of site contamination over the years had caused
lasting damage to plant life and/or animal life.

Response: There have been impacts to both plant and animal life over the years. The presence of stressed
vegetation has been documented and the soils in the marshy area are currently an unacceptable risk to
some forms of wildlife. None of these impacts, however, are expected to be permanent. Once the capping of
the landfill and marshy area and the treatment of lagoon soils is complete, the source of contamination
will be greatly reduced. Further, natural attenuation of groundwater is expected to achieve drinking
water standards at the compliance boundary within seven years. When the remediation activities are
complete, there will be no further unacceptable risks associated with the site.

Comment #6: A citizen questioned whether is was possible that some contamination at the site could have
been missed.

Response: Investigatory activities have included a comprehensive evaluation of all potential pathways of
contamination including groundwater, soil, sediments, surface water, and air. There is a very high level
of confidence that all site related contamination has been identified and thoroughly defined.

IV. CHANGES IN SEIiECTED REMEDY BASED ON PUBLIC CONCERNS

The comments received generally supported EPA's proposed alternative. The were no changes based on
comments received.

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                                               ATTACHMENT A

                               LIST OF FORMAL COMMUNITY RELATIONS ACTIVITIES
                         CONDUCTED TO DATE AT THE BURGESS BROTHERS SUPERFUND SITE

September 16, 1992   Community interviews conducted by the  EPA in Bennington and Woodford,  Vermont.

February 1995       Community Relations Plan issued.

April 1998          Fact Sheet No.  1 issued describing the  findings of the RI/FS, risk assessment and
                    proposed FS alternatives.

June 10, 1998        EPA Proposed Plan released

June 11, 1998        Public notice  published in the Bennington Banner announcing the availability of the
                    Proposed Plan and Administrative Record and the upcoming public meeting.

June 15, 1998        Start  of the public comment period.

June 23, 1998        Public meeting held by the EPA and VT  DEC at the Bennington Free Library discuss the
                     results of the RI, risk assessment, and EPA's proposed alternative.

September 1998      Responsiveness Summary issued as part of the Record of Decision on the EPA's
                    preferred alternative for the Burgess Brothers Site.

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                                               ATTACHMENT B
                                TRANSCRIPT FROM JUNE 23,1998 PUBLIC HEARING
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                                                                             **********
PRESENT:
                                                 EPA PROPOSED PLAN

                                         BURGESS BROTHERS SUPERFUND  SITE

                                         WOODFORD & BENNINGTON, VERMONT

                                        *************************************

                                                 Information Session

                                                           and

                                                Formal Comment Session

                                                Tuesday,        June 23, 1998
                                                           7:00 PM

                                                          Wills Room
                                                   Bennington Free Library
                                                      Bennington, Vermont
                                                                        **********
                     RONALD   JENNINGS
                    REMEDIAL PROJECT MANAGER
                     U.S.  ENVIRONMENTAL PROTECTION AGENCY
                    JFK FEDERAL BUILDING, HBT
                     BOSTON,  MA.  02203

                     MARY JANE S.  0'DONNELL
                    SUPERVISORY ENVIRONMENTAL ENGINEER
                     JFK FEDERAL BUILDING
                    BOSTON MA. 02203

                    GEOFFREY SEIBEL
                     DEMAXIMIS,  INC.
                    SUITE 202
                     ALLENTOWN,  PA.

                     SARAH WHITE
                    COMMUNITY INVOLVEMENT COORDINATOR
                     OFFICE OF THE SUPERFUND COMMUNITY RELATION
                    US ENVIRONMENTAL PROTECTION AGENCY
                     JFK FEDERAL BUILDING (RAA)
                    BOSTON, MA.  02203

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1                       MS.  O'DONNELL:  As you can see,  the formal





2             part of the hearing has started.  It will  be





3            transcribed. If you would like to make some formal





4             comments on the post cleanup plan,  now is your





5             opportunity.





6                       MRS.  MacINTYRE:  What's  the timeframe for





7             putting on the cover and completing the covering up





8             process?





9                      MS.  O'DONNELL: Could you identify yourself





10           just for the record?





11                      MRS.  MacINTYRE:  Barbara Maclntyre. We did





12            that doing the first? In other words,  you're going





13            to put a cover on,  how long will  it take  to put the





14            cover on,  make sure the test wells are in place and





15            be able to walk away and come back casually and





16            come back?





17                     MS.  O'DONNELL: Do you have a sense of that?





18                      MR.  JENNINGS: We are not formally answering





19            guestions  right now but the schedule needs to be





20            put forward. However, we are talking about





21            construction happening fairly soon. You folks over





22            there are  going to be moving forward on design,  we





23            are basically  moving faster than what our schedule





24            reguirement is. Can you give me some idea of what





25            your hope  is?

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1                        MR.  SEIBLE:  Geoff Seible for the record.





2             We're probably planning on an aggregate of anywhere





3             from 18 months to 24 months for design and





4             construction total.  And it's our objective to





5             design and build this remedy as guickly as possible





6             and construction may start as early as this year





7             but the bulk of the  work will likely be next year.





8                        MR.  JENNINGS:  That's fast for superfunds.





9                        MRS.  MacINTYRE:  That is,  that is.





10                       MS.  O'DONNELL:  If you could combine  your





11            comments to comments of the proposed plan that





12            would be great but we would be more than happy  to





13            answer certification type guestions after we close





14            the formal hearing.





15                       Any other comments? Well,  seeing there are





16            none, the formal hearing is now closed but





17            certainly when we will be more than that happy  to





18            answer any guestions you might have for as long as





19            you people want to stay.





20                       (WHEREUPON THE HEARING WAS CONCLUDED,  THIS





21            DATE.)





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1                       CERTIFICATION





2                        I,  ERIN K.  O'HEARN,  a  Shorthand





3             Reporter in and for the State of  Vermont do hereby





4             certify that the foregoing record taken by me at





5             the time and place noted in the heading hereof is a





6             true and accurate transcript of same,  to the best





7             of my ability and belief.





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