Superfund Record of Decision Pine Street Canal Burlington VT


                                    EPA/ROD/R01-98/130
                                    1998
EPA Superfund
     Record of Decision:
     PINE STREET CANAL
     EPA ID: VTD980523062
     OU01
     BURLINGTON, VT
     09/29/1998

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EPA 541-R98-130

DECLARATION FOR THE RECORD OF DECISION

Pine Street Canal Superfund Site
Burlington, Vermont
STATEMENT OF PURPOSE
This Decision Document presents the selected remedial action for the Pine Street Canal Superfund Site
in Burlington, 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 Regional Administrator for EPA New England has been delegated the authority to approve this Record
of Decision. The Regional Administrator has redelegated this authority to the Director of the Office of
Site Remediation and Restoration.

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
133 (k) of CERCLA and is available for public review in Burlington, Vermont, at the Fletcher Free Public
Library and Bailey Howe Library at the University of Vermont, and at the EPA New England Office of Site
Remediation and Restoration Records Center in Boston, Massachusetts. The Administrative Record Index
(Appendix D) 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 Record of Decision, may present an imminent and substantial
endangerment to the public health or welfare, or to the environment.

DESCRIPTION OF THE SEIiECTED REMEDY

This Record of Decision sets forth the selected remedy for the Pine Street Canal Superfund Site.

The major components of the selected remedy include:

• Capping contaminated sediments in Canal and Wetland Subareas 1, 2,3,7, and 8,
• Institutional controls for groundwater below the Site,
• Institutional controls for land-use development,
• Site boundary definition,
• Long-term performance monitoring, and,
• Five-year reviews.

DECLARATION

The selected remedy is protective of human health and the environment, attains federal and state
reguirements that are applicable or relevant and appropriate for this remedial action, and is
cost-effective. This remedy does not satisfy the statutory preference for remedies that utilize
treatment as a principal element to reduce the toxicity, mobility, or volume of hazardous
substances, however, it does reduce the mobility of the hazardous substances through containment. This
remedy utilizes permanent solutions and alternative treatment technologies to the maximum extent
practicable.

As this remedy will result in hazardous substances remaining on site above health-based levels and
guidelines for ecological health, five-year reviews will be conducted after commencement of remedial
action to ensure that the remedy continues to provide adeguate protection of human health and the
environment.

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                                    ENVIRONMENTAL PROTECTION AGENCY
                                                REGION I

                                           RECORD OF DECISION

                                    PINE STREET CANAL SUPERFUND SITE
                                          BURLINGTON, VERMONT

                                             SEPTEMBER 1998
                                    PINE STREET CANAL SUPERFUND SITE

                                            TABLE OF  CONTENTS


I .      SITE NAME, LOCATION AND DESCRIPTION	1

II.    SITE HISTORY AND ENFORCEMENT ACTIVITIES	2
         A.  Land-Use History	2
         B.  Environmental Responses	2
         C.  Enforcement History	4

III.   COMMUNITY PARTICIPATION	4

IV.    SCOPE OF REMEDIAL RESPONSE ACTION	5

V.      SUMMARY OF SITE CHARACTERISTICS	6
         A.  Waste/Source Areas	6
         B.  Surface and Subsurface Soils	7
         C.  Groundwater Contamination and Migration	8
         D.  Surface Water	8
         E.  Sediments	9
         F.  Air	9
         G.  Ecological Resources/Wetlands	9

VI.    SUMMARY OF SITE RISKS	11
         A.  Human Health Risk Assessment	11
         B.  Ecological Risk Assessment	17

VII .   DEVELOPMENT AND SCREENING OF ALTERNATIVES	21
         A.  Statutory Reguirements/Response Objectives	21
         B.  Remedial Action Objective/Goals	22
         C.  Development of Technology and Process Options	23
         D.  Technology and Alternative Screening	24

VIII.  DESCRIPTION OF ALTERNATIVES	27

IX.    SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES	35
         A.  Evaluation Criteria	35
         B.  Summary of the Comparative Analysis of  Alternatives	36

X .      THE SELECTED REMEDY	44
         A.  Capping	44
         B.  Stormwater Inflow Management	46
         C.  Performance Monitoring	46
         D.  Site Boundary Definition	47
         E.  Institutional Controls	47
         F.  Wetlands Restoration	49
         G.  Cost	49

XI.    STATUTORY DETERMINATIONS	49
         A.  The Selected Remedy is Protective of Human Health and
               the Envi ronment	50
         B.  The Selected Remedy Attains ARARs	50
         C.  The Selected Remedial Action is Cost Effective	52
         D.  The Selected Remedy Utilizes Permanent  Solutions and
               Alternative Treatment or Resource Recovery  Technologies
               to the Maximum Extent Practicable	53
         E.  The Selected Remedy Does Not Satisfy the Preference for
               Treatment That Permanently  and Significantly reduces  the
               Toxicity, Mobility or Volume  of  the  of the  Hazardous
               Substances as a Principal Element	54

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XII .   DOCUMENTATION OF SIGNIFICANT CHANGES	54

XIII.  STATE  ROLE	54

ACRONYMS AND  ABBREVIATIONS

REFERENCES

APPENDICES
         A.   TABLES  AND FIGURES
         B.   APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
         C.   STATE OF VERMONT DECLARATION  OF  CONCURRENCE
         D.   ADMINISTRATIVE RECORD INDEX
         E.   RESPONSIVENESS SUMMARY

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PINE STREET CANAL SUPERFUND
RECORD OF DECISION

I. SITE NAME, LOCATION AND DESCRIPTION

The Pine Street Canal Superfund Site (VTD980523062) (the "Site"), is located on Pine Street in
Burlington, Vermont, on the shores of Lake Champlain (Figure 1). The Site consists of an abandoned
barge canal and turning basin, surrounding vegetated wetlands, and upland areas. It is hydraulically
connected to Lake Champlain and is subject to flooding from the lake. The canal and turning basin
constructed circa 1868, runs north-south on the western portion of the Site.

Studies conducted under the direction of the U.S. Environmental Protection Agency (EPA) since 1988 have
examined a 70- to 80-acre area (the "Study Area") which includes the properties between Lakeside Avenue
to the south, Pine Street to the east, Vermont Railway property to the north, and the Vermont Railway
and Lake Champlain to the west. The Site itself is defined as a much smaller 38-acre area (within the
Study Area) where contaminants associated with wastes from the manufactured gas plant have been found.
Figure 2 shows the Site boundaries, as defined in this Record of Decision.

Currently, the majority of the Site is vacant. Surrounding land uses include industrial, commercial,
and residential. It is estimated from 1990 census data that 1,450 people reside within a half-mile
radius of the Site. The City of Burlington recognizes Pine Street as its major industrial corridor, and
plans to encourage further economic development. The City also recognizes that the Site is a unigue
natural setting, and has in the past, considered rezoning the barge canal for recreation, conservation
and open space. It is expected that future land use will be recreation/open space in the wetland areas
along the lakefront, and commercial/industrial in the upland areas along the Pine Street corridor. The
State of Vermont has reclassified the groundwater under the Site as Class IV, designating it suitable
only for agricultural or commercial use, and prohibiting its use for drinking water purposes. Municipal
sources supply potable water for all businesses and residences in the City. Several industrial
facilities near the Site have deep bedrock wells that supply process water.

Wetlands comprise approximately 21 acres of the Site and support a diversity of mammals, birds,
reptiles and amphibians. The wetland community types present on the Site are palustrine emergent
wetland, palustrine open water, palustrine forested wetland, and palustrine scrub-shrub wetland. The
wetlands and canal receive stormwater runoff from the Site and from three storm sewer culverts that
drain a watershed of approximately 150 acres. The canal and turning basin are connected to Lake
Champlain through a partially restricted outlet under the railroad trestle in the northwest corner of
the Site. The rest of the Site consists of grassy covered open areas, scrub-shrub upland and forested
upland.

Red guartzite and dolomite bedrock lies at depths of 60 to 150 feet below the ground surface, and dips
to the west. Directly overlying the bedrock are glacially deposited tills and ice-marginal kame terrace
deposits of silty gravel. These deposits are discontinuous. A thick seguence of laminated silts and
clays lies on top of the silty gravel and/or bedrock. Overlying most of this seguence is a peat
deposit. The exception is along the shore of Lake Champlain, and in the vicinity of two deltaic
deposits where numerous fine to coarse sand units are found. Fill, varying in age and composition, has
been deposited on much of the Site. The hydraulic gradients vary in the different geologic units and
are influenced, especially in the fill, peat, and silty-sand, by precipitation recharge, canal stage,
and lake stage. In general, groundwater flow is toward Lake Champlain.

Several locations on and surrounding the Site are possible candidates for the National Registry of
Historic Places. Five sunken wooden barges and two marine railways are submerged within the canal
itself. Several surrounding properties, including the General Dynamics facility and an old barge
terminal at the end of South Champlain Street, are also important historical resources.

A more complete description of the Site and the surrounding Study Area, can be found in the
Supplemental Remedial Investigation (SRI) Report (Metcalf & Eddy, March 1992), and the Additional
Remedial Investigation (ARI) Report (The Johnson Company, July 1997).

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. Land-Use History

The Site has been used for various industrial/commercial purposes since the mid-1800s, when the
railroad on the western edge of the canal was built. The barge canal and turning basin were first
dredged in 1868 to provide access to Lake Champlain for several lumber companies, a coal company and a
boat builder. By 1879, two slips for barges, one running north from the turning basin, the second
running east towards Pine Street from the middle of the canal, had also been constructed.

Around 1895, Burlington gas works, a manufactured gas plant (MGP), was constructed near Pine Street,
just north of what is now the Burlington Electric Department (Figure 3). The plant used a coal
gasification process to manufacture gas for the community. The Burlington gas works reportedly disposed
of large guantities of coal gasification wastes, such as coal tar, fuel oil, cyanide, contaminated wood

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chips, iron oxide, cinders and metals at its former location along Pine Street and in the wetland areas
behind the plant. These waste materials are the primary source-of-contamination at the Site.

Disposal practices at the MGP, as well as the operations of other industries at the Site, have resulted
in the infilling of wetlands and peaty soils at much of the Site. The gas plant ceased operations in
1966 and was dismantled in 1967. By 1977, both barge slips had been filled in. Naturally occurring
processes, such as deposition, eutrophication, and sediment trapping in large root mats, continue to
fill in the canal and turning basin today.

A more complete description of the Site history can be found in the 1992 SRI and 1997 ARI Reports.

B. Environmental Responses

Many environmental studies have been conducted at the Site since the late 1970s by the State, various
landowners, and EPA. A list of these studies can be found in Table 2.1-1 of the 1997 ARI Report.

In 1977 and 1978, the State of Vermont took exploratory borings for the Southern Connector highway that
was proposed for the Site. The borings revealed extensive sub-surface contamination. In 1981, the State
of Vermont nominated the Pine Street Canal Site as a candidate for the newly-created Superfund program.
The Site was proposed for the CERCLA National Priorities List (NPL) on October 23, 1981, and listed on
September 8, 1983.

In 1985, EPA Undertook an emergency removal action at Maltex Pond (see Figure 2). The Vermont
Department of Environmental Conservation (DEC) provided field oversight. Six to eighteen inches of soil
contaminated with coal tar were removed from the surface, mixed with limestone, solidified, and shipped
off site for disposal at an approved facility. A permeable geotextile membrane was placed over the
excavated area, and topped with six inches of clean topsoil. Contaminated soil was left in place below
that. Today, Maltex Pond supports a diverse wetland community of plants and animals. There is no
evidence that recontamination has occurred.

The Vermont Agency of Transportation investigated the Site, primarily along the proposed Southern
Connector right-of-way, from 1976 to 1988. In 1988, EPA took the lead for site investigations and
broadened their scope. The results of EPA's work is documented in the 1992 SRI Report. EPA also
completed a Baseline Risk Assessment Final Report (Metcalf & Eddy, May 1992) and a Feasibility Study
Report (Metcalf & Eddy, November 1992). Treatability studies were performed in 1992 as part of the
Feasibility Study.

In November of 1992, EPA proposed a cleanup plan for the Site. The plan called for (1) the construction
of a containment/disposal facility (CDF) over the most heavily contaminated portion of the Site
(wetland area west of the former coal gasification plant); (2) dredging contaminated sediments from the
canal and turning basin and placing the sediments in the CDF; (3) collecting mobile coal tar and coal
oil; (4) on site restoration or replication of wetlands; and, (5) institutional controls to protect the
integrity of the CDF and prevent ingestion of groundwater. Public comment on the 1992 Proposed Plan was
overwhelmingly negative. Commenters raised several concerns about the studies, including guestions
about the nature and extent of ecological risk at the Site, the migration of contaminated groundwater,
and air guality. In addition, commenters were concerned about the short-term health effects of
excavation and the construction of a large CDF on the shores of Lake Champlain. After a six-month
comment period, EPA withdrew the proposed cleanup plan due to community opposition.

After EPA's withdrawal of the proposed cleanup plan in 1993, environmental regulators, the potentially
responsible parties (PRPs), and citizens and groups who had been active in commenting on the 1992
Proposed Plan, formed the Pine Street Barge Canal Coordinating Council (PSBCCC). The purpose of the
council was to provide for more meaningful public involvement in the selection of a remedy.
Specifically, the PSBCCC's mission was to design and oversee the implementation of additional studies
to fill in data gaps from prior studies, and to recommend a proposed remedy for the Site to EPA
management, The PSBCCC consists of representatives of EPA, the Vermont DEC, the City of Burlington, US
Fish & Wildlife Service, The Lake Champlain Committee, The Pine Street Arts and Business Council, Ward
5 Planning Association, and the PRPs. EPA retained its statutory responsibility for final remedy
selection. PSBCCC meetings were announced in the Federal Register and to local news media, and were
open to the public. The unofficial minutes of the PSBCCC meetings are available as part of the
Administrative Record for this Record of Decision (Appendix D).

Under the oversight of EPA and the State, and with involvement by the members of the PSBCCC, additional
studies of the Site were performed in 1994-1998. The results of these studies are summarized throughout
this document, and contained in the 1997 ARI Report, Supplemental Baseline Ecological Risk Assessment
(SBERA) (Roy F. Weston, July 1997), and Additional Feasibility Study (AFS) RETEC May 1998). After
reviewing the results of the 1997 ARI, SBERA and AFS, the PSBCCC formally recommended that EPA adopt
the remedial approach contained in this Record of Decision. In May 1998, EPA released the proposed
cleanup plan for remediation of the Pine Street Canal Superfund Site. A public comment period was held
from June 5 to August 7, 1998.

C. Enforcement History

In 1987, 1988 and 1992, EPA notified parties who owned portions of the Site, were former owners or

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operators of the gas plant, or had succeeded to the liability of former operators of the gas plant, of
their potential liability and responsibility for cost of environmental response actions under CERCLA.
EPA entered into negotiations with PRPs for the performance of the Remedial Investigation and
Feasibility Study  (RI/FS) and reimbursement of EPA's response costs in 1988, but no agreement was
reached.

On June 27, 1988, EPA began the RI/FS, financed by the Superfund program. In December, 1988, EPA
filed suit against three PRPs who had owned and/or operated the gas plant from 1930-1968, seeking
reimbursement of costs incurred by EPA in undertaking the removal action at Maltex Pond and certain
other response costs. Several additional parties were brought into the suit by the original defendants.
In 1990, EPA reached a settlement with the defendants and third-party defendants. Under the terms of
the settlement, EPA recovered $945,000 in past CERCLA response costs and reserved the right to seek the
cost of future response actions from the parties. The settlement was approved by the United States
District Court for the District of Vermont on December 26, 1990.

Following the withdrawal of EPA's 1992 Proposed Plan, the PSBCCC identified several data gaps that
needed further study before another remedial alternative could be approved, and developed a statement
of work for such studies. EPA and the State of Vermont issued an Administrative Order on Consent in
1994 (U.S. EPA Docket No. 1-94-1065), and a second Administrative Order on Consent in 1995  (U.S. EPA
Docket No. 1-95-1048), under which certain PRPs agreed to undertake an Additional Remedial
Investigation  (ARI) and Additional Feasibility Study (AFS), and to compensate EPA and the State of
Vermont for the costs of oversight over the ARI and AFS. The settling PRPs retained a contractor and
conducted the ARI/AFS under EPA and DEC oversight and in cooperation with the PSBCCC.

Many of the PRPs have been active in the remedy selection process for this Site. At the time of the
1992 Proposed Plan, technical comments by several of the PRPs were submitted in writing and presented
at the public hearing during the public comment period. The PRPs had three representatives on the
PSBCCC, representing both generator and landowner parties. They participated fully in the development
of additional studies and the recommendation of a remedy for the site, reflected in the May 1998
Proposed Plan. The PRPs endorsement of the proposed cleanup plan was received during the public comment
period and is included in the Responsiveness Summary (Appendix E).


III.   COMMUNITY PARTICIPATION

Community concern and involvement with the Site has varied over time. EPA's Community Relations Plan,
released in December 1990, outlined a program to keep citizens informed about and involved in
activities during the remedial process. Between the time of the Site's listing on the NPL in 1983, and
the 1992 Proposed Plan, EPA used meetings, fact sheets and press releases to keep the community and
other interested parties apprized of activities at the Site. The public's interest in the Site peaked
in 1992 when EPA proposed a cleanup plan. In response to reguests from the community, EPA extended the
formal comment period on the proposed cleanup plan from 30 days to six months. EPA held numerous public
informational meetings and a public hearing during those six months to discuss and receive comments on
the proposed remedy. EPA withdrew the Proposed Plan in June 1993 in response to community opposition.

In 1993, the Pine Street Barge Canal Coordinating Council  (PSBCCC)  was formed to direct further studies
and recommend a remedy for the Site. The PSBCCC consists of representatives of EPA, the DEC, the City
of Burlington, US Fish & Wildlife Service, The Lake Champlain Committee,  The Pine Street Arts and
Business Council, Ward 5 Planning Association, and the PRPs. The Lake Champlain Committee received a
Technical Assistance Grant under Section 117 (e) of CERCLA, and used the funds to hire technical experts
to advise the community representatives on the Council.

The PSBCCC retained a neutral facilitator and agreed on Organizational Protocols to guide the decision
making process. Decisions were made with consensus from each party on the Coordinating Council. The
Council formed technical work groups to direct each phase of the ARI/AFS which was being conducted by
the PRPs' contractor. The Council and the work groups had an opportunity to comment on all interim and
draft technical documents. The Coordinating Council formed a Public Participation Committee, issued
printed progress updates, and held community informational meetings. All PSBCCC meetings were open to
the public, and members of the public were able to make presentations to the Council.

On May 27, 1998, the PSBCCC formally recommended to the EPA New England Regional Administrator that the
Agency adopt the remedy in this Record of Decision. On May 29th, EPA published a notice and brief
analysis of the 1998 Proposed Plan in the Burlington Free Press, and made the Administrative Record
available for public review at EPA' s offices in Boston, and the Fletcher Free Public Library and Bailey
Howe Library at the University of Vermont, both in Burlington.

On June 4, 1998, EPA and the PBCCC held an informational meeting to discuss and answer guestions from
the public about the results of the Additional Remedial Investigation and Supplemental Baseline
Ecological Risk Assessment, and the cleanup alternatives presented in the Additional Feasibility Study.
Also at this meeting, EPA presented and answered guestions about its proposal for remediation at the
Pine Street Canal Site. A 30-day public comment period opened the next day, June 5th. The formal public
hearing to accept oral comments on the plan was held in Contois Auditorium in Burlington, Vermont, on
June 24, 1998. The public comment period was extended to August 7,  1998.  Several comments from the
public were received and were considered in the development of the final Record of Decision. Appendix E
contains a summary of the comments received during the public comment period and EPA's responses,
indicating how they have been considered in the final Record of Decision.

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IV. SCOPE OF REMEDIAL RESPONSE ACTION

The selected remedy was developed by combining components of different source control and management of
migration alternatives to obtain a comprehensive approach to address the environmental and public
health risks posed by the Site. In summary, the remedy provides for the following actions.

• Capping Contaminated Sediments in Subareas 1, 2, 3, 7, and 8 (Figure 7). A cap of sand and
silt will be placed over contaminated sediments to reduce exposure of benthic organisms,
amphibians and bottom-feeding fish to elevated concentrations of polycyclic aromatic
hydrocarbons, and to reduce mobility of contamination to overlying surface waters within
the canal and lake.

• Site Boundary Definition. The boundaries of the Site are defined by the extent of wastes
related to the gas plant. The Site is smaller than the original "Study Area", and allows
for redevelopment of parcels surrounding the Site.

• Institutional Controls for Groundwater below the Site. Prevents the use of on-site
groundwater as drinking water.

• Institutional Controls for Land-Use Development. Prevents land uses that could result in
unacceptable risks to human health, such as residential use, use as a children's day
care center, and most excavations below five feet.

• Long-term Performance Monitoring. Monitoring of groundwater, stormwater, surface water,
sediment and cap performance per a regular schedule to ensure that the selected remedy
remains protective over time.

• Five-year Reviews. Ensures that the remedy continues to provide adeguate protection of
human health and the environment in the future.

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

V. SUMMARY OF SITE CHARACTERISTICS

The significant findings of the environmental investigations conducted at the 70- to 80-acre Study Area
are summarized below. This summary integrates findings from both the 1992 Supplemental Remedial
Investigation (SRI), and the 1997 Additional Remedial Investigation (ARI). The 1998 Additional
Feasibility Study (AFS) Report also contains an overview of the remedial investigation. This Record of
Decision defines the Site as a smaller 38-acre area, within the Study Area, where contaminants
associated with wastes from the manufactured gas plant have been found (Figure 2).

A. Waste/Source Areas

The primary contamination at the Pine Street Canal Site is waste material from the Burlington gas
works, which operated from about 1895 to 1966. Those wastes are residuals or by-products from the coal
gasification process and include aromatic hydrocarbons such as benzene, toluene, ethylbenzene, and
xylene (known as "BTEX"); polycyclic aromatic hydrocarbons (PAHs) in the form of light and heavy tars;
and, cyanides and sulfur compounds. These wastes also contain inorganics such as aluminum, antimony,
cobalt, nickel, iron, titanium, manganese, arsenic, lead, chromium, copper, vanadium, zinc, cadmium,
molybdenum, and selenium. Wood chips, probably contaminated with tar, iron filings, and complex forms
of cyanides, are reported to have been disposed of at the Site. Remedial investigations reveal the
presence of many of these chemicals across the Site, with PAHs being the most widespread and in the
highest concentrations (Figures 4, 5, and 6). Concentration gradients tend to decrease towards the
edges of the plumes.

Other historical activities on or abutting the Site may have also contributed PAHs, oils, solvents,
volatile organic compounds (VOCs), and metals to the Site. These include boat building, asphalt plants,
auto junk yard, oil storage, metal fabrication and finishing operations, railroad operations and
helicopter and Gatling gun manufacturing, as well as fill. Current urban activities provide a
continuing source of PAHs, such as auto emissions.

The current primary source of contaminants is an extensive area of non-agueous phase liguid ("free
phase" waste coal tar and coal oil), or NAPL, in the subsurface beneath the canal and the wetlands area
west of the former gas plant (Figure 4). The presence of NAPL has been confirmed to a depth of 24 feet.
The volume of NAPL-contaminated soils is estimated to be more than 200,000 cubic yards. The NAPL is
found most extensively in the peat and fill layers.

B. Surface and Subsurface Soils

1. Surface Soils

The 1992 SRI found that surface soils (top 6 inches) were contaminated with PAHs in much of the
Study Area. Surface soils with PAHs in the highest concentrations were located west of the
former coal gasification plant, particularly in the wetlands. Other organic chemicals were
detected in surface soils infreguently and in low concentrations. Metals are prevalent at
varying concentrations - most were slightly elevated when compared to background levels.
Chromium, cyanide, lead, barium, iron, and selenium concentrations were elevated in the wetlands

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west of the former coal gasification plant and the wetlands south of the Burlington Electric
Department.

During the 1997 ARI, shallow surface soil (top 4 inches) in areas of likely human access were
resampled. The highest and mean PAH values detected in immunoassay screening in these areas were
10 ppm and 1.3 ppm, respectively. The highest PAH laboratory values were in the turning basin
access area (21.7 ppm) and along Pine Street (24 ppm). The maximum values for metals by
laboratory analysis were 80 ppm for lead and 86 ppm for zinc. These concentrations are lower
than the Reasonable Maximum Exposure concentrations used for the 1992 Baseline Risk Assessment
for human health (Metcalf & Eddy, May 1992).

Deeper surface soil samples (top 12 inches) were collected in the 1997 ARI in an area of stained
soil and stressed vegetation north of the Burlington Electric Department. Concentrations of PAHs
and metals in these samples were lower than the rest of the Site. Four pesticides and amenable
cyanide were found in concentrations near the detection limits.

2. Subsurface Soils

Subsurface soil contamination (deeper than 12 inches) was delineated in the 1992 SRI. No
additional subsurface soil sampling was conducted in the 1997 ARI. Highly elevated coal tar,
PAH, BTEX, and cyanide concentrations were found in subsurface soils within the wetlands west of
the former coal gasification plant, where NAPL is present. Based on the stratigraphy at the
Site, it is believed that the majority of the contamination is within the peat and fill layers
to a depth of 24 feet. Dissolved BTEX compounds are also present in subsurface soils outside the
free-phase NAPL area. Metal concentrations in subsurface soil vary widely across the Study Area
and are highest in four areas: the wetlands west of the former coal gasification plant; the
filled south barge slip; subsurface sediments of the canal; and, near the industrial landfill at
the northern property line of General Dynamics (formerly Lockheed-Martin/GE).

C. Groundwater Contamination and Migration

1. Groundwater Contamination

Groundwater contamination was characterized primarily in the 1992 SRI. The 1997 ARI studies
concentrated on the groundwater below the portion of the Study Area that is west of the canal,
and the potential for contamination to migrate to Lake Champlain. The two studies revealed that
the major contaminants in the overburden hydrogeologic units are PAHs, BTEX, and cyanide. PAHs
are present at concentrations up to 78 ppm, BTEX to 25 ppm, and cyanide to 755 ppb. The areal
extent of PAHs in groundwater is similar to that found in subsurface soils (Figure 5). The
highest concentrations of PAHs are present in groundwater west of the former coal gasification
plant in the fill/peat and upper silt/clay zones. PAHs are also present in groundwater south of
the Burlington Electric Department and the former tank farm area north of the turning basin. The
distribution of BTEX compounds in groundwater is similar to that of PAHs but extends farther in
all directions. Benzene has migrated through a sand unit to the west of the canal but may be
localized in the vicinity of monitoring well MW-17 (see Figure 6). The extent of cyanide in
groundwater is limited to areas with PAH and BTEX contamination. To date, no groundwater
contamination has been detected in bedrock monitoring or water supply wells.

2 . Groundwater Migration

Groundwater flow and potential dissolved contaminant transport directions at the Study Area are
predominantly toward Lake Champlain. Dissolved contaminants in groundwater are found primarily
in areas where free-phase coal tar (NAPL) is present in the subsurface. Groundwater
contamination has been detected between the canal and the lake at monitoring well MW-17, and at
boring location PZ-3 (Figure 4) where NAPL was encountered. In the area west of the canal, only
benzene was found at levels greater than the Maximum Contaminant Level (MCL), the levels set by
EPA for protection of drinking water. Models using conservative assumptions suggest that benzene
migration to the lake at levels above the MCL is unlikely.

D. Surface Water

Surface water in both the canal and Lake Champlain was characterized in the 1992 SRI. Relatively low
levels, at or near the detection limits, of volatile and semi-volatile organic compounds were detected
in the canal. Metal concentrations were generally less than those found in groundwater. Samples of lake
water were collected just off shore from the Study Area, and up to 450 feet from the Study Area.
Adjacent lake samples did not contain elevated levels of site-related contaminants (PAHs, benzene,
toluene, and xylene). Nine metals were detected in Lake Champlain surface water, but at concentrations
that increased with increasing distance from the Study Area suggestive of other sources. No PAHs were
detected in stormwater inflow to the canal, but thirteen metals were detected.

Water guality data (pH, temperature, specific conductance, and dissolved oxygen) for the canal included
measurements taken during June and August 1990 and a continuous monitoring program conducted in 1994
and 1995. Dissolved oxygen levels range from 0.9 to 11.7 mg/L. The higher oxygen levels are at the
surface of the canal, the lower levels occur near the bottom. The variability of dissolved oxygen may
be attributed to high sediment oxygen demand associated with eutrophic conditions in the canal. A
detailed discussion of water guality information is in the 1997 ARI.

E. Sediments

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A thorough characterization of shallow (top 4 inches) sediments in the canal and wetlands during the
1997 ARI revealed extensive PAH contamination (mean concentration of 505.5 ppm), with the highest
levels (up to 29,360 ppm) in the northern part of the canal and turning basin. Concentrations of metals
and cyanide were also elevated in shallow canal and bordering wetland sediments. Concentrations of
cadmium, chromium, copper, lead, mercury, nickel, silver, and zinc exceeded their published ecological
effects guidelines (Long et al., 1995; Jaagumagi et al., 1995).

F. Air

Air sampling was conducted during the 1992 SRI and 1997 ARI. The results indicate that during
undisturbed conditions, that is when the soil and sediments at the Site are not stirred up, there is no
impact on the local ambient air.

G. Ecological Resources/Wetlands

1. Ecological Setting

Approximately 21 acres of the Site are represented by four wetland community types. These are
palustrine emergent wetland (7.5 acres), palustrine open water (6.2 acres), palustrine forested
wetland (3.7 acres) and palustrine scrub-shrub wetland (3.7 acres). (Palustrine refers to a
specific wetland system that is nontidal and dominated by trees, shrubs and emergent
vegetation.) The remaining 17 acres of the Site are upland scrub-shrub and forested communities,
and open grassy areas typical of disturbed urban areas. Pine Street Canal Site wetlands rated
high in a wetlands functions and values assessment based on the presence of physical (abiotic)
elements and vegetation (plant assemblages). The wetlands rated high because structural elements
exist for promotion of wildlife and aguatic habitat, nutrient removal/transformation,
sediment/toxicant retention, and production export. These wetlands have the potential to provide
the following ecological and socio-economic services: temporary storage of stormwater runoff,
surficial-flow stormwater guality enhancement, fisheries habitat, wildlife and migratory bird
habitat, and open space and aesthetics. Based on a computer simulation model (WEThings),
wildlife surveys and best professional judgement, the wetlands have the potential to support a
variety of mammals, reptiles, fish, and amphibians, based on the interspersion and juxtaposition
of vegetation and abiotic structural elements.

The wetlands are heavily influenced by the canal's connection to Burlington Bay and, to a lesser
extent, by the inflow from several culverts connected to the Burlington sewer/stormwater system.
Much of the wetland is flooded in spring when the level of Lake Champlain is normally at its
highest annual elevation. Water levels in the canal typically recede through the summer, fall
and winter as lake levels recede. During these seasons, inflow from surface runoff become a more
important factor, During the period of study, beaver dams in the southern portion of the canal
and near the outlet of the turning basin to the lake influenced water levels in the canal and
wetlands.

The Pine Street Canal Site wetlands and uplands have the potential to form a distinct ecological
community, unigue in that it is in an urban setting less than a half mile from the center of
Burlington. However, the Study Area has been dramatically altered by human activity and is
currently impaired. The cessation of industrial operations within the last two decades has
allowed some portions of the Study Area to revert back to a more natural state characterized by
early successional vegetation (succession may be delayed due to impairment) and wildlife not
common to an urban setting. The Study Area attracts a diversity of seasonal migratory wildlife
and resident wildlife, which may be exposed to contaminated sediments directly or indirectly
through the food chain. No rare, threatened, or endangered species were identified in the Pine
Street study area.

2 . Ecological Studies

The Pine Street Canal Site ecosystem has been studied extensively. During the 1992 SRI, the
aguatic environment at Pine Street was surveyed and compared with that of Malletts Creek, to
determine if any differences are the result of contamination. Malletts Creek, which drains to
Lake Champlain approximately eight miles north of the Site, was selected as a reference site
because it has physical and biological characteristics similar to the Pine Street Canal
ecosystem but has not been influenced by historic disposal activities. Wildlife surveys, wetland
delineation and vegetation mapping, and a wetland functional assessment were conducted. Studies
of samples taken from benthic invertebrate, fish and zooplankton showed that the invertebrates
inhabiting the canal sediments at the Site appeared to be greatly affected by the environmental
conditions in the canal, as demonstrated by some abiotic areas and the dominance of
opportunistic species (tubificid worms). The aguatic communities appeared to be less affected by
contamination. However, EPA interim sediment guality criteria were exceeded for acenapthene,
fluoranthene and phenanthrene in the canal and turning basin sediments, and it was noted that
the fish communities were more likely to be exposed to contaminated sediments, during feeding,
spawning, and when using the canal as a nursery.

The 1997 ARI focused on the Site's ecological resources and included a wetland habitat
assessment, chemical screening of surficial sediments for PAHs and metals, an avian dietary
study through the collection of site-specific aguatic insect tissue, a fish biomarker study,
fish tissue sampling, and sediment toxicity testing. Shallow sediment and soil samples from the
entire Study Area were screened for PAHs and metals. Using a threshold value of 40 ppm total
PAH, an area of focus was delineated. The focus area was divided into eight subareas on the

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basis of topography, bathymetry, vegetation type, and contaminant concentrations (Figure 3).
Sediment samples were collected in each of these eight subareas for chemical characterization
and toxicity testing. The highest PAH concentrations (over 1000 ppm) were found in the northern
portion of the canal and in the turning basin. The remainder of the canal had lower, but still
elevated, PAH concentrations. High metals concentrations (primarily aluminum, barium, cadmium,
chromium, copper, and zinc) in relation to site-wide averages were found in the south end of the
wetland west of the canal, in the northern portion of the canal, in the turning basin, and in
the wetlands south of North Road.

The results of the sediment toxicity testing program indicated at least one or more toxicity
tests in each area within the canal and turning basin in which benthic invertebrate and frog
embryos exhibited statistically significant decrease in growth and survival rates compared to
the on-site reference location in the wetlands west of the canal. The areas showing the most
consistent statistically significant toxic responses in the tests were the turning basin and
canal and the area between Burlington Electric Department and Lockheed-Martin, and the wetlands
south of North Road. A fish biomarker study was performed using brown bullhead to evaluate
exposure of bottom feeding fish to PAH contaminants. The level of biochemical biomarkers
(Cytochrome P4501A) indicates the fish from the Site have greater exposure to PAHs than fish
from the reference site. No statistically significant differences in cellular or organ level
biomarkers were observed, possibly suggesting that, although fish were exposed to PAHs at the
Site, the levels of exposure could not be correlated to adverse physical effects. However,
because fish caught from both the Site and reference site were relatively young, they are not
necessarily expected to have high freguencies of these physical abnormalities. Avian receptor
modeling, incorporating the data from the avian dietary study, and using conservative
assumptions, shows that exposure of birds to PAHs and metals through the ingestion of fish and
insects is not expected to be significantly greater at the Pine Street Canal Site than at the
reference site.

VI. SUMMARY OF SITE RISKS

In 1992, EPA performed a risk assessment to estimate the probability and magnitude of potential adverse
human health and ecological effects from exposure to contaminants found at the Site (Baseline Risk
Assessment Final Report, Metcalf & Eddy, May 1992). One of the tasks of the Coordinating Council was to
reexamine certain aspects of the human health risk assessment. Their conclusions are documented in a
series of position papers which are summarized below in Section A.3. Ecological risk was revisited in
the Supplemental Ecological Baseline Risk Assessment (Weston, 1997) with Coordinating Council
oversight, using additional data collected during the 1997 ARI.

A. Human Health Risk Assessment

Carcinogenic and noncarcinogenic risk estimates were developed in the 1992 Baseline Risk Assessment
(Metcalf & Eddy, May 1992) and evaluated against EPA's criteria and target risk range to identify the
need for remedial actions at the Site. The following section presents the findings of the human health
risk assessment first. These are followed by a summary of the risk assessment process, and subseguent
reevaluation by the Pine Street Barge Canal Coordinating Council. For a more complete discussion, see
Section 2 of the Baseline Risk Assessment Final Report.

1. Findings

The most significant human health risk at the Site is associated with potential residential
ingestion of groundwater. Estimated carcinogenic risk in groundwater exceeded EPA's target risk
range of 10 -4 to 10 -6 by orders of magnitude. Non-carcinogenic risks estimated for ingestion
exceed it hazard index of 1. However, the State of Vermont has reclassified the groundwater
under the Site as Class IV, designating it suitable for agricultural or commercial use only,
prohibiting its use as drinking water (Appendix B of 1998 AFS). Furthermore, the Pine Street
Canal Site is in an area that has been used for industrial purposes for over 130 years and is
currently zoned for industrial use. It is located in a 100-year floodplain and contains
extensive wetlands. These factors make residential development and use of groundwater at the
Site for drinking unlikely.

Carcinoclenic and non-carcinogenic risk estimates for all of the other exposure pathways
evaluated were below, within, or close to EPA's target risk range. Therefore, there are no
unacceptable risks from Site contaminants to swimmers in Lake Champlain, current Site visitors,
outdoor workers exposed to soils above a depth of 5 feet, or future visitors (adults and
children) to an area which may be zoned as recreation, conservation, and open space.

2. 1992 Human Health Risk Assessment

The human health risk assessment followed a four step process: a) contaminant identification,
which identified those hazardous substances that, given the specifics of the Site, were of
significant concern; b) toxicity assessment, which considered the types and magnitude of adverse
health effects associated with exposure to hazardous substances; c) exposure assessment, which
identified actual or potential exposure pathways, characterized the potentially exposed
populations, and determined the extent of possible exposure; and, d) risk characterization,
which integrated the three earlier steps to summarize the potential and actual risks
carcinogenic and non-carcinogenic risks posed by hazardous substances at the Site. The results
are summarized below.

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a. Contaminant Identification

Several Contaminants of Concern (COCs) were selected to represent potential Site-related
hazards based on toxicity, concentration, frequency of detection, mobility, and
persistence in the environment. The chemicals preselected as COCS included coal
gasification process-related chemicals PAHs and cyanide, volatile organics, non-PAH
semi-volatile organics, and metals. There were a total of 45 COCS for groundwater, 27 for
soil, 32 for sediment, and 24 for surface water, for a total of 56 COCs found in one or
more of the four environmental media. The complete list of human health COCs for the Pine
Street Canal Site can be found in Table 1 of this Record of Decision

b. Toxicity Assessment

Each COG was evaluated in terms of the scientific evidence of toxicity and information
relating to chemical exposures (dose), and anticipated health effects (response). This
information was used to quantitatively evaluate the exposure assessment models (discussed
below). Detailed toxicity assessment data for each COG can be found in Appendix C of the
1992 Baseline Risk Assessment Final Report.

c. Exposure Assessment

Potential human health effects were estimated quantitatively or qualitatively through the
development of several hypothetical exposure pathways. These pathways were developed to
reflect the potential for exposure to COCs based on the present uses, potential future
uses, and location of the Site. Currently, the Site is a mixture of industrial/commercial
and undeveloped areas which include wetlands, open water, and upland forest and fields.
Future land-use assumptions are: 1) the Site will not be used as a residential area; 2) a
highway may be built through a portion of the Site; and 3) part of the Site along the
waterfront may be developed as a recreation/conservation/open space area.

The following is a brief summary of the exposure pathways evaluated and the assumptions
used to model exposure. For each pathway evaluated, average and reasonable maximum
exposure estimates were generated using average and maximum concentrations detected in
that particular medium.

i. Present and future incidental ingestion of water, and dermal adsorption of
water and sediment by swimmers in Lake Champlain close to the canal.

An adult was assumed to swim in Lake Champlain regularly (36 days/year) for 2.5
hours/day over a 30-year residency period. It assumes an incidental ingestion of 50
ml of water per hour of swimming, a chemical-specific dermal permeation constant
for water, and 500 mg of lake sediment adhering to the swimmer's skin.

ii. Present and future incidental ingestion of water, and dermal absorption of
water and sediment by persons falling into the canal.

An adult was assumed to be exposed to canal water and sediment at a frequency of
two one-hour periods per year for 30 years, using the same exposure assumptions as
a lake swimmer.

iii. Present incidental ingestion and dermal absorption of surface soils and
sediments by Site visitors.

The frequency of Site visits was assumed to be twice per month for both adults and
children, using the standard ingestion and dermal absorption assumptions that are
presented in "i" above.

iv. Present and future incidental ingestion and derinal absorption of soils not
deeper than five feet by outdoor maintenance workers in the southern and
northern parts of the Site.

It was assumed that adult exposure would continue over a full period of employment,
250 days per year for 25 years, using the standard ingestion and dermal absorption
assumptions that are presented in "i" above. (Given the climate in northern
Vermont, this is a conservative exposure assumption.)

v. Future incidental ingestion and dermal absorption of soils and sediments by
frequent visitors under a recreation/conservation/open space scenario.

It was assumed that adults and children would be exposed five days/week from May
through October (130 days/year), to an area of the site that is expected to be
developed as a recreation/open space area in the future. Standard ingestion and
dermal absorption assumptions as in item "i" above were used. (Given the climate in
northern Vermont, this is a conservative exposure assumption.)

vi. Future ingestion of groundwater as a source of potable domestic water.

This scenario was evaluated during the 1992 Baseline Risk Assessment because the

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groundwater underlying the site was classified, at that time, as a potential
drinking water source. Since then, the Vermont Agency of Natural Resources has
reclassified the groundwater for nonpotable uses only. Given that, and the fact
that there is an ample alternative water supply (Lake Champlain) provided by the
City of Burlington, it was determined groundwater at the Site is unlikely to be
used as a drinking water source in the future.

d. Risk Characterization

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

The hazard index was also calculated for each pathway (i-vi) as EPA's measure of the
potential for non-carcinogenic health effects. First, a hazard guotient is calculated by
dividing the exposure level by the reference dose (RfD) or other suitable benchmark for
noncarcinogenic health effects for an individual compound. RfDs reflect a daily exposure
level that is unlikely to result in the increased risk of an adverse health effect. EPA
has developed RfDs to protect sensitive individuals over the course of a lifetime. RfDs
are derived from epiclemioloalcal or animal studies and incorporate uncertainty factors to
help ensure that adverse health effects will not occur. The hazard guotient 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 sum
of hazard guotients for compounds that have the same or similar toxic endpoints (e.g., the
hazard, guotient for a compound known to produce liver damage should not be added to a
second whose toxic endpoint is kidney damage) is the hazard index.

As stated above in Section A.I., the human health risks posed by the Site were generally
in EPA's target risk range, and do not pose an unacceptable risk. The risks associated
with ingestion of groundwater would be unacceptable; however, it is unlikely that the Site
will be used as a drinking water source.

3. Refinement of Human Health Risk Assessment

In 1993, the Pine Street Barge Canal Coordinating Council identified several human health
exposure pathways as reguiring additional consideration beyond the 1992 Baseline Risk
Assessment. Position papers on these issues were developed by the technical experts advising the
Coordinating Council, and were subseguently adopted by the council. The conclusions drawn in the
position papers helped council members as they directed studies to fill data gaps during the
1997 ARI. The position papers can be found in Appendix 7 of the 1997 ARI. The following
summarizes the results of the additional exposure pathways.

a. Exposure to shallow soil

Additional surficial soil samples were collected from accessible areas of the Site during
the 1997 ARI. The contaminant concentrations in these additional surficial soil samples
were below those used for the 1992 Baseline Risk Assessment, thus confirming the previous
conclusion that there is no unacceptable human health risk to site visitors from exposure
to Site soils.

b. Air

Additional air samples collected during the 1997 ARI confirmed that the Site, in an
undisturbed state (i.e., neither soil nor sediments recently dug up), does not adversely
affect the local ambient air.

c. Groundwater

A risk assessment screening for the use of Site groundwater for agricultural and
commercial purposes (consistent with the current Class IV designation) found that there is
no unacceptable risk associated with agricultural, commercial or industrial use. Possible
exposure pathways associated with commercial or agricultural use include dermal contact
and inhalation of groundwater, but not ingestion.

d. Fish consumption/metals

Based on an evaluation of metals, a risk screening concluded that a person would have to
consume multiple whole fish meals per week, 52 weeks per year, to experience unacceptable
risk from arsenic, cadmium, and silver. It is not likely that consumption of whole fish

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(including internal organs) from the canal occurs at this level. Mercury levels posed an
unacceptable risk at a consumption rate of one whole fish meal per month. However,
mercury contamination is a regional problem, which is not limited to the Site.

e. Fish consumption/PAHs and metabolites

A search of research literature shows that it is not likely that there is an unacceptable
risk from the consumption of fillets from fish exposed to PAHs or their metabolites.

f. Subsurface soil

Given the high water table and structurally weak soils, the Coordinating Council believed
that it is unlikely that development of the site would result in excavations below five
feet, in which case there would be no exposure to these deeper soils. However, as
discussed below in the Description of the Remedy, because of the uncertainty of predicting
future building technigues, the selected remedy includes a reguirement that legal controls
be established to limit worker exposure to subsurface soils to freguencies that will
assure protection of human health.

g. Exposure to Site contaminants in Lake Champlain water

The 1997 ARI studies regarding fate and transport concluded that contaminants are not
reaching Lake Champlain through groundwater migration or through sediment transport at
concentrations exceeding their Maximum Contaminant Levels (levels set to protect drinking
water). This confirms the previous conclusion that there is no unacceptable Site- related
human health risk to persons swimming in Lake Champlain or using it as a drinking water
source.

h. Synergy and antagonism of PAHs

The guestion of synergistic and antagonistic effects was not answered directly by the risk
assessment methodology since this is an area that continues to be the subject of much
research. However, the Coordinating Council concluded that EPA' s original Human Health
Risk Assessment was based on assumptions that were sufficiently conservative to
accommodate the possibility of some synergistic effects between chemicals.

i. Children's day care scenario

It is possible, under current zoning ordinances, that a day care center for children could
be developed on site. A risk screening analysis indicated that there would be some concern
for a child's exposure to areas of the Site with elevated lead levels in the soil. In
addition, although carcinogenic PAHs are not expected to result in an elevated risk of
internal cancers, there is also a concern for dermally toxic effects to children from
exposures to carcinogenic PAHs in Site soils.

B. Ecological Risk Assessment

Two ecological risk assessments were conducted at Pine Street Canal Superfund Site. The first as part
of the 1992 Baseline Risk Assessment. A supplemental baseline ecological risk assessment (SBERA,
Weston, July 1997) was conducted under a workplan developed by the Pine Street Barge Canal Coordinating
Council. The findings of the risk assessments are presented first in the section below. This is
followed by summaries of the two risk assessment processes.

1. Findings

The ecolocrical 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
Record of Decision, mail present an imminent and substantial endangerment to the environment.
Specifically, contaminants in sediments in Subareas 1, 2, 3, 7, and 8, appear to be responsible
for statistically significant adverse effects in benthic organisms and amphibians exposed to
these sediments. While there are findings of ecological significance associated with individual
measurement endpoints, in Subareas 4, 5, and 6, these lines of evidence are not as compelling
and do not appear to constitute a baseline ecological risk.

The SBERA identified statistically significant (P< 0.05) adverse effects in aguatic
invertebrates or amphibians exposed in the laboratory to sediments collected from subareas 1, 2,
3, 7 and 8, relative to reference or control sediment. Significant reductions in 10 day growth
and survival were observed in freshwater, larval midge (Chironomus tentans) or amphipod
(Hyalella azteca) tests using samples from these subareas. Significant reductions in 30 day
(full life-cycle) survival and emergence of the midge were also observed. The magnitude and/or
freguency of adverse effects in the bacterial bioassay, Microtox R, was greatest in samples from
Subareas 1, 2, 3, 7 and 8. Mean embryo survival in amphibian (frog) bioassays were significantly
reduced in exposures to sediment ftom the wetland south of North Road (Subareas 2 and _33),
relative to reference or control sediment.

Conclusions from the ecological risk assessment include the following:

• PAHs and metals exceeded sediment guidelines published by NOAA (Long et al., 1995) and

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     Ontario Ministry of Environment and Energy (OMEE) (Persaud et al.,  1993)  indicating that
     the level of sediment contamination would be responsible for a pronounced disturbance to
     sediment-dwelling organisms and the contaminant concentration will be detrimental to the
     majority of benthic species.

•    Data from the 1994 sampling event identified that draft EPA sediment guality criteria were
     exceeded by acenapthene, fluoranthene and phenanthrene in the turning basin (Subarea 8)  and
     1995 data exceeded criteria for acenapthene and phenanthrene in the canal (Subarea 1).

•    Biochemical biomarker levels and PAH metabolite levels detected in fish bile samples for
     brown bullheads were statistically significantly higher than corresponding levels for fish
     collected in the reference area. Therefore, bottom feeding fish are more likely exposed to
     sediment contaminants that could be responsible for adverse effects to that fish community.

•    There was 100% mortality among frog embryos exposed to sediments from the southern section
     of the Canal. In addition, embryo survival was significantly reduced when exposed to
     sediments from the wetland south of North Road.

The response action selected in this Record of Decision addresses the risks at the Site in
Subareas 1, 2, 3, 7 and 8, by covering the contaminated sediments with a cap of sand and silt.
This creates a barrier between the contaminated sediments,  which were found to cause adverse
effects, and wildlife, thereby preventing or limiting direct exposure and reducing the
associated risk.

2.     1992 Ecological Risk Assessment

Risks to mammals, birds, fish and amphibians that live in terrestrial,  emergent wetland, wooded
wetland, and aguatic habitats at the Site were evaluated for exposure to PAHs, benzene, toluene
and xylene in soils and sediment. Target species,  or species groups such as the benthic
organisms, were identified and evaluated against measures of exposure and effects such as,
comparisons to chemical concentrations in sediments to criteria, and guidance values and
sediments toxicity testing using benthic invertebrates and frog embryos. Specific bird species
were evaluated by calculating food-chain models with site-specific aguatic insect tissue
contaminant concentrations. These predicted body burdens for target avian species were compared
to literature values to determine whether the burded could be responsible for an adverse effect
to reproduction, growth and survival. All potential exposure pathways were evaluated including
ingestion of contaminated media and biota, inhalation, and dermal exposures from contaminants
in, or volatilizing from, surface soils and sediments.

The results of the guantitative assessment revealed that contaminated canal sediments have
demonstrable adverse effects to benthic organisms. Site soils, particularly in emergent wetland
areas, also have the potential for causing adverse effects to mammals,  like the muskrat, from
dermal exposure. Ecological effect levels (defined as the concentration of a contaminant in a
specific medium below which no adverse effects are likely to occur) were developed based on 1)
established numerical criteria (i.e., EPA's Draft Interim Sediment Quality Criteria, NOAA's
ER-Ls and ER-Ms and OMEE's LELs and SELs) for aguatic areas, and 2) exposure pathway modeling
using general- and site-specific data for wetland and upland habitats.  Mammals (beavers,
muskrats, and mink) were selected as representative organisms for the wetland and upland areas
since their activities would bring them into direct contact with contaminated wetlands or
uplands areas.

Ecological effect levels, converted to eguivalent total PAH levels, were then compared to
observed Site concentrations to determine the magnitude of baseline risk. Ecological effect
levels for total PAHs in emergent wetland surface soils were 13.7 mg/kg  (based upon a dermal
exposure of muskrats to benzo(a)pyrene),  in wooded wetland surface soils within 10 feet from the
canal bank were 24.8 mg/kg  (based upon a dermal exposure of beavers to benzo(a)pyrene), in
wooded wetland surface soils more than 10 feet from the canal bank were 878.4 mg/kg (based upon
ingestion exposure of beavers to benzo(a)pyrene),  and in upland surface soils were 160.6 mg/kg
(based upon ingestion exposure of Peromyscus mice to benzo(a)pyrene). For volatile organics,  the
effect level was 0.286 mg/kg (based upon an inhalation exposure to benzene) for all wetland and
upland habitats. Ecological effect levels for total PAHs in canal surface sediments were 42.4
mg/kg (based on the interim sediment guality criterion for phenanthrene and a five percent total
organic carbon content).

In emergent wetland areas and wooded wetland areas within 10 feet of the canal bank, effect
levels were less than the respective mean and maximum observed Site concentrations in surface
soils, suggesting, potential adverse effects to mammals.  For wooded wetland areas more than ten
feet from the canal bank, the total PAH effect level exceeded the maximum observed soil
concentration, suggesting that risks in these areas are neglialble. PAH concentrations in the
Canal surface sediments exceeded interim sediment guality criteria for three of the six
compounds with existing criteria values.  Thus, the potential for adverse effects from exposure
to Canal sediments is relatively high. This was supported by field observations of adverse
effects to benthic organisms inhabiting the Canal sediments. In upland areas,  effects levels
were less than the maximum observed Site concentrations in surface soils but greater than the
observed mean soil concentrations. This suggests that potential adverse effects would be limited
to relatively small areas with high concentrations, such as the area of the former coal
gasification plant. All potential exposure pathways were evaluated including ingestion of
contaminated media and biota, inhalation, and dermal exposure from contaminants in, or

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volatilizing from, surface soils and sediments.

3. 1997 Supplemental Baseline Ecological Risk Assessment (SBERA)

In 1993, the Pine Street Barge Canal Coordinating Council convened an Ecological Work Group to
address data gaps and to re-evaluate the ecological risks associated with the Site. The
Ecological Work Group, comprised of technical experts representing EPA, the State of Vermont,
the PRPs and the citizen members of the Coordinating Council reached consensus on additional
work necessary to re-evaluate the ecological risks, agreed upon a weight of evidence approach to
evaluating the results of the data, and provided input into the preparation of the SBERA
(Weston, 1997). The SBERA augments the 1992 Baseline Risk Assessment.

The additional investigatory work proposed by the Coordinating Council was performed by the PRPs
in 1994-95 for the ARI. The ARI was completed in phases. Phase I included extensive surficial
soil sampling and screening for PAHs and metals. Using a threshold value of 40 ppm total PAH,
the Ecological Work Group delineated an area of focus within the Study Area. The focus area was
divided into eight subareas on the basis of physical characteristics and contaminant
concentrations (Figure 3). Phase II of the ARI included fish biomarker studies, aguatic insect
tissue collection analyses, and, in each subarea, chemical analyses and sediment toxicity
testing using two species of benthic invertebrates (Chironomus tentans and Hyalella azteca) and
the frog embryo, Xenopus laevis. A summary of ecological contaminants of concern in sediment can
be found in Table 2 of this Record of Decision.

The SBERA outlines the potential effects of site contaminants on ecological receptors. The
assessment methods used consider various endpoints and effects that differ in their suitability
for and sensitivity to assessing potential risks at the site. In assessing ecological risk, a
number of endpoints are measured and evaluated to provide a weight of evidence to the assessment
of risk. The weight of evidence approach is a process by which measures of exposure and effects
are evaluated against the target species or species groups to evaluate whether a significant
risk of harm is posed. The weights of evidence for ecological endpoints were agreed upon by the
Ecological Work Group prior to evaluation of the ARI data and potential ecological effects (see
Appendix C of the SBERA).

Section 4.3 of the SBERA report discusses the risk estimates and an interpretation of the
ecological significance of those estimates. Risk estimates consist of two primary elements, the
weight of evidence analysis and the interpretation of ecological significance. The weight of
evidence analysis the results of the risk estimation and uncertainty analysis and assesses
confidence in the risk estimates through a discussion of the different lines of evidence. The
second element, is the interpretation of ecological significance, which may be described in
terms of the spatial and temporal extent of adverse effects.

The following presents the findings of ecological risk to Pine Street Canal Superfund Site
target species or groups of species from exposure to detected contaminants in sediments. Due to
the complexity of contaminants and sediment environments at the Site, individual contaminants
could not be identified as specifically responsible for the adverse effects observed.

a. Sediment benchmarks and SEM/AVS ratios

Based on comparisons with NOAA and OMEE sediment benchmarks (ER-Ls, ER-Ms, LELs and SELs),
exceedances suggest that adverse effects on benthic communities from exposure to sediment
contaminants are a potential. EPA's Draft Sediment Criteria for acenapthene, fluoranthene,
and phenanthrene were exceeded by samples collected in 1994 in Subarea 8 (the turning
basin) and for samples collected in Subarea 1 (the canal) for acenapthene and phenanthrene
in 1995. Simultaneously extracted metals/acid volatile sulfides (SEM/AVS) ratios exceeded
1 for several samples in Subareas 2, 4, 6, and 7,indicating that benthic, toxicity
attributable to the five divalent metals (copper, cadmium, nickel, zinc and lead) is
possible.

b. Biomarkers

A biomarker is an indicator of toxic exposure observed at the biochemical, cellular, or
organ-level of an organism. The level of biochemical biomarkers observed during this study
indicates that fish from the Site had greater exposure to PAHs; than fish of the same
species found in the reference site (Shelburne Bay). No statistically significant
differences in cellular or organ-level biomarkers were observed, possibly suggesting
that although fish were exposed to PAHs at the Site, the levels of exposure were not
great enough to cause physical effects. However, because fish from both the Site and the
reference site were relatively young, they are not necessarily expected to have high
freguencies of these physical abnormalities.

c. Sediment Toxicity Tests

For the Chironomus tentans 10-day test, a statistically significant reduction in growth
and survival were observed in at least one sampling location in Subareas 1, 2, 3, 5, 6, 7,
and 8. The Chironomus tentans 30-day emergence test was conducted for samples in which
there was not statistically significant reduction in survival or growth in the 10-day test
when compared to the reference location response. Statistically significant reductions in
growth and emergence were observed in at least one sample in Subareas 3, 4, and 7. For

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the Hyalella azteca 10-day test, a significant decrease in growth and survival were
observed in samples Subareas 1, 2, 5, and 8. For the frog embryo teratogenesis assay
Xenopus (FETAX), statistically significant lower results for one or more of the three
endpoints evaluated (i.e., survival, growth, and malformation) were identified in samples
from Subareas 2, 6, and 7.

d. Avian Receptor Modeling

Estimates to the red-winged blackbird, tree swallow and great blue heron resulting from
exposure to contaminated media and biota are not expected to result in body burdens
responsible for adverse effects to reproduction, growth and survival.

The SBERA concluded that, based on the multiple lines of evidence associated with the
comparison of chemical concentrations to published sediment guidelines, evaluation of
chemical bioavailability using total organic carbon, SEM/AVS and eguilibrium partitioning
(EPA Draft Sediment Quality Criteria), sediment toxicity testing using C. tentans and H.
azteca, cytochrome P450 analysis, bile analysis and FETAX, baseline ecological risks were
exceeded in sediments in Subareas 1, 2, 3, 7, and 8. While there were findings of adverse
effects in Subareas 4, 5, and 6, these lines of evidence are not as compelling and do not
appear to constitute a baseline ecological risk.

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
standards, reguirements, criteria or limitations, unless a waiver is invoked; a reguirement that EPA
select a remedial action that is cost effective and that utilizes permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable; and a
preference for remedies that permanently and significantly reduce the volume, toxicity or mobility of
the hazardous substances. Remedial alternatives were developed to be consistent with these
Congressional mandates.

B. Remedial Action Objective/Goals

Remedial alternatives were also developed with and evaluated against site-specific remedial action
objectives and goals (RAO/Gs) that mitigate existing and potential threats to public health and the
environment. The remedial action objectives and goals established for the Site (Ecological, Human
Health, and Management of Migration) are discussed below.

1. Ecological

a. In areas where risks are unacceptable, including Subareas 1, 2, 3, 7, and 8,
eliminate direct exposure of ecological receptors to contaminated soils and
sediments, or reduce exposure to levels representing an acceptable risk.

a. In areas as identified in item a above, where it is not feasible to eliminate
direct exposure to contaminated soils and sediments or reduce exposure to levels
presenting an acceptable risk, reduce direct exposures of ecological receptors to
contaminants of concern to the extent feasible.

c. Prevent or minimize the long-term adverse effects of remediation activities on the
existing aguatic environment and/or wetland habitat.

d. Restore wetlands affected by remediation.

2 . Human Health

a. Absent an appropriate risk assessment which has been approved by EPA, prevent
unacceptable exposure (direct contact, ingestion and inhalation) to contaminated
soils located greater than five feet below grade.

b. Prevent ingestion and exposures associated with residential use (direct contact,
ingestion and inhalation) to contaminated groundwater where contaminated
groundwater presents unacceptable risks, including Class IV areas.

c. Prevent exposures associated with residential use (direct contact, ingestion and
inhalation) to contaminated soils, sediments, air and surface water at the Site.

3. Management of Migration

a. Protect Lake Champlain from being impacted by contaminants left on site.

i. Ensure Lake Champlain is not impacted by a significant increase in mass flux

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of contaminants through groundwater migration.

ii. Ensure Lake Champlain is not impacted by a significant increase in mass flux
of contaminants through contaminated sediment migration.

iii. Prevent changes in hydrogeologic conditions that will likely cause migration
of contaminated groundwater to Lake Champlain in concentrations that exceed
a standard to be developed.

b. Protect areas not targeted for remediation (both on- and off-site) by preventing
significant migration of contamination from on-site sources.

i. Ensure that contaminated groundwater with concentration levels above
drinking water standards does not migrate beyond the Class IV classification
boundary.

ii. Ensure that contaminated on-site sediments are not significantly mobilized.

iii. Ensure that NAPL is not significantly mobilized.

iv. Prevent degradation of surface water to levels above ambient water guality
criteria.

v. Prevent degradation of local (urban) background air guality.

c. Protect remediated area on the Site from becoming recontaminated from on site and
know off-site sources.

i. Ensure that hazardous substances left in place do not mobilize or create
unacceptable risk to ecological receptors and humans in remediated areas.

ii. Monitor to provide the necessary data to determine if non-CERCLA substances
are mobilizing or are creating unacceptable risks.

iii. Monitor to provide the necessary data to determine whether stormwater and
non-contact cooling water may be creating an unacceptable risk to ecological
receptors and humans in remediated areas.

4. Site Uses

a. Ensure to the extent practical that the remedy itself does not reduce the
suitability of the Site for current and future uses, including a highway.

b. Retain or expand current Class IV groundwater classification and boundary.

c. Maintain or replace beneficial functions and values of wetlands.

C. Development of Technology and Process Options

CERCLA and the NCP set forth the process by which technologies and process options are evaluated
and selected. The universe of technologies and process options to be considered for remedial action at
the Pine Street Canal Site was developed from a variety of sources. Technologies and process options
were identified based on a literature search and experiences at other manufactured gas plant sites,
using the resources of the Electric Power Research Institute, Gas Research Institute, EPA's Superfund
Innovative Technology Program, and information from vendors. Remedial technologies and process options
identified by the public during the 1992 comment period were also included.

In accordance with the reguirements, a range of alternatives were developed for the Site. The 1998 AFS
and the 1992 RI/FS evaluated alternatives in which treatment that reduces the toxicity, mobility, or
volume of the hazardous substances is a principal element, as well as alternatives that reduce toxicity
and mobility of hazardous substances by containment, which limits or eliminates the exposure of humans
and wildlife to contamination. Alternatives that remove or destroy hazardous substances to the maximum
extent feasible, eliminating or minimizing to the degree possible the need for long-term management,
were included. Also included was a limited action alternative that involves no treatment or
containment, but provides limited protection through institutional controls, as well as a "no action"
alternative. Table 3 of this Record of Decision presents all the remedial technologies and process
option evaluated for the Pine Street Canal Site.

With respect to groundwater, it is extremely unlikely that groundwater under the Site would be used as
a drinking water source. The City of Burlington has a municipal water supply and prohibits drilling of
drinking water wells within the City, and Lake Champlain provides an alternative source of drinking
water. Furthermore, in 1993, the State of Vermont reclassified groundwater under the Site to Class IV,
which prohibits its use as a potable drinking water source. Accordingly, the AFS did not evaluate any
remedial alternatives that seek to attain cleanup of the groundwater to meet federal and state drinking
water standards. However, the AFS did evaluate the imposition of additional institutional controls to
make certain that groundwater will not be used for drinking water purposes, as well as a no action
alternative.

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D. Technology and Alternative Screening

Various remedial technologies and process options that are potentially applicable to the RAO/Gs were
screened in accordance with EPA's Guidance for Conducting Remedial Investigations and Feasibility
Studies under CERCLA. This screening step includes three phases: 1) a preliminary screening phase, 2)
an initial screening phase, and 3) a detailed screening phase. The preliminary screening phase
evaluates broad technologies and process options based on implementability. The second screening phase,
the initial screening, evaluates the retained technologies and process options for effectiveness,
implementability, and cost. The third phase, the detailed screening, evaluates the retained
technologies and process options against the nine criteria established in the NCP. Screening results
are summarized below. For more detailed information, see Section 2 of the AFS.

1. Preliminary Screening for Implementability

Many technologies and treatment options were eliminated from consideration early on due to site
conditions that would make actual construction difficult or impossible. The subagueous
environment of the canal and turning basin, as well as the saturated soils in the wetlands and
upland areas are problematic for many in-situ treatment technologies such as soil venting, soil
washing, vitrification, radio freguency heating, and, bioremediation which reguires the presence
of oxygen. Applying these technologies on sediments removed from the canal, turning basin and
wetlands would be impracticable because the fine-grain size of the sediments hinders reguisite
dewatering. Many different types of caps for containment of the contaminated sediments, such as
compacted soil, geomembrane liners, non-compacted bentonite, and bentonite mats, were also
eliminated because of excess water.

In some instances, the types of contaminants found at the Site were the cause for a technology
or process to be eliminated. Solvent extraction is inefficient for PAHS. Incineration, and
landfarming or composting are not effective on inorganics. The organic content of the sediments,
prevents recycling in an asphalt paving batch plant (organic content too high), or for fuel
blending at a power generating station or industrial kiln (organic content too low). Innovative
technologies such as foam injection, electrokinetics, molten metal, while may be promising in
the future, are either not currently available for full-scale operation, or are still in the
research and development phase.

Upon completion of the preliminary screening phase, thirteen options remained for treatment of
contaminated sediments in the canal and turning basin, six remained for the wetlands and uplands
areas, and two remained for groundwater. The remedial action options retained are listed below.
(Note: Assessment of a "no action" alternative is reguired under Superfund and provides a
baseline for comparison to all other alternatives.)

a. Subareas 1-8

• No Action
• Institutional Controls
• Enhanced In-Situ Bioremediation
• Capping
• In-Situ Solidification/Stabilization
• Excavation with On-Site Disposal
• Vertical Containment
• Phytoremediation
• Excavation and Solvent Extraction
• Excavation and Ex-Situ Solidification/Stabilization
• Excavation and Ex-Situ Bioremediation
• Excavation and Thermal Desorption
• Excavation and Off-Site Disposal

b. Uplands/Wetlands

• No Action
• Institutional Controls
• Soil Excavation and Off-Site Disposal
• In-Situ Stabilization/Fixation
• Capping
• Phytoremediation

c. Groundwater

• No Action
• Institutional Controls

2. Initial Screening for Effectiveness, Implementability and Cost

Following the preliminary screening for technical implementability, the options retained are
evaluated for effectiveness, further implementability and cost. The effectiveness relates to the
overall performance in eliminating, reducing, or controlling the current and potential risks
posed by the Site, both during implementation and over time. The implementability involves the
degree of difficulty associated with actual construction, both technical and administrative, and
logistical problems that affect the time necessary to complete the remedy. Cost considerations

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include construction costs and the cost of operating and maintaining the remedy over time.

The results of assessments of these three considerations (effectiveness, implementability and
cost) are weighed against each other. Treatability studies might show a technology to be very
effective, but at an extremely high cost. Or, a technology might have relatively low capital,
and operation and maintenance costs, but might not be very effective in treating the
contamination. In this example, neither treatment option would make it to the short list to be
considered for the final, detailed screening phase.

At this Site, enhanced in-situ bioremediation, while possibly effective, would likely cause a
release of contaminants to surface water and ambient air, and is costly. In-situ solidification
and stabilization of submerged sediments in the canal and turning basin would be very difficult
to implement. Phytoremediation would not be effective during the dormant seasons of fall and
winter. Excavation of contaminated sediments is very effective in the long-term, but in the
short-term, increases risk because contaminants will be suspended in the water column, and will
migrate. Excavation would be difficult and costly to implement, given the amount of sediments
that would reguire dredging, dewatering, and subseguent treatment.

The treatment options that were retained for the final screening phase, are listed below.

a. Subareas 1-8

• No Action
• Capping
• Excavation and Off-Site Treatment/Disposal
b.
Uplands/Wetlands
No Action
Institutional Controls
Groundwater
No Action
Institutional Controls
3.
Detailed Screening Phase
The purpose of this detailed analysis is to objectively assess the alternatives with respect to
nine evaluation criteria established in the NCP that encompass statutory reguirements and
include other gauges of the overall feasibility and acceptability of remedial alternatives. The
criteria fall into three categories: threshold, balancing, and modifying. The two threshold
criteria must be met in order for an alternative to be eligible for selection in accordance with
the NCP. The five primary balancing criteria are used to compare and evaluate the elements of
alternatives that meet the threshold criteria. The two modifying criteria, state and community
acceptance are used in the final evaluation of the alternatives, generally after EPA has
received public comment on the RI/FS and proposed cleanup plan. The criteria are listed in
Section IX of this Record of Decision. A detailed description of the eight alternatives retained
for the final analysis, and assessed against the criteria are described in the following
section, Section VIII.
VIII. DESCRIPTION OF ALTERNATIVES

The 1998 AFS evaluated the remedial alternatives retained after the initial screening process for
effectiveness, implementability and cost. These include engineering measures as well as institutional
controls to protect human health and the environment from the risks presented at the Site. This Section
provides a summary of each alternative evaluated. A more comprehensive discussion of each alternative
can be found in Section 3 of the 1998 AFS.
Alternative 1
Alternative 2a
Alternative 2b
Alternative 2c
Alternative 2d
Alternative 3a
No Action Groundwater, Subareas 1-8, and Uplands/Wetlands; Long-term
Monitoring

Institutional Controls for Groundwater and Uplands/Wetlands; No Action
in Subareas 1, 2, 3, 7, and 8; Long-term Monitoring

Institutional Controls for Groundwater and Uplands/Wetlands; No Action
in Subareas 1, 2, 7, and 8; Capping in Subarea 3; Long-term Monitoring

Institutional Controls for Groundwater and Uplands/Wetlands; No Action
in Subareas 3 and 7; Capping in Subareas 1, 2, and 8; Long-term
Monitoring

Institutional Controls for Groundwater and Uplands/Wetlands; No Action
in Subareas 3 and 7; Excavation and Off-site Treatment and Disposal
for Subareas 1, 2, and 8; Long-term Monitoring; Dewatering

Institutional Controls for Groundwater and Uplands/Wetlands; Capping

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                                 in Subareas 1, 2, 3, 7, and 8; Long-term Monitoring

       Alternative 3b            Institutional Controls for Groundwater and Uplands/Wetlands; Capping
                                 in Subareas 3 and 7; Excavation and Off-site Treatment/Disposal for
                                 Subareas  1, 2, and  8; Long-term Monitoring; Dewatering

       Alternative 3c            Institutional Controls for Groundwater and Uplands/Wetlands; Capping
                                 in Subareas 1, 2, 3, and 8; No Action in Subarea 7; Long-term
                                 Monitoring

All of the alternatives include long-term environmental monitoring and five-year reviews. All of the
alternatives also include institutional controls to prevent the use of contaminated groundwater and
place deed restrictions on land use.

Alternative 3a is the remedy selected with this Record of Decision.

A.     Alternative 1:   No Action Groundwater,  Subareas 1-8  and  Uplands/Wetlands;  Long-term Monitoring

The "No Action" alternative is provided as a baseline for the comparison of all the other alternatives.
Under this alternative, no remedial activities and no institutional controls are implemented. This
alternative uses monitoring programs for groundwater, the eight subareas,  and the rest of the
uplands/wetlands areas to assess impacts from the contaminants  left on site.

Current groundwater data show that contaminants are not being discharged into Lake Champlain at
detectable levels. This condition is unlikely to change unless  there is an increase in hydraulic
gradient, area occupied by contaminants, or in concentrations in groundwater at or near the "source".
With the "No Action" alternative, a groundwater monitoring program would be used to identify changes in
site conditions relating to the fate and transport of contaminants in groundwater. There is no risk to
human health or the environment currently demonstrated in the uplands/wetlands area.

The "No Action" alternative for the eight subareas relies,  to the extent possible, on natural
attenuation to prevent migration of chemicals of concern in the sediments.  Two studies conducted
by RETEC, a contractor hired by the PRPs, in 1995 and 1996 tend to support the hypothesis that
naturally occurring mechanisms may be helping to stabilize the  rate of transport of the organic
constituents present in the soils and sediment. A monitoring program would be implemented to test
sediments for sulfide, PAHs, heterotrophic microorganisms,  and pH.  The results of these sampling would
be used to monitor the degradation of the organic constituents  in the sediments.

The "No Action" alternative does not prevent or reduce the risk to human health or the environment.
Risks identified during the SBERA evaluation are not mitigated, and without additional institutional
controls such as deed restrictions, the potential for consumption of contaminated groundwater in excess
of the MCLs still exists.

       Estimated Capital  Cost:  $125,050
       Estimated Annual Operation and  Maintenance  (O&M)  Cost: $102,563
       Estimated Total O&M over 30  Years (net  present worth): $1,272,702
       Estimated Total Cost of the  Remedy (net  present icorlh):  $1397,752

B.     Alternative 2a:  Institutional Controls  for  Groundwater and Uplands/Wetlands;  No  Action in
       Subareas 1, 2,  3,  7, and 8;  Long-term Monitoring

Alternative 2a combines natural attenuation principles from Alternative 1 with a variety of
institutional and administrative controls for the groundwater and upland/wetland areas, including

       •     implementation of institutional controls  to  prevent the use  of  groundwater  and limit land
            use at the Site;
       •     installation  and maintenance of a  barrier system around the  Site to  prevent unauthorized
            dumping;
       •     groundwater monitoring;
       •     sediment  sampling,  to monitor attenuation process;  and,
       •     sediment  transport monitoring to evaluate mass  flux of  contaminants  from the Site.

Alternative 2a reduces the risk to human health by implementing groundwater and land-use restrictions.
Enforceable institutional controls, such as deed restrictions,  in conjunction with the Class IV water
classification, will provide a greater level of assurance that  groundwater that does not meet State
standards for drinking water will not be used.  In addition,  deed restrictions or other institutional
controls would prevent land uses that could cause unacceptable  risk to human health, including risks to
workers or visitors at the Site.

Alternative 2a would not reduce the risk to the environment in Subareas 1,  2,  3,7, or 8.

       Estimated Capital  Cost:  $244,0469
       Estimated Annual Operation and  Maintenance  (O&M)  Cost: $119,750
       Estimated Total O&M over 30  years (net  present worth): $1,485,983
       Estimated Total Cost of the  Remedy (net  present worth):  $1,730,032

C.     Alternative 2b:  Institutional Controls  for  Groundwater and Uplands/Wetlands;  No  Action in
       Subareas 1, 2,  7,  and 8;  Capping in Subarea 3; Long-Term Monitoring

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Alternative 2b consists of the same elements as Alternative 2a with the addition of a sand and silt cap
over the emergent wetlands in Subarea 3. A cap is used to reduce exposure to contaminated sediments by
placing clean material over the existing contaminated substrate. Construction of the sand and silt cap,
approximately 1.5 feet thick, will consist of the following steps:

• mobilization and site preparation;
• site clearing to remove trees, brush, and grass from Subarea 3;
• if reguired to maintain wetlands functions, excavation of sediments from area to be capped
with disposal in the turning basin;
• cap construction using standard excavation eguipment;
• wetland restoration or replacement; and,
• site restoration.

Monitoring programs that consists of the same elements from Alternatives 1 and 2a will be used to
assess groundwater, natural attenuation, and sediment transport. Additional monitoring programs will be
implemented to monitor cap integrity, stormwater and sediment monitoring to evaluate cap performance.
The cap monitoring program ensures that the physical integrity of the cap is not compromised over time.

Since the portions of the Site affected in this alternative are wetlands, wetland impact will be
unavoidable. Every feasible measure will be taken to minimize or mitigate the impact on existing
wetlands. In areas where wetlands will be capped over, an effort will be made to replicate the
wetlands using suitable material from the local area. If no suitable material from the local area is
available an appropriate seed bank mix would be used to reestablish wetland vegetation in the impacted
areas.

This alternative offers the same level of overall protection of human health as Alternative 2a. The
same land-use and groundwater restrictions that were applied to the previous alternative would also
apply to this alternative. This alternative would provide a reduction in ecological risk for Subarea 3,
where exposure would be reduced by the presence of the cap. However, it provides no protection for the
other subareas (1, 2, 7, and 8) identified as having ecological risk.

Estimated Capital Cost: $532,613
Estimated Annual Operation and Maintenance (O&M) Cost: $132,250
Estimated Total O&M over 30 Years (net present worth): $1,641,096
Estimated Total Cost of the Remedy (net present worth): $2,173,709

D. Alternative 2c: Institutional Controls for Groundwater and Uplands/Wetlands; No Action in
Subareas 3 and 7; Capping in Subareas 1, 2, and 8; Long-Term Monitoring

This alternative includes the land-use and groundwater restrictions from Alternative 2a. This
alternative provides for capping for Subareas 1, 2, and 8, the canal and turning basin, and no action
for Subareas 3 and 7.

Capping isolates contaminated sediments by placing clean sediments over the existing substrate.
The proposed subagueous cap will be constructed of layers of sand and silt. A cap thickness of 1 to 1.5
feet will likely be sufficient to chemically isolate the PAHs and metals in the canal and turning
basin. The cap design must also provide resistance to erosion caused by surface currents and
groundwater currents, waves caused by wind, and propeller wash as well as a barrier to the effects of
borrowing bottom dwelling organisms (bioturbation). One important feature of this alternative is the
construction of a permanent weir at the mouth of the turning basin where it enters Lake Champlain.
This weir would be constructed in the approximate location of the existing beaver dam and will maintain
a water level of 96 feet above MSL or greater. The sand and silt cap construction would follow the
steps listed below:

• mobilization and site preparation,
• site clearing to remove trees, brush, and grass from cap area,
• construction of a permanent weir and a temporary turbidity curtain over the mouth of the
canal to prevent the potential migration of contaminants;
• if reguired to maintain wetlands functions, excavation of sediments from areas to be capped
with disposal in the turning basin;
• cap construction using a hydraulic method ;
• wetland restoration or replacement; and,
• site restoration.

This alternative would cause some adverse impacts to wetlands. After the clean fill has been placed,
the original bottom contours and hydrologic connections to Lake Champlain to the north, and storm
sewers and non-contact cooling water discharges to the south, will be restored. It is estimated that
the bottom elevation will be raised by 1 foot following the capping. However, in order to prevent or
mitigate adverse impacts on the wetlands caused by a decrease in water depth, a weir will be designed
to ensure that the water elevation in the canal remains at 96 feet above MSL or higher. The restored
bottom contours will permit emergent vegetation to colonize the clean sediments up to the maximum depth
the species will tolerate. Undisturbed plants in Subarea 4 will provide a seed bank for recolonization
of the restored areas.

Cap design will call for silt in the final sand layer to encourage recolonization by benthic organisms.
However, the benthic community will largely be determined by the natural processes that take place in
the canal and turning basin during spring flooding of Lake Champlain and water that enters the Site

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from the south. This water movement will both reintroduce benthic organisms to the area,  and provide
additional silt to the system.

This alternative includes stormwater redirection, stormwater inflow monitoring and sediment and
stormwater monitoring. (These monitoring programs are included for any alternative where active
remediation is provided in the canal and the turning basin.)  This alternative also includes cap,
sediment and stormwater monitoring programs to monitor the protectiveness of the cap.

This alternative provides a high degree of protection of human health and the environment through the
use of land-use and groundwater restriction, and a reduction in ecological risk at a significant
portion of the site (namely Subareas 1, 2, and 8).  However, the ecological risk identified in Subareas
3 and 7 would not be addressed by this alternative.

       Estimated Capital  Cost:  $2,083,107
       Estimated Annual Operation and Maintenance (O&M)  Cost:  $147,895
       Estimated Total O&M over 30 Years  (net present worth):  $1,835,235
       Estimated Total Cost of the Remedy  (net present worth):  $3,918,342

E.     Alternative 2d:  Institutional Controls for Groundwater  and Uplands/Wetlands;  No Action in
       Subareas 3 and  7;  Excavation and Off-site Treatment/Disposal for Subareas 1,  2, and 8;  Long-term
       Monitoring;  Dewatering

This alternative includes all the same components from Alternative 2c,  except for the areas of the
canal and turning basin,  where contaminated sediments would be excavated and taken off site for
treatment and/or disposal. This alternative includes the following:

       •     groundwater monitoring;
       •     administrative controls  to prevent the use of Site groundwater as a drinking  water source;
       •     restrictions  on the installation of wells that might  mobilize NAPL;
       •     in Subareas 1,  2,  and 8,  all of the visually contaminated materials in the canal  and
            turning basin will be excavated and transported off site for  treatment and/or disposal;
       •     sediment and  stormwater  monitoring in Subareas 3 and  7;
       •     monitoring of stormwater inflow to the canal and turning basin;
       •     installation  of barriers to prevent access for dumping;
       •     implementation of zoning changes to prevent site usage for  commercial activities  involving
            children,  and,
       •     prevention of potential  unacceptable risks associated with  soils  at depths greater than  5
            feet in uplands/wetlands.

It is estimated that excavation in Subareas 1, 2, and 8 would be approximately 25 feet in depth.  To
remove the contaminated materials the following steps would be taken:

       •     sheet piles will be driven into the clay layer to  provide support for the  excavation;
       •     existing stormwater and  process water inflows to the  canal  and turning basin  will  be
            diverted into Lake Champlain;
       •     the canal  and turning basin will be dewatered;
       •     the removed water will be treated in an  onsite treatment system and discharged either  to
            the local  POTW or to Lake Champlain;
       •     the visually  contaminated soft sediments and peat  will be excavated;
       •     excavated  materials will be further dewatered and  stabilized  (as  necessary)  to prepare the
            excavated  material for transportation and treatment or disposal;
       •     clean fill will be returned to the excavation area to maintain current subsurface
            elevations;
       •     the temporary weir will  be removed and the area of the Site affected by remediation
            activities will be revegetated;
       •     stormwater inflow diversion structures will be constructed;  and,
       •     the Site and  associated  wetland areas will be restored and  eguipment will  be  decontaminated
            and demobilized.

The excavation alternative for the canal and turning basin would reguire that trees, shrubs and large
herbaceous vegetation in a 10-foot perimeter be cleared for the placement of sheet piling. The cleared
perimeter in the drier northern end of the Site and around the turning basin will be seeded and
mulched.  Aggressive scrub shrub species would be expected to fill in the cleared area rapidly, once the
soil is stabilized.

The excavated material will be replaced with clean fill to recreate the present bottom contours.  The
original bottom contours and hydrologic connections  to Lake Champlain will be restored as far south as
the southern storm sewers and non-contact  cooling water discharges. The restored bottom contours will
permit the emergent vegetation surrounding the restored area to colonize the clean sediments up to the
maximum depth the species will tolerate. The spring flooding of Lake Champlain and the flow from the
south at other times of the year will introduce the  native benthic species to the restored areas.  This
water movement will also bring in silt to  add to the sediments.  The ultimate mix of sand and silt in
the sediments will be  strongly influenced  by these depositional processes, and the final benthic
community will be largely determined by these factors.

Under this alternative, a reduction in long-term ecological risks is anticipated. Long-term contact
with contaminants in Subareas 1, 2,  and 8  would be eliminated by removing the entire depth of impacted
soils and sediments and replacing with clean fill.  The installation of permanent sheet pilings around

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the perimeter of these subareas would reduce the likelihood of recontamination, although the sheet
piling could cause alterations to the hydrogeologic regime. This alternative does not address
ecological risks in Subareas 3 and 7, however.

This alternative contains protection from any risks posed by the groundwater or exposure to
contaminated media in the uplands/wetlands by implementation of groundwater and land-use
restrictions. However, a short-term increase in human health risks is anticipated as a result of
volatilization of contaminants during excavation. These risks could be controlled through the use of
emission control measures.

The potential for contaminated sediments in the canal and turning basin to migrate off site would be
completely removed with this alternative.

       Estimated Capital  Cost:  $39,042,497
       Estimated Annual  Operation and Maintenance (O&M)  Cost:  $125,770
       Estimated Total O&M over 30 Years (net present worth):  $1,560,685
       Estimated Total Cost of the Remedy (net present worth):  $40,603,182

F.     Alternative 3a: Institutional Controls for Groundwater and Uplands/Wetlands;  Capping in Subareas
       1,  2,  3,  7,  and 8;  Long-term Monitoring

This alternative combines the institutional controls for the groundwater and the uplands/wetlands areas
with the capping activities described in Alternative 2c. Additionally, Subareas 3 and 7 would be capped
and restored with an  engineered wetlands. With this alternative, all areas that have been identified as
posing an unacceptable ecological risk would be capped, thereby reducing direct exposure of wildlife to
contaminated soils and sediments.

Alternative 3a is the alternative that EPA has chosen as the most feasible and protective of human
health and the environment, and is explained in detail in Section X of this Record of Decision.

       Estimated Capital  Cost:  $2,543,762
       Estimated Annual  Operation and Maintenance (O&M)  Cost:  $147,895
       Estimated Total O&M over 30 Years (net present worth):  $1,835,235
       Estimated Total Cost of the Remedy (net present worth):  $4,378,997

G.     Alternative 3b: Institutional Controls for Groundwater and Uplands/Wetlands;  Capping in Subareas
       3 and 7;  Excavation and Off-site Treatment/Disposal  for Subareas 1,  2,  and 8;  Long-term
       monitoring;  Dewatering

This alternative combines the institutional controls on groundwater and the uplands/wetlands,
capping of the emergent  wetlands in Subareas 3 and 7, and excavation and off-site disposal of the
sediments and underlying peat layer in Subareas 1, 2, and 8. After excavation of Subareas 1, 2, and 8,
clean fill would replace all excavated materials, and the area will be restored to its original
contours. As with the previous alternatives, wetland restoration activities will take place throughout
the Area of Focus. Specific components of this alternative include:

       •    groundwater  water monitoring;
       •    administrative controls to prevent the use of site groundwater  for drinking water;
       •    restrictions  on installation of wells that might mobilize NAPL;
       •    sediment  and stormwater monitoring in Subareas  3 and 7;
       •    redirection  of offsite stormwater;
       •    monitoring of stormwater inflow to the canal and turning basin;
       •    installation of barriers to prevent access for  dumping;
       •    prevention of site usage for a  day care center  or commercial activities  involving children;
       •    prevention of potential unacceptable risks associated with soils  at depths  greater than 5
            feet in the  uplands/wetlands;
       •    capping of Subareas 3 and 7 as  described in Alternatives 2b and 3a;  and,
       •    excavation and off-site disposal of sediments in the canal and  turning basin as described
            in Alternative 2d.

Since the two technologies used in this alternative, capping and excavation and backfilling with
clean fill, both result  in reduction of the same ecological risk exposure  pathway, this alternative has
the same level of overall protection of the environment as Alternative 3a.

       Estimated Capital  Cost:  $39,477,672
       Estimated Annual  Operation and Maintenance (O&M)  Cost:  $119,895
       Estimated Total O&M over 30 Years (net present value):  $1,487,782
       Estimated Total Cost of the Remedy (net present value):  $40,965,454

H.     Alternative 3c: Institutional Controls for Groundwater and Uplands/Wetlands;  Capping,  in
       Subareas  1,  2,  3,  and 8; No Action in Subarea 7;  Long-term Monitoring

This alternative is exactly the same as alternative 3a, except that no cap would be  constructed in
Subarea 7. Each alternative with active remediation in the canal and turning basin include plans to
construct a sedimentation basin in Subarea 7 as part of the stormwater redirection program. This
alternative has been  included in acknowledgment of the fact that soils placed during cap construction
in Subarea 7 may be subject to some degree of recontamination from stormwater.

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Estimated CJapital Cost: $2,344,212
Estimated Operation and Maintenance (O&M) Cost (annual): $147,895
Estimated Present Value of O&M over 30 Years: $1,835,235
Estimated Cost of the Remedy: $4,179,447

IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

A. Evaluation Criteria

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

Threshold Criteria

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

1. Overall protection of human health and the environment addresses whether or not a remedy
provides adequate protection, and describes how risks posed through each pathway are
eliminated, reduced or controlled through treatment, engineering controls, or
institutional controls.

2. Compliance with applicable or relevant and appropriate requirements (ARARS) addresses
whether or not a remedy will meet all of the ARARs of other Federal and State
environmental laws and/or provide grounds for invoking a waiver.

Primary Balancing Criteria

The following five criteria are used to compare and evaluate the elements of the alternatives that meet
the two threshold criteria.

3. Long-term effectiveness and permanence assess alternatives for the long-term effectiveness
and permanence they afford, along with the degree of certainty that they will prove
successful.

4. Reduction of toxicity, mobility, or volume through treatment addresses the degree to which
alternatives employ recycling or treatment that reduces toxicity, mobility, or volume,
including how treatment is used to address the principal threats posed by the Site.

5. Short-term effectiveness addresses the period of time needed to achieve protection and any
adverse impacts on human health and the environment that may be posed during the
construction and implementation period, until cleanup goals are achieved.

6. Implementability addresses the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to implement a particular
option.

7. Cost includes estimated capital and Operation Maintenance (O&M) costs, as well as
present-worth costs.

Modifying Criteria

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

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

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

B. Summary of the Comparative Analysis of Alternatives

A detailed analysis was performed on each alternative using the nine evaluation criteria in order to
select a Site remedy. The strengths and weaknesses of each alternative with respect to the evaluation
criteria are summarized in Table 4 of this Record of Decision. After the detail analysis of each
individual alternative is conducted, a comparative analysis, again focusing on the relative performance
of each alternative against the nine criteria, is conducted. The following is a summary of the
comparative analysis. A more complete discussion of the comparative analysis can be found in Section 4
of the 1998 AFS.

1. Overall Protection of Human Health and the Environment

The potential risks identified at the Site are attributed to human health risks from consumption

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of groundwater and ecological risks from exposure to soils and sediments in Subareas 1, 2, 3, 7,
and 8. Additionally, the Site remedial action objectives/goals (RAO/Gs) provide for protection
and restoration of wetlands, prevention of unacceptable exposure to contaminated soils located
greater than 5 feet below grade, prevention of exposures associated with residential use, and
prevention of impacts to Lake Champlain. An evaluation of the ability of each site-wide
alternative to obtain the RAO/Gs is included in Table 5.

Alternatives 1 and 2a provide no protection against ecological risk. The remaining six remedies
have an active remediation component that would result in the reduction of risk to ecological
receptors from long-term exposures; however, some risk from short-term exposure to contaminants
during construction of the remedy will occur. Although off-site transport of contaminants is not
occurring at levels that are considered significant under current conditions, the implementation
of alternatives involving remedial activities in the canal and turning basin greatly reduces the
potential for future off-site migration of contamination.

The ranked order of active remediation alternatives with respect to ecological risk reduction.
Based on the sguare area of contaminated sediments capped or excavated and filled in, is as
follows: 3b (highest), 3a, 3c, 2d, 2c, 2b (lowest). Alternative 3b provides a slightly greater
level of protection of the environment than Alternative 3a, EPA's selected remedy, in the
long-term due to the complete removal of all contaminated materials in the canal and turning
basin versus capping these areas. On the other hand, Alternative 3a is more protective of human
health in the short term.

Alternative 1, "no action", does not eliminate site human health risks. Alternative 2a relies on
institutional controls to eliminate site human health risks by preventing consumption of
groundwater and unacceptable exposures to soils greater than 5 feet. As long as institutional
controls are maintained, site-related human health risks would remain within acceptable levels.
Like 2a, Alternatives 2b, 2c, 3a, 3b, and 3c rely on institutional controls for groundwater and
soils greater than 5 feet, as well as the integrity of the caps for protection of human health
and the environment.

Alternatives 3a and 3b are the most protective of human health and the environment, but involve
a level of short-term risk to Site workers and commercial area employees. Short term risk to
Site workers and commercial area employees is much greater under Alternative 3b because of the
added component of excavation and off-site transportation of contaminated materials, which could
result in exposures to volatilized contaminants. The short-term, temporary displacement of
ecological receptors and disruption of ecological habitats will occur with Alternatives 2b, 2c,
2d, 3a, 3b, and 3c, although this displacement can be minimized through engineering controls
during construction and wetlands restoration at the conclusion of construction activities. The
success of wetlands restoration would reguire long-term evaluation and maintenance.

2. Compliance with Applicable or Relevant and Appropriate Reguirements (ARARs)

Appendix B of this Record of Decision contains a summary of the applicable and relevant
reguirements for the alternatives considered in detail, and states how the alternatives comply
or fail to comply with all ARARs.

The most significant ARARs for the Pine Street Canal Superfund Site are laws and regulations
relating to the protection of wetlands and floodplains, the protection of historic resources and
handling, storage and disposal of hazardous wastes.

a. Wetland/Floodplain and CWA Section 404 Reguirements

Wetland and floodplain reguirements relate to the prevention of significant degradation of
the waters of the United States under Section 404 of the Clean Water Act, and reguire that
all appropriate steps be taken to minimize impacts to wetlands. The alternatives that
have remedial action components that eliminate the potential for migration of contaminated
sediments into Lake Champlain (Alternatives 2c, 2d, 3a, 3b, 3c) provide the highest degree
of protection. Alternatives 2a and 2b provide protection by monitoring sediment transport.

The alternatives that have an active remediation component (Alternatives 2b, 2c, 2d, 3a,
3b, 3c) would all reguire wetlands restoration activities to meet the reguirements of
Executive Order 11990, Section 404 of the Clean Water Act, and the Vermont Wetlands Rules.
Although remediation activities would result in some short-term impacts to wetlands,
restoration of wetlands and floodplains is a practical alternative for the Site. Section
404 of the Clean Water Act and the Vermont Wetland Rules reguire that remediation and
mitigation efforts will protect significant wetlands and the functions that they serve,
Under the Section 404 regulations, 40 CFR 230.10(a), there must be a comparison to other
practicable alternatives, and the "least environmentally damaging practicable alternative"
must be selected. Based on the comparison below, EPA has determined that Alternative 3a is
the least environmentally damaging practicable alternative that achieves the remedial
action objectives and goals. For purposes of the Section 404 analysis, the alternatives
were grouped into general categories of no action and engineering controls (Alternatives
1, 2a), capping alternatives (Alternatives 2b, 2c, 3a, 3c), and excavation and disposal
alternatives (Alternatives 2d, 3b). The no action and institutional controls alternatives
would leave habitat intact but would also leave contaminants where they are exposed to
wildlife, posing an unacceptable long-term ecological risk. Although the capping
alternatives would result in some direct short-term impacts to the Site, disturbance of

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wetlands and floodplains with subsequent wetlands restoration is the only practicable
alternative for the Site to address contamination while minimizing impact on the
terrestrial and aquatic ecosystem. Capping alternative 3a would restore portions of the
Site and replicate other portions on site to serve as a viable habitat where an indigenous
population of wildlife may exist and breed. The excavation and complete in-filling
alternatives present the maximum adverse impact on the terrestrial and aquatic
environments of all the alternatives evaluated.

The capping and excavation alternatives would require temporary disturbance of indigenous
population of wildlife. Although excavation would require temporary disturbance of a
significant portion of the submerged areas, these impacts would be minimized, and to a
large extent, mitigated through a variety of measures. Mitigating measures would be
implemented during and after dredging and capping to ensure that the replacement areas are
stable, will not erode, and will continue to perform the wetland functions of nutrient,
sediment, and toxicant removal and stabilization. The area will be restored (or enhanced)
as close as is practical to pre-excavation or capping conditions such that there are no
long-term adverse impacts to wildlife, recreation, aesthetics, and economic values.
Performance of the capping alternatives will meet or attain all applicable or relevant and
appropriate federal and state wetland and floodplain requirements for the Site. However,
placing a cap over sediments in the canal and turning basin will result in a slight loss
of flood storage capacity.

The excavation alternatives, 2d and 3b, can be designed and implemented to meet
action-specific ARARs with the exception of Section 404 of the Clean Water Act and Vermont
Wetlands Rules.

b. National Historical Presenation Act (NHPA)

The alternatives that involved excavation or capping of Subareas 1, 2, and 8 (Alternatives
2c, 2d, 3a, 3b, 3c) in which the potentially historically significant structures would
either be covered or excavated and disposed of off site with other debris would trigger
this ARAR. Compliance with the NHPA could be met by involving the proper agencies during
remedial design/remedial action and by initiating mitigation efforts such as additional
research and documentation, recordation, and/or data recovery. Alternatives where no
action is contemplated for these subareas would not trigger this ARAR. Alternatives
involving excavation and off-site disposal would result in the greatest adverse impacts
with regard to this ARAR and may require more significant activities to be compliance.

c. RCRA Issues

Those alternatives that involve the excavation and off-site disposal of materials that may
be identified as hazardous by characteristic would require management of these materials
according to specific RCRA requirements. For alternatives that have a consolidation of
materials that may be hazardous under a cap component (Alternatives 2c, 3a, 3c), specific
RCRA requirements including General Facility Standards, Preparedness and Prevention,
Contingency Planning and Emergency Procedures, Releases from Solid Waste Management Units,
and certain Closure and Post-Closure requirements (including groundwater monitoring) may
be relevant and appropriate. Those RCRA standards that may apply to the off-site disposal
or on-site containment portions of the alternatives will be considered during the Remedial
Design/Remedial Action phases of the work.

d. Groundwater ARARs

Although groundwater at the Site is heavily contaminated, EPA has determined, based on the
factors set forth at 40 C.F.R. 300.400(g), that drinking water regulations including those
established under the Safe Drinking Water Act, are not ARARs for the Pine Street Site.
Therefore, none of the remedial alternatives evaluated are required to meet drinking water
standards.

This determination is based on several conditions specific to the Pine Street Canal Site.
EPA has concluded that it is extremely unlikely that contaminated groundwater underlying
the Pine Street Site will be used as a source of drinking water. First, the Site is
located in an urban area that has been used for industrial/commercial purposes for many
years. The Site is not zoned for residential purposes, and residential development is
unlikely because much of the Site contains extensive wetlands and is located in a 100-year
floodplain. It is therefore unlikely that private drinking water wells would be installed.
Second, ample alternative water supplies are available. The Site is located next to Lake
Champlain, which provides drinking water for the City of Burlington and will continue to
meet the City's needs in the future. Although groundwater in the deep bedrock aquifer is
currently used for commercial/industrial purposes, all residential drinking water in the
city of Burlington is provided (after treatment) by Lake Champlain. Finally, pursuant to
10 V.S.A. 1394, the State of Vermont in 1993 reclassified the groundwater underlying most
of the Site as Class IV groundwater, which is not suitable as a source of potable water
(but which is suitable for some agricultural, industrial and commercial uses).

3. Long-Term Effectiveness and Permanence

To conduct the evaluation of long-term effectiveness and permanence for each alternative, the

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remedies have been grouped into "active" remedies (those that contain remedial actions for at
least one portion of the Site including Alternatives 2b, 2c, 2d, 3a, 3b, 3c), alternatives that
rely solely on monitoring and institutional controls for effectiveness (Alternative 2a), and the
no action alternative (Alternative 1). No action includes monitoring of the groundwater and
sediments for natural attenuation potential and stormwater outflow monitoring.

Alternatives 3a and 3b provide the highest degree of long-term effectiveness. Both rely on
institutional controls to prevent the consumption of contaminated groundwater and access to the
uplands/wetlands portion of the Site. Alternative 3b, which minimizes long-term ecological risk
by removing contaminants in Subareas 1, 2, and 8, would provide a greater level of long-term
effectiveness over Alternative 3a, which reduces long-term risk by capping contaminated
sediments there. While the permanence of Alternative 3a relies on long-term monitoring and
maintenance of the cap to ensure effectiveness, the cap and construction methods would be
designed to provide long-term success. Alternative 3c would provide the third highest level of
long-term effectiveness and permanence. Alternatives 2a, 2b, 2c, and 2d are effective in
preventing consumption of the groundwater, but provide a lesser degree of ecological protection.
With all of the active remedies, the long-term effectiveness of wetland and aguatic habitat
restoration must be monitored. Over time, modifications may be needed to increase the long-term
effectiveness and permanence of these alternatives. Alternative 1, "no action", provides the
least degree of ecological protection.

4. Reduction of Toxicity, Mobility, or Volume Through Treatment

Alternatives 2d and 3b, those alternatives with excavation and off-site treatment/disposal
components, would provide reductions in toxicity, mobility, and volume. These two alternatives
would also provide a reduction in the toxicity, mobility, and volume of contaminated surface
water recovered during the excavation and dewatering steps. Alternatives 2d and 3b are the only
alternatives in which process residuals may be generated. These would probably be sent off site
for treatment/disposal or discharged to surface water or storm sewers. The volume of residuals
generated would be a function of the reguired effluent water guality parameters. None of the
other alternatives under consideration would provide a reduction in the toxicity, mobility or
volume through treatment of contaminated groundwater or soils/sediments, nor would they generate
process residuals.

In the no action and institutional controls alternatives (Alternatives 1, 2a), natural
attenuation might provide some measure of reduction in the toxicity of the sediments in the
upper portions of the sediments. The capping alternatives (Alternatives 2b, 2c, 3a, 3b, 3c) will
result in a reduction of mobility and exposure to toxicity through the isolation of contaminants
from ecological receptors.

5. Short-Term Effectiveness

The RAO/Gs would be best met in the short-term by the placement of a cap over all areas
identified as presenting unacceptable ecological risk (Alternative 3a), second by those
alternatives with a capping activity over some portions of these areas (Alternatives 3c, 2c, and
2b in descending order), and then those alternatives with an excavation component (Alternatives
3b, 2d). Alternatives 1 and 2a would not meet the RAO/Gs in the short-term.

Institutional controls to protect human health could be obtained in a relatively short time
frame (approximately 3 months). The alternatives that have a capping component and wetlands
restoration (Alternatives 2b, 2c, 3a, 3b, 3c), may be associated with an increase in short-term
human health risk from volatilization of contaminants during construction. Volatilization
potentials are slightly greater with the placement of caps in the emergent wetlands areas
(Alternatives 2b, 3a, 3b, 3c) rather that in the agueous environment of Subareas 1, 2, and 8.
However, capping activities in the agueous portions of the Site have a greater potential for
release of contaminants into surface water. The mitigation activities, including construction
controls and the placement of a temporary weir at the mouth of the turning basin, would reduce
these risks.

Short-term risks to ecological receptors are likely to increase for all alternatives with an
active remediation component (all alternatives except 1 and 2a). Those alternatives with greater
soil and sediment disruption reguirements, i.e., excavation of Subareas 1, 2, and 8, would cause
the greatest short-term risk to the benthic population. This risk is deemed lower for
Alternatives 2b, 2c, 3a, and 3c, where the remedial components consist of capping and wetlands
restoration activities. All active remedial alternatives will result in short-term displacement
and mortality of some organisms.

Additionally, short-term habitat impacts will occur during and following implementation of the
active remediation alternatives. Disturbed habitat would be restored after remediation.

6. Implementability

Alternatives 1 and 2a, which reguire administrative activities and minor site activities
(possible installation of additional monitoring wells, and installation of a barrier system),
would be the easiest to implement. Alternatives with active remediation components would reguire
varying degrees of effort and are evaluated below.

Alternative 2b, which reguires capping of Subarea 3, would be the most implementable of the

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       active remedies. With potential  access  from the General Dynamics property  and  the  use of
       conventional earth moving equipment,  this  alternative could be rapidly implemented.  Construction
       of the restored wetlands habitat would  be  easiest in this area, which is less  submerged than
       other portions of the area of focus.

       Alternative 2c, which would require  subaqueous capping in Subareas 1, 2, and 8,  would be
       slightiv more difficult to implement, and  fewer contractors are available  to conduct this work.
       However,  wetland restoration activities would be the easiest to conduct.

       Alternatives 3a and 3c, capping  and  wetlands restoration across all  subareas evaluated in the
       area of focus  (with the exception  of Subarea 7 in Alternative 3c), would require significant
       coordination of activities to reduce impacts to the surrounding emergent wetlands  and would
       require more than one set of construction  methods. Wetlands restoration in both  Subareas 3 and 7
       would be significantly greater than  Subarea 3 only, or in Subareas 1, 2, and 8.

       Alternative 2d, with excavation  of the  entire depth of impacted soft sediments and peat in
       Subareas 1, 2, and 8, would require  significant dewatering and subsequent  water  treatment
       activities, sheet pile installation,  large staging areas, and coordination with  the City to
       conduct large scale transportation of excavated materials to disposal. The implementability of
       dewatering these materials has not been tested, and the issues surrounding dewatering peat could
       be significant. Furthermore, the extremely large volume of clean fill necessary  to infill this
       area may be limited in availability.

       Alternative 3b, which combines the implementability problems of capping the emergent wetlands
       and subsequent wetlands restoration  activities with the excavation and infilling issues of
       Subareas 1, 2, and 8, would be the most difficult remedy to implement.
       7.
              Cost
       As summarized in the Estimated Cost  Table on the following page, the total net  present cost for
       all alternatives varies from  $1.4 million for no action (Alternative 1) to $41  million for
       Alternatives 2d and 3b. The costs developed for this document are intended for  comparison
       purposes only, actual remedial action  costs would be developed after the Record of Decision and
       remedial design.

       8 .     State Acceptance

       The Vermont Department of Environmental  Conservation (DEC) has been involved  in all Site
       activities to date. Representatives  of Vermont DEC served as members of the Coordinating
       Council, that developed and oversaw  the  ARI/AFS, and joined in the consensus  recommendation of
       the Coordinating Council that EPA should propose Alternative 3a as the remedy for  the Pine
       Street Canal Site.

       The Secretary of the Vermont  DEC has provided EPA with a letter of concurrence  with the selected
       remedy. This letter is attached as Appendix C.
                                           Estimated Cost Table
1:
2d:
             Site-Wide
            Alternative
No Action, Groundwater, Subareas 1-8,  and
Uplands/Wetlands;Long-term Monitoring
      Institutional Controls, Groundwater and
      Uplands/Wetlands;  No Action,  Subareas 1,2,4,7, and 8;
      Long-term Monitoring
                                                                        Estimated
      Institutional Controls, Groundwater and
      Uplands/Wetlands;  No Action,  Subareas and  7
      Subareas  1, 2, and 8; Long-term Monitoring
      Institutional Controls, Groundwater and
      Uplands/Wetlands;  No Action,  Subareas 3 and 7;
      Excavation and Off-site Treatment/Disposal, Subareas  1,
      2, and 8; Long-term Monitoring; Dewatering

      Institutional Controls, Groundwater and
      Uplands/Wetlands;  Capping,  Subareas 1,2,3,7, and 8;
      Long-term Monitoring  (EPA's selected alternative)
                                                           Capital
                                                           Annual O&M
                                                           PV of O&M
                                                           NPV

                                                           Capital
                                                           Annual O&M
                                                           PV of O&M
                                                           NPV

                                                           Capital
                                                           Annual O&M
                                                           PV of O&M
                                                           NPV

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3 b: Institutional Controls, Groundwater and
Uplands/Wetlands; Capping, Subareas 3 and 7; Excavation
and Off-site Treatment/Disposal, Subareas 1, 2, and 8,
Long-term Monitoring; Dewatering
Capital
Annual O&M
PV of O&M
NPV

Capital
Annual O&M
PV of O&M
NPV
9.
Community Acceptance
As mentioned above, EPA began working in 1993 with the Pine Street Barge Canal Coordinating
Council, which includes several community representatives including the City of Burlington, the
Lake Champlain Committee (a regional environmental organization), The Pine Street Arts and
Business Council, and the Ward 5 Planning Association. Each of these representatives freguently
reported back to larger constituencies. Over the course of five years, the Coordinating Council
and its working groups met scores of times. Consensus decisions on the scope and implementation
of studies were made with the full participation of the community members on the Coordinating
Council. In May 1998, the Coordinating Council voted as a whole to recommend that EPA propose
Alternative 3a as the preferred remedy for the Site.

Comments received from the public at large during the 60-day comment period were generally
supportive of the selected remedy. One member favored selecting the more permanent remedial
alternatives rather than a containment alternative. Copies of the comments received and EPA's
response are presented in the Responsiveness Summary, attached as Appendix E.
X.
THE SELECTED REMEDY
Detailed Description of Alternative 3a: Institutional Controls, Groundwater and Uplands/Wetlands;
Capping, Subareas 1, 2, 3, 7, and 8; Long-term Monitoring

The remedy selected to address contamination at the Pine Street Canal Superfund Site is Alternative 3a,
which best satisfies the statutory criteria for remedy selection.

Alternative 3a provides for capping of contaminated sediments in all areas where an unacceptable
ecological risk has been found, effectively isolating the contamination below the biologically active
zone. Long-term performance monitoring of groundwater, surface water, stormwater, sediments and the
caps is reguired. This alternative includes institutional controls to:(1) prevent the use of on-site
groundwater for drinking water,(2) prevent land uses that could result in unacceptable risks to human
health, such as residential use, use as a children's day care center and most excavations below five
feet; and (3) prevent or limit the migration of existing contamination. These institutional controls
are discussed below in Section E.

Implementation of this combination of engineering and institutional controls is expected to be
completed within a three-year time frame. All design issues presented in this section will be
reevaluated during the remedial design.
A.
Capping
Alternative 3a calls for subagueous capping of Subareas 1, 2, and 8 (the canal and turning basin), and
construction of a cap in the emergent wetlands in Subareas 3 and 7 (Figure 7).

As conceived in the AFS, the subagueous cap in Subareas 1, 2, and 8, will be constructed of layers of
sand and silt. A final cap thickness of 1 to 1.5 feet above the current bottom elevation will likely be
sufficient to chemically isolate the PAHs and metals in the sediments in the canal and turning basin.
Analysis of site-specific cap design reguirements will be conducted to identify necessary elements in
the final design to ensure satisfactory performance in the field. For example, it may be necessary to
place at least 2.5 to 3 feet of capping material to attain the final cap thickness, after settling and
consolidation occurs. The cap design must provide resistance to erosion caused by surface currents,
waves caused by wind, and propeller wash, as well as a barrier to the effects of borrowing bottom
dwelling organisms (bioturbation). It is not expected that excavation of existing bottom sediments
prior to placement of the cap will be reguired to limit increases in the elevation in the bottom of the
canal; however, this issue will be reevaluated during design. If it is determined that excavation is
reguired, sediments would be dredged from the canal and transported by pipeline or truck to the turning
basin for on-site disposal.

The method for placement of the subagueous cap is expected to be hydraulic placement, as described in
Section 3.5.1 of the AFS. This would reguire placement of the cap over and around the five sunken
barges in the canal and turning basin, and would reguire measures to minimize disturbance. State and

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federal law require mitigation of the adverse effects of the remedial action on these potentially
historic resources. The barges and other potential historic structures will be recorded and documented,
prior to placement of the cap.

One important feature of this alternative is the construction of a permanent weir at the mouth of the
turning basin where it enters Lake Champlain. This weir would will be constructed in the
approximate location of the existing beaver dam and will maintain a water level of 96 feet above
MSL or greater. The weir will not cause significant additional inundation during periods of high
water, and will help maintain an adequate surface water depth where the subaqueous cap is
constructed. The weir will also help to reduce the potential for cap erosion. Based on historic lake
level records, the weir will not hinder fish migration between the Lake and canal.

Construction of the subaqueous cap will follow the steps listed below:

• mobilization anti site preparation;
• site clearing, to remove trees, brush, and grass from cap area;
• construction of a permanent weir and a temporary turbidity curtain over the mouth of the
canal to prevent the potential migration of contaminants;
• excavation of sediments from areas to be capped, if required to maintain wetlands
functions, with disposal in the turning basin;
• construction of subaqueous cap;
• wetland restoration or replacement; and,
• site restoration.

In order for the subaqueous cap to be effective, it must prevent the migration of contaminants (by
erosion, diffusion, advection or bioturbation) from the underlying contaminated sediments through the
cap, and then their contact with benthic organisms and fish in the biologically active portion of the
canal bottom at ecologically harmful levels. Performance standards for physical, chemical and
biological characteristics of the cap will be developed during the design phase. Post-construction, the
cap will meet the physical requirements of the design within pre-determined tolerance limits. Chemical
concentrations in vertical samples of the cap will be compared to screening-level benchmarks such as
EPA's Draft Sediment Quality Criteria for PAHs or Ambient Water Quality Criteria (AWQC), NOAA's Effects
Range-Medium (ER-M) or -Low (ER-L) concentrations, or Ontario Ministry of the Environment (OME) Lowest
Effects Level (LEL) guidelines. Grab samples of the cap will be evaluated for the presence/absence of
benthic macroinvertebrate species.

In addition to the subaqueous cap in the canal and turning basin, the selected remedy provides for
placement of a sand/silt cap over the emergent wetlands in Subareas 3 and 7, in order to prevent the
migration of contaminants to the environment. The steps for construction of the cap over Subareas and 7
are similar to the process for construction of the subaqueous cap in Subareas 1, 2, and 8. However,
because access is significantly easier in Subarea 7 than in the other four subareas, and because
excavation equipment will be used in the area to restore Subarea 7 wetlands, it is likely that
mechanical methods will be used to place the cap (although hydraulic methods are a possibility).

As with Subareas 1, 2, and 8, it is possible that some excavation of sediments may be required in
Subareas 3 and 7 to meet wetland restoration goals established during remedial design. Excavated
materials would be transported by truck and placed in the turning basin for disposal.

Alternative 3a also calls for placement of a soil cover over an area of elevated concentrations of COCs
in the uplands/wetlands area to reduce exposure. An evaluation of soil constituent concentrations in
that area indicate that an area of approximately 100 feet by 100 feet will require covering. Topsoil
will be spread over the area followed by seeding with wetland species and plantings of appropriate
plants.

B. Stormwater Inflow Management

The selected remedy includes the redirection of stormwater from storm sewers at the southern end of the
Site, in order to reduce the potential that any contaminants from off site may recontaminate remediated
portions of the Site. Stormwater entering Subarea 7 will be redirected using a spreader structure. It
is expected that the culvert under North Road will be modified, and North Road will be raised by about
two feet, to allow suitable retention time to remove sediments from stormwater passing through the
wetland. As an added benefit, this will reduce the occurrence of flooding over the road. In addition,
the stormwater flowing onto the Site north of the Burlington Electric Department property will be
redirected using a spreader structure.

C. Performance Monitoring

Long-term performance monitoring to address the remedial action objectives and goals is required as
part of the selected remedy. The monitoring program will include, but will not be limited to:

1. Groundwater monitoring to verify the current understanding of hydraulic conditions, to
ensure that contaminants do not migrate beyond the Class IV boundary at concentrations
Champlain. The monitoring data will be used to evaluate whether there is a change in
hydraulic gradient, an increase in the cross sectional area occupied by contaminants, an
increase in contaminant concentration in groundwater at or near the "source", or an
increase in mass flux of contaminants to the Lake. The groundwater monitoring program will
be refined during, design, but will include, at a minimum, chemical monitoring of existing
wells at regular intervals, installation and chemical monitoring of additional wells as

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             determined necessary by EPA; and measurement of groundwater elevations.

       2.     Surface Water Monitoring to prevent degradation of surface water to levels above ambient
             water guality criteria ensuring protection of the canal and Lake Champlain, and the
             protectiveness of the remedy over the long term.

       3.     Stormwater Inflow and Non-Contact Cooling Water Monitoring to determine whether or not
             stormwater  (dissolved and sediment loads) and non-contact cooling water are creating
             unacceptable ecological or human health  risks in remediated areas of the Site.

       4 .     Sediment Monitoring to determine if contaminated sediments from the non-capped uplands and
             wetlands portions of the Site are contaminating the remediated areas or the Lake. Also, to
             ensure that the sediment cover in unremediated portions of the Site remains of a
             sufficient thickness so as not to pose unacceptable ecological or human health risks.

       5.     Performance Physical and Chemical Monitoring of the Cap to verify attainment of remedial
             action objectives and goals. The methods of measuring performance of the subagueous cap
             will be refined during design of the cap, but will include physical inspection; chemical
             monitoring of cap sediments  (including pore water) and surface water, and, biological
             monitoring.

      6.      Wetlands Monitoring to ensure that erosion controls and wetland hydrology remain in place
             for the establishment of stable biological communities, and restoration/mitigation of
             wetland and aguatic structure and function as defined by the ecological advisory group.

D.      Site Boundary Definition

Studies conducted under the direction of the EPA since 1988 have examined a 70-to 80-acre area,  known
as the Study Area,  which includes the properties between Lakeside Avenue to the south,  Pine Street to
the east,  Vermont Railway property to the north,  and the Vermont Railway and Lake Champlain to the
west. With this Record of Decision,  the Site is now defined as the much smaller 38-acre area (within
the Study Area) where contaminants associated with wastes from the manufactured gas plant have been
found (Figure 2).  The remaining portions of the original 70-acre Study Area are not part of the Pine
Street Canal Superfund Site.  Future land use on the Site and parcels outside of the Site boundary that
are identified in the footnote on the following page will be subject to institutional controls to limit
the potential for unacceptable risk to human health and the environment.

E.      Institutional Controls

The selected remedy includes legal controls (known as "institutional controls")  to ensure protection of
human health over the long term.  The institutional controls will impose certain groundwater use and
land use restrictions on the site and on parcels adjoining the site,  in order to prevent unacceptable
exposures to contaminants and to prevent further migration of contaminants.   The form of institutional
controls will be determined during implementation of the remedy,  but may include deed restrictions,
easements, and/or zoning ordinances.   The institutional controls will be crafted so that they will run
with the land,  and will be enforceable by either EPA,  the State of Vermont,  or other appropriate
entities.

The institutional controls will include restrictions for parcels of property within the site boundary,
as well as certain properties outside the boundary of the Site,  1 where restrictions are necessary to
ensure that the on-site remedy remains effective (collectively,  the "Properties").  The restrictions
will include:

       •     The Properties will not be used  for  residential  use  or  for  children's day care  centers;

       •     Groundwater  under  the  Properties  shall  not be  used  for  potable drinking  water purposes.  No
            production well  (e.g.  for  industrial use)  will  be  installed at any  location where  free
            phase  contamination has been  shown  to  be present;

       •     The Properties will not be used  so  as  to  interfere with investigations  of environmental
            conditions,  or  cause  recontamination of the  Site  or  contamination  of  off-site properties
            following completion  of the  remedy.

       •     No  construction  activities that  will change  hydrogeologic  conditions  and that would  cause
            migration of contaminated  groundwater  to Lake  Champlain will be  allowed;

       •     Excavations  to  depths  greater  than  five feet  (including those below  the  water table)  on  the
            Properties will be  prohibited  unless one  or  more  of  the following  exceptions  apply:(a)  the
            excavation  is performed to install,  repair,  maintain,  service or remove  underground  utility
            components,  conduits,  installations  or  channels, which  may  presently  be  in place deeper
            than five feet  and  which may be  below  the  water  table;  (b)drilling,  driving  or  boring to
            install pilings  for otherwise  allowable construction  is permitted;  or,(c)  the excavation is
            performed in a  location on the property in which  current  contaminant  concentrations  at
            depths  greater  than five  feet  are below 140  mg/kg  total PAH In the  case  of exceptions  (a)
            and (b), workers  conducting  the  excavations  and working in  the area must use  appropriate
            personal protective eguipment  as  reguired  by the  Occupational Health  and Safety
            Administration  or  its  successor  agencies,  unless  a  site-specific risk assessment is
            performed and  its  results have been  approved by  EPA prior  to the excavation.

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1 These properties are identified as properties 53-0-7-0, 52-0-1-0, 52-04-0, 52-0-5-0, 52-0-6-0,
52-0-8-0, 52-0-9-0, 52-0-10-0, 56-0-6-0, 56-0-7-0, and 56-0-9-0 on the City of Burlington tax
assessor's map.

F. Wetlands Restoration

The selected remedy will result in some immediate adverse impacts to wetlands at the site, which will
be mitigated. Significant wetlands restoration activities will be conducted with this alternative to
restore the functions and values of the various wetlands habitats affected by remediation. The specific
goals and objectives of the wetlands restoration/mitigation program will be refined during design, in
meetings of an ecological advisory group that the EPA intends to reconvene. No restoration/mitigation
activities will be allowed that could change hydrogeologic conditions, and cause erosion and migration
of contaminated sediments to Lake Champlain or the canal.

The current mix of open water, emergent, scrub/shrub and forested wetlands on the Site will be
preserved. This will also provide sediment trapping and flood storage functions. The restored
bottom contours will permit emergent vegetation (such as cattail) surrounding the restored area to
colonize the clean sediments. The spring flooding of Lake Champlain and the flow from the south at
other times of the year will also introduce the native benthic species to the restored areas in the
canal and turning, basin. This water movement will also bring in silt to add to the sediments. Silt
will be included in the final layers of the sand cap to encourage recolonization by benthic organisms,
but is not essential to the long-term recovery of the community. The final mix of sand and silt in the
sediments will be strongly influenced by the depositional processes that occur naturally, which in turn
will determine the characteristics of the benthic community.

In Subareas 3 and 7, wetland soils or top soil will be placed over the sand cap. In Subarea 3, young
shrubs will be planted along the northern boundary of the General Dynamics property and the edge of the
cap to accelerate the development of scrub/shrub vegetation. The combination of the placement of the
cap and the raising of the water level will likely increase the amount of scrub/shrub wetland and
decrease the amount of emergent wetland in Subarea 3. In Subarea 7, a wetlands diversity seed mix,
including rushes, sedges, grasses and other fauna, will be applied if necessary to restore the
functions and value of the wetlands there. Measures (such as a weir) at the culvert under North Street
may be taken to control the water levels in Subarea 7.

G. Cost

The capital cost for Alternative 3a is estimated as $2,543,762. The annual operating cost for the
alternative is $147,895 with a present worth value for 30 years of $1,835,235. The total present worth
cost of the remedy is estimated at $4,378,997. Details of this estimate are presented in Table C-6B of
the AFS.

XI. STATUTORY DETERMINATIONS

The remedial action selected for implementation at the Pine Street Canal 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 does not satisfy the
statutory preference for treatment that permanently and significantly reduces the mobility, toxicity or
volume of hazardous substances as a principal element. The remedy does significantly reduce mobility
through use of containment technigues. The selected remedy utilizes alternate treatment technologies or
resource recovery technologies to the maximum extent practicable.

A. The Selected Remedy is Protective of Human Health and the Environment

The remedy at this Site will permanently reduce the risks posed to human health and the environment by
eliminating, reducing or controlling exposures to human and environmental receptors through
containment, engineering controls, and institutional controls. Capping will also prevent further
transport of contaminants into the surface water. Institutional controls will be implemented to prevent
the use of contaminated groundwater. Legal mechanisms, such as deed restrictions, will restrict future
land uses that could result in unacceptable risks to human health and the environment. Long-term
monitoring will insure that the remedy remains protective in the future.

B. The Selected Remedy Attains ARARs

This remedy will meet or attain all applicable or relevant and appropriate federal and state
reguirements that apply to the Site. A detailed listing of environmental laws from which ARARs for the
selected remedial action are derived, and the specific ARARs can be found in Appendix B of this Record
of Decision. These tables give a brief synopsis of the ARARs and an explanation of the actions
necessary to meet the ARARs. These tables also indicate whether the ARARs are applicable or relevant
and appropriate to actions at the Site. In addition to ARARs, the tables describe standards that are
To-Be-Considered (TBC) with respect to remedial actions.

The more significant ARARs are discussed in detail below.

1. Principal ARARs for Groundwater Protection

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As noted above in Section IX federal drinking water standards promulgated under the Safe
Drinking Water Act are not relevant and appropriate, because it is highly unlikely that
groundwater at the site will be used as a drinking water source.

Primary Groundwater Standards, contained in the State of Vermont Groundwater Protection Act and
Groundwater Quality Standards (10 V.S.A. Chapter 47 and 48) are applicable. The Vermont Agency
of Natural Resources has classified groundwater under the Site as Class IV, suitable for some
agricultural, industrial and commercial use but not as a source of potable water. The management
objective for Class IV groundwater is to achieve the Vermont Groundwater Standards to the extent
feasible. The selected remedy will comply with this ARAR by achieving the standards at and
beyond the boundary of the Class IV designation.

2. Principal ARARs/TBCs for Wetland Protection

The federal Clean Water Act, the Vermont Wetland Rules, and Executive Order 11990 are ARARs for
the remedy, as the cap will be constructed in and will affect wetlands at the Site.

The selected remedy complies with regulations promulgated under Section 404 of the Clean Water
Act at 40 CFR 230.10. The selected remedy is the least environmentally damaging practicable
alternative which attains the project purpose of addressing ecological risk; the remedy will not
cause or contribute to a violation of a state water guality standard, violate any toxic effluent
standard; and will not jeopardize any endangered species; the remedy will not cause or
contribute to significant degradation of water of the United States; and the remedy includes
appropriate steps to minimize the impacts the aguatic ecosystem. Although the remedy will
result in some direct short-term impacts to the Site, disturbance of wetlands and floodplains
with subseguent wetlands restoration is the only practicable alternative for the Site that will
address contamination while minimizing impact on the terrestrial and aguatic ecosystem.
Mitigating measures will be implemented during and after both the dredging activities and the
cap placement activities to ensure that the replacement areas are stable, will not erode, and
will continue to perform the wetland functions of nutrient, sediment, and toxicant removal and
stabilization. The remedy includes restoration/mitigation of portions of the Site and
replication of other portions on-site to allow the area to serve as a viable habitat where an
indigenous population of wildlife may exist and breed. The area will be restored (or enhanced)
as close as is practical to pre-excavation or capping conditions such that there are no
long-term adverse impacts to wildlife, recreation, aesthetics, and economic values.

The remedy complies with applicable Vermont Wetlands Rules, 10 V.S.A.37. Vermont policy is to
protect significant wetlands and the values and functions that they serve in a manner such that
no net loss of significant wetlands and their function is achieved. Adverse impacts to wetlands
must be mitigated according to a hierarchy of avoidance, minimization, restoration, and
compensation or replacement. Wetlands on the Pine Street Site are Class 2.

In addition, the design of the cap will take include efforts to avoid and limit adverse effects
on wetlands and on the beneficial values of the floodplain, consistent with Executive Orders
11988 and 11990. Construction of the weir will comply with Vermont dam reguirements at 10
V.S.A.43.

3. Historic Preservation ARARs

The selected remedy provides for capping of Subareas 1, 2 and 8, where potentially historically
significant structures, including five sunken barges and a marine railway will be covered. Under
the federal and state historic preservation statutes, EPA must take into account the effects of
the remedy on these potentially historic structures. The Vermont Historic Preservation Law and
the federal National Historic Preservation Act (NHPA) are applicable laws which limit actions
that may affect historic properties or properties eligible for inclusion on the, National
Register of Historic Places. If an effect exists that would materially alter the characteristics
of the historic property, EPA in consultation with the State Historic Preservation Officer must
determine if the effect is adverse. An effect can be adverse if it causes destruction, damage or
alteration to the property; however, if a property has only archeological, historical or
architectural research values, the effect may not be adverse if such values can be preserved
through research and data recovery. If an adverse effect is found, consultation with the State
Historic Preservation Officer and the Advisory Council on Historic Preservation to seek ways to
avoid or minimize harm to the property.

NHPA and Vermont reguirements will be attained by conducting a full assessment of the historic
structures during remedial design and by consulting with the State Historic Preservation Officer
and appropriate federal authorities. If there is a possibility of an adverse effect on a
historic property, appropriate steps will be taken to minimize the harm, including mitigation
efforts such as additional research and documentation, recordation (such as photography), and/or
other data recovery.

4 . Hazardous Waste

Based on the chemical composition and concentrations, the coal the constituents of the
manufactured gas plant wastes are similar to listed RCRA hazardous wastes, such as K087 wastes.
As part of the 1992 SRI, EPA conducted TCLP test of the on-site contaminants. Some, but not all,
samples of contaminated material failed the TCLP test for benzene. Accordingly, portions of
federal RCRA regulations and the current State of Vermont Hazardous Waste Regulations, 10 V.S.A.

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ch. 159, may be relevant and appropriate to this remedy. In those limited instances where these
regulations may conflict, the more stringent regulation will be followed.

Basic RCRA facility reguirements are relevant and appropriate during the construction period of
the remedy. These include appropriate portions of 40 CFR Part 264, Subparts B,C,D,F and G. The
deed restriction provisions at 40 CFR 264.116 and 264.119 (b) (1) will be considered, as
appropriate, in fashioning the institutional controls for the site.

Land disposal regulations at 40 CFR Part 268 are not ARARs. As noted in Section X, the remedy
will likely not involve placement or disposal of contaminated materials, but rather the
application of clean fill over contaminated sediments. If some excavation of contaminated
sediments before placement of the cap is necessary to maintain the proper elevations and
hydrology for ultimate wetlands restoration, such excavated materials will be placed in the
turning basin, which is within the same area of contamination. Such in-situ consolidation and
capping within an existing area of contamination does not implicate RCRA land disposal
regulations.

In addition, the subagueous cap and the cap in Subareas 3 and 7, which are intended to provide a
clean substrate and to isolate contaminants from ecological receptors (rather than to protect
groundwater by providing an impermeable barrier to prevent wastes from leaching), are not
subject to the landfill cap reguirements set out at 40 CFR Subpart N.

5. Air Pollution Control

Vermont air pollution control regulations at 10 V.S.A. ch. 48 and ambient air guality standards
for particulates are ARARs and will be attained during construction period of the remedial
action. These air guality regulations will be considered during the remedial design for the
excavation/cap placement portions of the remedy. Necessary steps will be taken to control dust
during implementation of the remedy.

C. The Selected Remedial Action is Cost Effective

In the Agency's judgment, the selected remedy is cost effective, i.e., the remedy affords overall
effectiveness proportional to its costs. In selecting this remedy, once EPA identified alternatives
that are protective of human health and the environment and that attain, or, as appropriate, waive
ARARs, EPA evaluated the overall effectiveness of each alternative by assessing the relevant three
criteria—long-term effectiveness and permanence; reduction in toxicity, mobility, and volume through
treatment; and short-term effectiveness, in combination. The relationship of the overall effectiveness
of this remedial alternative was determined to be proportional to its costs.

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

Estimated Capital Cost: $2,543,762
Estimated Annual Operation and Maintenance (O&M) Cost: $147,895
Estimated Total O&M over 30 Years (net present worth): $1,835,235
Estimated Total Cost of the Remedy (net present worth): $4,378,997

For comparison, the estimated total costs for the only other alternative (3b) that meets the threshold
criteria for protection of human health and the environment and compliance with ARARs are:

Estimated Capital Cost: $39,477,672
Estimated Annual Operation and Maintenance (O&M) Cost: $119,895
Estimated Total O&M over 30 Years (net present value): $1,487,782
Estimated Total Cost of the Remedy (net present value): $40,965,454

The selected remedy (Alternative 3a) is the less expensive of the two alternatives that meet the
threshold criteria.

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

Once the Agency identified those alternatives that attain or, as appropriate, waive ARARs and that are
protective of human health and the environment, EPA identified which alternative utilizes permanent
solutions and alternative treatment technologies or 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.

The selected remedy provides long-term effectiveness through capping, institutional controls on
groundwater use as drinking water, land-use restrictions to prevent future uses that could result in
unacceptable risk to human health and the environment, and long-term performance monitoring.

E. The Selected Remedy Does Not Satisfy the Preference for Treatment That Permanently and

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Significantly reduces the Toxicity, Mobility or Volume of the Hazardous Substances as a
Principal Element

The selected remedy does not satisfy the preference for treatment that permanently and significantly
reduces the toxicity, mobility or volume of hazardous substances. The remedy proposed in 1992 which did
satisfy this preference was withdrawn, because of concerns over implementability, short term health
impacts, cost and community and state opposition. The remedy selected in this Record of Decision was
recommended by the Pine Street Barge Canal Coordinating Council after a thorough re-evaluation of
issues raised by the public in 1992-1993. Although the selected remedy does notutilize treatment, it
does reduce the mobility of the hazardous substances through containment.

XII. DOCUMENTATION OF SIGNIFICANT CHANGES

The selected remedy in this Record of Decision is generally consistent with the Proposed Plan for
remediation of the Site, issued on May 29, 1998. The preferred alternative included:

• Capping contaminated sediments in canal Subareas 1, 2, 3, 7, and 8;
• Institutional controls for groundwater below the Site;
• Institutional controls for land-use development;
• Site boundary definition;
• Long-term performance monitoring; and,
• Five-year reviews.

XIII. STATE ROLE

The Vermont Department of Environmental Conservation has reviewed the various alternatives and has
indicated its support for the selected remedy. The State has also reviewed the draft Remedial
Investigation, the Supplemental Remedial Investigation, the Additional Remedial Investigation, the
Baseline Human Health Risk Assessment, the Supplemental Baseline Ecological Risk Assessment, and the
Additional Feasibility Study to determine if the selected remedy is in compliance with applicable or
relevant and appropriate State environmental laws and regulations. The State of Vermont concurs with
the selected remedy for the Pine Street Canal Superfund Site. A copy of the declaration of concurrence
is attached as Appendix C.

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                                       ACRONYMS and ABBREVIATIONS

1992 SRI      Supplemental Remedial  Investigation  (Metcalf  & Eddy,  Inc, March  1992)
1997 ARI      Additional Remedial  Investlaation (Johnson Company,  July  1997)
AFS           Additional Feasibility Study  (The Johnson Company,  May  1998)
ARAR(s)       Applicable or Relevant and Appropriate Requirement(s)
AWQC          ambient water quality  criteria
BTEX          aromatic hydrocarbons  (benzene,  toluene, ethylbenzene and xylene)
CDF           containment/disposal facility
CERCLA        Comprehensive Environmental Response, Compensation  and  Liability Act
COC(s)         contaminant(s)  of  concern
DEC           Vermont Department of  Environmental  Conservation
ER-L          effects ranqe-low
ER-M          effects ranqe-medium
EPA           United States Environmental Protection Aqency
FETAX         froq  embryo teratoqenesis assay  - Xenopus
LEL           lowest effects  levels
MCL           Maximum Contaminant  Level
mq/kq         milliqrams per  kiloqram
ml            milliliter
MGP           manufactured qas plant
MSL           mean  sea level
NAPL          non-aqueous phase  liquid
NCP           National Continqency Plan
NHPA          National Historic  Preservation Act
NOAA          National Oceanoqraphic and Atmospheric Administration
NPL           National Priorities  List
OMEE          Ontario Ministry of  Environment  and  Enerqy
PAH(s)         polycyclic aromatic  hydrocarbon(s)
PCB(s)         polychlorinated biphenyl(s)
ppb           parts per billion
ppm           parts per million
PRP(s)         Potentially Responsible Party(ies)
PSBCCC        Pine  Street Barsqe Canal  Coordinatinq Council
RCRA          Resource Conservation  and Recovery Act
RfD           reference dose
RI/FS         Remedial Investiqration/Feasibility  Study
ROD           Record of Decision
SEL           severe effects  level
SEM/AVS       Simultaneously  Extracted  Metals/Acid Volatile Sulfides
SBERA         Supplemental Baseline  Ecoloqical  Risk Assessment  (Weston, July 1997)
TCLP          toxicity characteristic leachate  procedure
VOC(s)         volatile orqanic compound(s)

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                                               REFERENCES

Jaagumagi,R. , D. Persaud, and D. Bedard. 1995. Ontario's Approach to Sediment Assessment and
Remediation. SETAC Second World Congress. 5-9 November 1996. Vancouver, British Columbia, Canada.

Johnson Company, The, 1997. Additional Remedial Investigation Report submitted to the US EPA. July,

Long, E.R., D.D. MacDonald, S.L. Smith and F.D. Calder. 1995. Incidence of adverse biological effects
within ranges of chemical concentrations in marine and estuarine sediment. Journal of Environmental
Management. Vol 19:81-97.

Metcalf & Eddy, Inc, 1992. Baseline Risk Assessment Final Report. Prepared for the US EPA. May.

Metcalf & Eddy, Inc, 1992a. Feasibility Study Report. Submitted to the US EPA. November.

Metcalf & Eddy, Inc, 1992b. Supplememal Remedial Itivestigatioti. Prepared for the US EPA. Mare.h.,g

Persaud, D., R. Jaagumagi, and A. Hayton. 1993. Guidelines for the Protection  and Management of
Aguatic Sediment Quality in Ontario, Ontario Ministry of the Environment and Energy. Queen's Printer
for Ontario. August.

Remediation Technologies  (RETEC), Inc, 1998. Additional Feasibility Study. Report submitted to the US
EPA. May.

US Environmental Protection Agency, 1990. Community Relations Plan. December.

US Environmental Protection Agency, 1992. Proposed Plan. November.

US Environmental Protection Agency, 1998. Proposed Plan. May.

Weston, Roy F.,1997. Supplemental Baseline Ecological Risk Assessment. Report prepared for US EPA.
July.

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                                               APPENDIX A

                                           FIGURES AND TAKLES

981300
98130D>
98130E>
98130F>
98130G>
98130H>

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                                   TABIiE 1
                CHEMICALS OF CONCERN FOR THE PINE STREET SITE
CHEMICAL NAME           GROUNDWATER
Vinyl Chloride               x
Methylene Chloride           x
Acetone                      x
Carbon Bisulfide
1,2-Dichloroethene
1,2-Dichloroethane           x
2-Hexanone                   x
Chloroform
Trichloroethene              x
Benzene                      x
Toluene                      x
Ethylbenzene                 x
Styrene                      x
Xylene

Naphthalene                  x
2-Methylnaphthalene          x
1-Methylnaphthalene          x
Acenaphthylene               x
Acenaphthene                 x
Fluorene                     x
Phenanthrene                 x
Anthracene                   x
Flouranthene                 x
Pyrene                       x
Benzo(a)anthracene           x
Chrysene                     x
Benzo(b)fluoranthene         x
Benzo(k)fluoranthene         x
Benzo(a)pyrene               x
Indeno(1,2,3-c,d)pyrene    x
Dibenz(a,h)anthracene        x
Benzo(g,h,i)perylene         x

2-Methylphenol
4-Chloroaniline
4-Nitrophenol
Dibenzofuran                 x
Bis(2-ethylhexyl)phthalate   x
                                              SOIL
                                                          SEDIMENT
Methoxychlor
Endosultan
Dieldrin
gamma-Chlordane

Antimony
Arsenic
Barium
Beryllium
Cadmium
ChromiumVI
Cobalt
Lead
Manganese
Mercury
Selenium
Silver
Vanadium
Zinc
                                                                        SURFACE
                                                                         WATER
Cyanide

-------
                                         Table 2

                 Summary of Ecological Contaminants of Concern in Sediment
             (Supplemental Baseline Risk Assessment Report, Weston, July 1997)
        Contaminant
            of
         Concern
Organics (PAHs)
  Acenaphthene
  Acenapthylene
  Anthracene
  Benzo(a)anthracene
  Benzo(b)fluoranthene
  Benzo(k)fluoranthene
  Benzo(a)pyrene
  Benzo(g,h,i)perylene
  Chrysene
  Dibenzo(a,h)anthracene
  Fluoranthene
  Fluorene
Inorganics
  Arsenic
  Cadmium
  Chromium
  Copper
  Lead
  Mercury
  Nickel
  Selenium
  Silver
  Thallium
  Vanadium
  Zinc
   Minimum
Concentration
   (mg/kg)

    0.14
    0.024
    0.08
    0.62
    0.71
    0.37
    0.44
    0.24
    0.98
    0.11
    0.6
    0.13
       1
   57.3
   79.6
    0.11
   16.6
    0.35
       1
    0.29
    9.3
     148
   Maximum
Concentration
    (mg/kg)

      180
       30
      160
      100
       35
       50
       72
       31
      100
      9.7
      220
      160

       26
     13.4
     1130
     1680
     1110
      4.3
     1330
     13. 6
     90. 6
     0.76
     71.8
     1300
Frequency
   of
Detection

   23/25
   23/25
   25/25
   25/25
   25/25
   25/25
   25/25
   25/25
   25/25
   17/25
   25/25
   23/25

   21/21
   21/21
   21/21
   21/21
   21/21
   18/21
   21/21
   15/21
   18/21
    3/21
   21/21
   21/21

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                                                           TABIiE 3

                             Summary of Process Option Descriptions as Applicable to Groundwater
Remedial Technology
    Category

 None
 Monitoring
 Access Restrictions
    Process Option
No Action
Ground Water Monitoring
Deed Restrictions
    Description
No remedial or response action
taken.

Monitoring of selected site wells
for contaminants of concern and
against established standards.

Deeds for properties in the site
area would include restrictions of
ground water use.

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Summary of Process Option Descriptions as Applicable to the Area of Focus
Remedial
Technology
Category
Process Option
Offsite Disposal Asphalt Batching
Molten Metal Technology

Landfill

Co-Firing at Utility Boiler
Description
Asphalt batching can be performed either as a cold-mix process or a hot-mix process. These two processes work guite
differently and are described below. The contaminants are physically and chemically bound in the cold mix asphalt. The
hot mix process removes the organic contaminants from the soil.

The cold-mix asphalt process mixes the soil (after being reprocessed to remove debris and oversized material) with a liguid
asphalt emulsion. The mixture is allowed to cure for several days prior to use. The contaminants are resistant to leaching
in this form.

The hot-mix asphalt process foods the contaminated soil into kiln with aggregate where the mixture is heated to
approximately 500! F at which temperature organic contaminants are volatilized. Liguid asphalt is mixed the soil and
aggregate to form asphalt. The off gases from the kiln are treated.

Molten Metal Technology uses a catalytic extraction process to reduce wastes to their component elements. The wastes are
placed into molten metal (temperatures between 2,400! F and 3,200! F) which cause the molecular bonds of waste
compounds to break. The molten metal sets as a solvent and catalysts. This technology does not have demonstrated full-
scale operations and no mobile units are available.

Contaminated material is excavated, tested and disposed of at an appropriate landfill facility.

The contaminated soil is blended with coal at concentrations between 1 and 5 percent and the mixture is burned in the power
generating boiler. The process was originally developed for soils which contained free product because of their high BTU
value, but the technology has been applied to soils with which contain light to moderate contamination. Co-firing would
reguire seperate contaminated soil storage facilities, material handling, and feed systems. Studies would need to be
conducted to determine the effects on the potential reduction in power generation, additional ash generation, ash handling
and disposal reguirements, potential effects on combustion performance, and air emissions.

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Summary of Process Option Descriptions as Applicable to the Area of Focus
Remedial
Techonology
Category

Thermal Treatment
Process Option
In
Situ Vitrification
Radio Frequency
Heating
Incineration
Solidification/
Stabilization
Description
Infrared thermal desorption is similar to other thermal desorption processes except that it uses infrared heating rods to
heat the contaminated material to seperate the contaminants. The volatilized contaminants are collected for further onsite
or offsite treatment. The infrared thermal desorption process is marketed by Westinghouse Remediation Services, Inc., and
the advantages are better control over temperature, and the minimization of fines carryover.
The soil is placed in an incinerator which volatilizes and combusts the organic contaminants. Costs for incineration are
generally fairly high in comparison with other remedial technologies. The incineration process must be carefully monitored
to prevent the creation of more toxic compounds. Some of the metals detected in the sediments may become volatile during
incineration and further complicate the process.

Soil venting is the removal of organic compounds by induced air flow. Vacuum extraction, air stripping, soil sparging,
and soil vapor extraction all fall under the category of soil venting. Soil venting works well on volatile compounds in
hydraulically conductive soils above the water table. Soil venting is often used in conjunction with bioremediation as a
method of adding oxygen to the soil to enhance microbial activity.

-------
Summary of Process Option Descriptions as Applicable to the Area of Focus
Remedial
Techonology
Category
Process Option

IWT Fixation

Soil Washing
Description
Typical ex situ soil washing processes separate the fine grained materials from the coarse grained particles. Contaminants
are removed from the coarse grained particles and fine grained particles are collected for additional treatment. This type
of soil washing is a volume reduction process. Soils with high humic content, such as those found at the site, inhibit the
desorption of contaminants. Due to the limited volume of coarse grained material expected in the Area of Focus, this
technology would not result in a significant volume reduction.
Contaminants are extracted from the soil by dissolving them in a solvent. Multiple extractions may be required to decrease
contaminants to the required concentrations. To effectively dissolve the contaminants, the solvent must penetrate the soil
matrix, which is difficult in low permeability soils. High water contents, which would be expected from soils excavated
from the site, would inhibit the performance of solvent extraction.

Carver-Greenfield Process The Carver-Greenfield process is a solvent extraction process with moisture removal pretreatment. The pretreatment also
serves to break any emulsions which are present. The lower water content of the solvent extraction feedstock allows the
process to operate more efficiently. The Carver-Greenfield process has been used in a pilot-scale basis to treat drilling
fluids, and full-scale in industrial applications to treat various sludges.

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Summary of Process Option Descriptions as Applicable to the Area of Focus
Remedial
Technology
Category
Biological
Treatment
Process Option
Description
Limmofix Inc.
Land Farming/Composting
In Situ Slurry Bioreactor
Horizontal
Barriers
Land farming/composting is the ex situ biological treatment of soils or sediment, often under controlled conditions. This
technology can treat organic contaminants (VOCs and PAHs) and conventional pollutants (BOB, COD, and TOG) . The
control measures provide favorable conditions for the bacteria to grow and may include oxygen enhancement, temperature
control, moisture adj ustment, pH adjustment and nutrient control. Biological treatment is limited by the bioavailability of
contaminants. Full-scale remediation his been conducted at sites which were contaminated by coal-tar distillation,
petroleum refining and petroleum storage industries.

A bioslurry reactor is a type of bioremediation where contaminated soils and sediments are mixed with water to create a
slurry. The slurry is placed in a bioreactor (large tank) where the environment is controlled to create favorable conditions
for microbial activity and nutrients are added. The slurry is constantly agitated to maximize contact between contaminants,
microorganisms and nutrients. As a result of the controlled conditions, biodegradation occurs more rapidly.

In Situ slurry bioremediation is similar to the bioslurry reactor except it is performed in situ. An area of the canal would
be isolated with and dewatered to remove any free liquids. The sediments which remain in the enclosed area would be in
a slurry form. Nutrients would be mixed with the sediments to provide favorable biological conditions. In Situ dewatering
of sediments would be required to achieve required solids content.

A geomembrane cap is constructed of a polymer liner (typically HDPE or LDPE) with layers of sand to protect the liner
from punctures. The polymer liner has a low permeability to limit contaminant migration through the cap and limit direct
contaminant contact. Installation of the geomembrane cap below the water table may result in sediments being displaced
to the top of the membrane. Vertical gradients would need to be investigated to determine uplift pressures on the cap.

A non-compactod soil cap consists of low permeability soil (bentonite) cap constructed underwater. The clay is placed on
top of the sediments and hydrates when in contact with water, increasing in size and reducing voids spaces in an attempt
to form a continuous layer. The non-compacted soil cap would be difficult to construct, is likely to contain voids despite
the hydration, and be discontinous in coverage. It is likely that significant mixing between the clay and sediments would
occur.

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                                                                                      Summary  of Process Option Descriptions as  Applicable to  the Area  or Focus
 Remedial
Technology
 Category
                       Process Option
                    Bentonite Mat
                                                                        Description
                    Soil  Bentonite Slurry Wall

                    Cement Bentonite Slurry
                    Wall

                    Concrete Diaphragm Wall

                    Vertical Membrane
                                                A high  density polyethylene  (HDPE)  membrane vibrated in place or inserted  with slurry trench  techniques.  HDPE
                                                panels  are joined with  interlocking joints.

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                                                                                       Summary  of Process Option Descriptions  as Applicable  to Upland and Wetland Areas
    Remedial            Process Option                                   Description
   Technology
   Category

Offsite Disposal      Asphalt  Batching
                     Land  Filling

                     Co-Firing  at Utility Boiler    The contaminated soil is  blended  with  coal at concentrations between 1 and 5 percent and the  mixture  is burned in the power
                                                   generating boiler.  The process  was  originally developed for soils which contained free product  because of their high BTU
                                                   value, but the technology has been  applied to soils with which contain light to moderate contamination. Co-firing would
                                                   require separate contaminated soil  storage facilities, material handling,  and feed systems. Studies would need to be
                                                   conducted to determine the effects  on  the potential reduction in power generation,  additional ash  generation, ash handling
                                                   and disposal requirements,  potential effects on combustion performance, and air emissions.  Several test burns have been
                                                   conducted and soil  from two MGP sites  have been remediated in this method.

Thermal              Infrared Desorption            Infrared thermal desorption is  similar to other thermal desorption processes except that it uses infrared heating rods to
Treatment                                          heat the contaminated material  to separate volatile contaminants.  The volatilized contaminants  are collected for further
                                                   onsite or offsite treatment. The  infrared thermal desorption process is marketed by Westinghouse Remediation Services,
                                                   Inc., and the advantages  are better control over temperature, and minimization of fines carryover.
                     In  Situ  Vitrification          High voltage electricity is  transmitted  through the contaminated soil. Heat generated by the  resistance of the soil to the
                                                   flow of electricity elevates the  temperature past the melting point of soil.  The result  of  the  process is a glass-like
                                                   material which is resistant  to  leaching. Off-gases created by the process are treated. A large  source of electricity would
                                                   be required. The vitrified material would need to be disposed of (may contain metals).

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Summary of Process Option Descriptions as Applicable to Upland and Wetland Areas
Remedial
Technology
Category
Process Option
In Situ Soil Venting
Description
The soil is placed in an incinerator which volatilizes and combusts the organic contaminants. Costs for incineration are
generally fairly high in comparison with other remedial technologies. The incineration process must be carefully monitored
to prevent the creation of more toxic compounds. Some of the metals detected in the sediments may become volatile during
incineration and further complicate the process.

Soil venting is the removal of organic compounds by induced air flow. Vacuum extraction, air stripping and soil vapor
extraction all fall under the category of soil venting. Soil venting works well on volatile compounds in hydraulically
conductive soils above the water table. Soil venting is often used in conjunction with bioremediation as a method of adding
oxygen to the soil to enhance microbial activity.

Solidification/stabilization (SS) consists of mixing the contaminated media with Portland cement and/or other admixtures
either in situ or ex situ. The resulting solid mass generally has a lower permeability and chemically binds the contaminants
to reduce their mobility. For shallow applications, it is likely that mixing would occur with rototiller-like equipment
mounted on the boom of an excavator. For ex situ applications, a pugmill is typically used. This technology has been
applied to an MGP site. Bench-scale tests conducted for the FS on samples of peat, fill and sediment indicated that
solidification treatment could potentially result in some reduction in leachability of PAHs and BTEX as measured by TCLP
extraction tests.
IWT Fixation
Soil Washing removes contamination from soils and sediments by using a combination of mechanical and chemical
processes. Chemical additives may include surfactants, pH adj ustments, and chelating agents. Soil washing can be
performed in situ or ex situ. Typical ex situ soil washing processes separate the fine grained materials from the coarse
grained particles. Contaminants are removed from the coarse grained particles and fine grained particles are collected for
additional treatment This type of soil washing is a volume reduction process. Soil washing can also be performed in situ
by injecting the washing solution below the ground, allowing it to flow through the contaminated material and pumping
it out again. Soil washing can be enhanced with the use of steam to increase contaminant removal efficiencies.

Contaminants are extracted from the soil by dissolving them in a solvent. The contaminants are removed from the solvent
so that it may be reused. Multiple extractions may be required to decrease contaminants to the required concentrations.
To effectively dissolve the contaminants, the solvent must penetrate the soil matrix, which is difficult in low permeability
soils. Limited quantities make unit treatment costs very high. Not effective for treatment of metals.

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Summary of Process Option Descriptions as Applicable to Upland and Wetland Areas
Remedial
Technology
Category
Biological
Treatment
Horizontal Barriers
Process Option
Enhanced Bioremediation
Land Farming/
Composting
Bioslurry Reactor
Compacted Soil
Geomembrane Cap
Composite Cap
Bentonite Mat
Steel Barrier
Description
In Situ biological treatment uses existing microorganism to biodegrade contaminants. Ground water is pumped from the
contaminated aguifer, enhanced with nutrients to promote bacteria growth and reinjected upgradient. Use at MGP sites has
been only partially successful due to the inability to distribute nutrients throughout the extent of contaminated media. Not
effective for treatment of metals.

Composting is the ex situ biological treatment of soils or sediment, often under controlled conditions. This technology can
treat organic contaminants (VOCs and PAHs) and conventional pollutants (BOB, COD, and TOG). The control measures
provide favorable conditions for the bacteria to grow and may include oxygen enhancement, temperature control, moisture
adjustment, pH adjustment and nutrient control. Not effective for metals.

A bioslurry reactor is a type of bioremediation where contaminated soils and sediments are mixed with water to create a
slurry. The slurry is placed in a bioreactor (large tank) where the environment is controlled to create favorable conditions
for microbial activity and nutrients are added. The slurry is constantly agitated to maximize contact between contaminants,
microorganism and nutrients. As a result of the controlled conditions, biodegradation occurs more rapidly.

A compacted soil cap consisting of low permeability soil would limit infiltration of water through contaminated soils and
reduce leaching potential. A compacted soil cap would provide a limited barrier to burrowing animals contacting
contaminated soil. Once holes are burrowed through the cap, its effectiveness at reducing surface water infiltration and
providing a barrier to contaminated soil is reduced.

A geomembrane cap is constructed of a polymer liner (typically HDPE or LDPE)with layers of sand to protect the liner
from punctures. The polymer liner has a low permeability to limit infiltration of water through the contaminated soils to
reduce leaching and may provide a limited barrier to discourage animal burrowing.

A composite cap is a combination of a compacted soil cap and a geomembrane cap. The composite cap consists of
compacted low permeability soil with a polymer liner. This system has redundancy built into the design. This cap does
not provide any additional benefit to prevent burrowing animals from contacting contaminated soils but has higher cost.

A bentonite mat is a polymer liner with a layer of bentonite attached to one side of the liner. The bentonite mat is installed
with protective layers of sand on either side.

A layer of chain-link fencing or similar barrier would be placed in conjunction with a capping process option. The steel
barrier would inhibit burrowing animals from contacting soil contaminants.

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                                                                                                                      TABIiE 4

                                                                                                      Ranking for the Criteria of the NCP
                                                                          Threshold Criteria
                                                                                                                                                                     Balancing Criteria
Alt. Number
No Action

     1:
                           Description
Overall Protection
  of Human Health
      and the
    Environment
Compliance with
    ARARs
Long-Term Effectiveness and
        Permanence
 Short-Term
Effectiveness
Reduction of Toxicity,
   Mobility, £ Volume
  Through Treatment
Implementability
                                                                                                                                                                                                                                     Cost
Monitoring and Institutional Controls Only
                  Institutional Controls, Groundwater and
                  Uplands/Wetlands; No Action, Subareas 1, 2, 4
                  and 8; Monitoring
                  Institutional Controls, Groundwater and Uplands/
                  Wetlands; No Action, Subareas 1, 2,7, and 8;
                  Capping, Subarea 3; Monitoring
                                                                                          Partial 2
                                                                                          Partial 2
                  Institutional Controls, Groundwater and Uplands/
                  Wetlands; No Action Subareas 3 and 7; Excavation
                  and Off Site Treatment/Disposal, Subareas 1, 2,
                  and 8; Monitoring; Dewatering
                                                                                          Partial 3
                                                 (Slightly greater permanence due
                                                 to removal of Subareas 1,  2, and
                                                 8 materials over alternative 2d,
                                                       capping these areas)
                  Institutional Controls, Groundwater and Uplands/
                  Wetlands; Capping, Subareas 3 and 7: Excavation
                  and Off Site Treatment/Disposal, Subareas 1, 2,
                  and 8; Monitoring; Dewatering
                                                                                          Partial 3
                                                               1
                                                   (Largest volume of potentially
                                                  contaminated material removed,
                                                 remaining ecological risk capped)
                                                                                                                                                                                      1 4
                                                                                          Partial 2
                                                                                                               (All areas that are not subject
                                                                                                                 to recontamination from
                                                                                                                    stormwater capped)
                                                                                                                                                                                      4 4
All areas potentially exceeding sediment quality criteria will continue to be exposed: Wetlands regulations regarding the mitigation of past wetlands impacts would not be met.
Some areas potentially exceeding sediment quality criteria will continue to be exposed: Wetlands regulations regarding the mitigation of past wetlands impacts would not be met.
Most areas potentially exceeding sediment quality criteria will be capped or in-filled thereby meeting the TBC sediment criteria; however, excavation of Subareas 1,2, and 8 will cause more destruction to wetlands than other available
alternatives, therefore this alternative does not comply with Section 404 of the CWA.  These alternatives obtain a reduction in the toxicity and mobility through containment.

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                                                                                                         TABIiE 5

                                                                              Remedial Action Objection and Goals By Area/Media of Interest
Ecological
 Al ternatives
  Which Meet
    RAO/G:
    Alternatives
 Which Do Not Meet
       RAO/G:
                                                                                                                                                                             RAO/G Does
                                                                                                                                                                              Not Apply
                                                                                                                                                                                 To:
1    In areas where risks are unacceptable, including Subareas 1, 2, 3, 7, and 8, eliminate
     direct exposure of ecological receptors to contaminated soils and sediments, or reduce
     exposure to levels presenting an acceptable risk.

2    In areas identified in Paragraph 1 above, where it is not feasible to eliminate direct
     exposure to contaminated soils and sediments or reduce exposure to levels presenting
     an acceptable risk, reduce direct exposures of ecological receptors to contaminants of
     concern to the extent feasible.

3    Prevent or minimize the long-term adverse effects of remediation activities on the
     existing aguatic environment and/or wetland habitat.

4    Restore wetlands affected by remediation.


Human Health

1    Absent an appropriate risk assessment which has been approved by EPA, prevent
     unacceptable exposure (direct contact, ingestion, and inhalation) to contaminated soils
     located greater than five feet below grade.

2    Prevent ingestion and exposures associated with residential use  (direct contact,
     ingestion, and inhalation)  to contaminated groundwater where contaminated
     groundwater presents unacceptable risks, including Class IV areas.

3    Prevent exposures associated with residential use (direct contact, ingestion and
     inhalation)  to contaminated soils, sediments, air and surface water at the site.

Management of Migration

1    Protect Lake Champlain from being impacted by contaminants left on site.

     A Ensure Lake Champlain is not impacted by a significant increase in mass flux of
       contaminants through groundwater migration.
    3a,  3b
    3a,  3b
  2b,  2c,  2d,
  3a,  3b,  3c

  2b,  2c,  2d,
  3a,  3b,  3c
2a,  2b,  2c,  2d,
  3a,  3b,  3c
2a,  2b,  2c,  2d,
  3a,  3b,  3c
 1,  2A,  2b (partial),
   2c (partial),  2d
(partial), 3c (partial)

1,  2a,  2b (partial) ,
   2c (partial),  2d
(partial), 3c (partial)
                                     All 1
                                   1,  2a
                                   1,  2a
     All
      1 Site is currently zoned for industrial/commercial use only.

-------
Remedial Action Objection and Goals By Area/Media of Interest
Management of Migration (continued)

B Ensure Lake Champlain is not impacted by a significant increase in mass flux of
contaminants through contaminated sediment migration.

C Prevent changes in hydrogeologic conditions that will likely cause migration of
contaminated groundwater to Lake Champlain in concentrations that exceed a
stands to be developed.

2 Protect areas not targeted for remediation (both on and off site) by preventing
significant migration of contamination from on-site sources.

A Ensure that contaminated groundwater with concentration levels above drinking water
standards does not migrate beyond the Class IV classification boundary.

B Ensure that contaminated on-site sediments are not significantly mobilized.

C Ensure that NAPL is not significantly mobilized.

D Prevent degradation of surface water to levels above ambient water guality criteria.

E Prevent degradation of local (urban) background air guality.

3 Protect remediated areas on the site from becoming recontaminated from on-site and
known off-site sources.

A Ensure that hazardous substances left in place do not mobilize or create unacceptable
risk to ecological receptors and humans in remediated areas.

B Monitor to provide the necessary data to determine if non-CERCLA substances are
mobilizing or creating unacceptable risks.

C Monitor to provide the necessary data to determine whether stormwater and non-
contact cooling water may be creating an unacceptable risk to ecological receptors and
humans in remediated areas.

4 Site Uses

A Ensure to the extent practical that the remedy itself does not reduce the suitability of
the site for current and future uses, including a highway.

B Retain or expand current Class IV groundwater classification and boundary.

C Maintain or replace beneficial functions and values of wetlands.
Alternatives
Which Meet
RAO/G:

All
2a, 2b, 2c,
3a, 3c
All

All

1, 2a, 2b, 2c,
3a, 3c

All

2b, 2c, 3a, 3c
2b, 2c, 2d, 3a,
3b, 3c

All
2c, 2d, 3a
3b, 3c
All
2a, 2b, 2c, 2d
3a, 3b, 3c

2b, 2c, 2d, 3a,
3b, 3c
Al ternatives
Which Do Not Meet
RAO/G:
2d(potentially) ,
3b (potentially)
RAO/G Does
Not Apply
To:
2d(potentially) ,
3b (potentially)
2d(potentially)
3b (potentially)
l,2a
l,2a
, 2a, 2b
1, 2a

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                                                                                                                    APPENDIX B

                                                                                             APPLICABLE OR  RELEVANT AND APPROPRIATE  REQUIREMENTS
                                                                                                                      (ARARS)
                                                                               ARARs  Specific  to Remedial Alternative  3a:  Capping Subareas 1,  2,  3, 7  and 8
REQUIREMENTS/
  CRITERIA
                                                      DESCRIPTION
                                                                                            EVALUATION
                                                                                             DECISION
                                                                                                                                                                            ACTION TO BE TAKEN TO ATTAIN ARAR
                                                                                                              Chemi cal-Speci fie
Draft Sediment Quality
Criteria

Ontario Ministry of the
Environment and Energy
(OMEE)  Sediment Quality
Guidelines
Clean Water Act (CWA)
    Ambient Water Quality
    Criteria Guidelines.
    40 CFR Part 131
Guidelines derived specifically for freshwater sediments that define three
levels of chronic effects on benthic organisms:  no-effect level;  lowest-
effect level (LEL)  which indicates level of sediment contamination that can
be tolerated by most benthic organisms;  severe-effects level (SEL)  level
at which pronounced disturbances or sediment-dwelling organisms will
occur for a majority of the benthic species.

Used to identify concentration levels associated with deleterious effects on
estuarine and marine species and environments Based on a database
complied from 89 publications lowest (ER-L)  and median (ER-M)  effects
ranges (corresponding to 10th and 50th percentiles, respectively)  of
observed biological effects were developed.
                                                                                                                                       TBC
                                                                                              TBC
                                                                                                                                       TBC
                                                                                                                                       TBC
                          Capping sediment areas that currently exceed these criteria will
                          attain compliance with the guidance criteria.  Alternative 3a.
                          capping all subareas with ecological concern,  will address this
                          ARAR most completely.
                                                                                                                                                                 Capping  sediment  areas that currently exceed these criteria will
                                                                                                                                                                 attain compliance with the guidance criteria. Alternative 3a.
                                                                                                                                                                 capping  all  subareas with ecological concern, will address this
                                                                                                                                                                 ARAR most  completely
                                                                                                              Location-Specific
Resource Conservation and
Recovery Act (RCRA)
    Hazardous Waste
    Facility Located on
    100-year Floodplain,
    40 CFR 264.18 (b)

Executive Order 11988
    Floodplains
    Management,
    40 CFR 6, Subpart A
Facility must be designed and operated to avoid washout.
                          Substantiative portions of this requirement will be considered
                          during design or the capped areas to minimize wash out
                          effects from flood events.
                                                                                                                        Substantiative  portions  or  this  requirement will be  considered
                                                                                                                        during  design of  the  capped areas minimize wash out
                                                                                                                        effects from flood  events
Executive Order 11990
    Protection of Wetlands,
    40 CFR 6, Subpart A
Actions by federal agencies taking place within wetlands must be
planned to limit adverse impacts.
Applicable
All remedial actions will be designed to minimize wetlands
areas to be impacted during implementation of the remedy and
all remediated areas will have wetlands restoration activities.

-------
                                                                        ARARs Specific to Remedial Alternative 3a: Capping Subareas 1,  2, 3,  7  and 8  (continued)
REQUIREMENTS/
  CRITERIA
                                                      DESCRIPTION
                                                                                            EVALUATION
                                                                                             DECISION
                                                                                                                                                                            ACTION TO BE TAKEN TO ATTAIN ARAR
Clean Water Act (CWA)
Section 404
    Dredge and Fill in
    Wetlands,
    40 CFR Part 230
National Historic
Preservation Act Regulations
    Preservation of Historic
    Properties Controlled
    by Federal Agency,
    36 CFR 800
Dredging or filling activities in wetlands;  are regulated.  Appropriate
and practicable steps must be taken to minimize the address impacts of
any discharges occurring as a result of the  selected remedial alternative.
No activity that adversely affects a wetland shall be permitted if a
practicable alternative with lesser effects  is available.
Actions by federal agencies must be planned to preserve historic
properties and minimize harm to National Historic Landmarks.  Statues
include requirements that actions must be taken to recover and preserve
artifacts, preserve historic properties and minimize harm to  National
Historic Landmarks
Substantive portions of this act will be met through the design
of these alternatives.  In particular, actions which minimize
impacts to non-remediation areas of the Site will be taken and
every effort will be made to prevent migration of either
contaminated sediments  or cap material during placement.
Steps to prevent this occurrence may include, but are not
limited to silt curtains, weirs, subaqueous cap placement, and
specialized placement techniques. Alternative 3a is the least
environmentally damaging practicable alternative. Restoration
and mitigation measures will be taken following placement of
the cap.

A full assessment or the status of the historical submerged
structures will be conducted prior to remedial design.
Appropriate steps to record and document the structures will
be conducted following  consultation with the state and prior to
construction or the cap.
Vermont Historic
Preservation Law, 22 VSA
Ch. 14, °° 743  (4)  and 767
Fish and Wildlife
Coordination Act
    Modification to
    Waterway that Affects
    Fish or Wildlife,
    50 CFR Part 297
                                                                                                                       A full assessment of the status of the historical submerged
                                                                                                                       structures will be  conducted prior to  remedial design.
                                                                                                                       Appropriate  steps to  record and document the structures will
                                                                                                                       be  conducted following  consultation with the state and prior to
                                                                                                                       construction or the cap.

                                                                                                                       A  full  assessment of  the  status of the historical submerged
                                                                                                                       structures will be  conducted prior to  remedial design.
                                                                                                                       Appropriate  steps to  record and document the structures will
                                                                                                                       be  conducted following  consultation with the state and prior to
                                                                                                                       construction of the cap.

                                                                                                                       The  requirements of this  Act will be considered during design
                                                                                                                       of  the  remedy. Consultation with U.S.  Fish and Wildlife
                                                                                                                       Service and  Vermont Fish  and Wildlife  Dept. is required.
                                                                                                                                                               The wetland functions and values will be restored by
                                                                                                                                                               implementation or these alternatives. Alternative 3a most
                                                                                                                                                               completely addresses this ARAR by restoration of all stressed
                                                                                                                                                               wetlands identified at the Site.

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                                                                        ARARs Specific to Remedial Alternative 3a: Capping Subareas 1,  2, 3, 7  and 8  (continued)
REQUIREMENTS/
  CRITERIA
                                            DESCRIPTION
                                                                                 EVALUATION
                                                                                  DECISION
                                                                                                                                                 ACTION TO BE TAKEN TO ATTAIN ARAR
                                                                                      Action-Specific
RCRA - Identification and
Listing of Hazardous Wastes
      40 CFR 261
RCRA - Treatment, Storage
and Disposal Facilities,
40 CFR Part 268
Resource Conservation and
Recovery Act
   Land Disposal Facility
   Notice in Deed
   40 CFR 264.116,
   264.119  (b)(1)
Regulations concerning land disposal of listed or characteristically
hazardous waste.
                                                                                potentially ARAR
                                                                                Potentially
                                                                                Relevant  and
                                                                                Appropriate
                                                                                                                                          In  1993, the Vermont Agency of Natural Resources designated
                                                                                                                                          most of the groundwater under the site as a Class IV
                                                                                                                                          groundwater, which is not suitable for potable use but suitable
                                                                                                                                          for some agricultural, industrial and commercial uses. Existing
                                                                                                                                          Class  IV designation establishes a measure of protection from
                                                                                                                                          consumption of groundwater exceeding federal drinking water
                                                                                                                                          standards  (MCLs). As a Class IV goundwater, appropriate
                                                                                                                                          management practices must be used to prevent violation of
                                                                                                                                          groundwater quality standards in adjacent Class III
                                                                                                                                          groundwaters.
If a contaminatated media exhibits the characteristic of a
hazardous waste, these regulations are applicable.  If a
contaminated media is sufficiently similar to listed RCRA
hazardous wastes, these regulations are potentially relevant and
appropriate.

No RCRA hazardous wastes would be generated under this
alternative.  In Situ capping activities will involve consolidation
 of  materials within  an  area of existing contamination, which does
not implicate RCRA standards [55  Fed.  Reg. 8666,  8760 (March
8, 1990)] .

Purpose of deed restrictions or other institutional controls for
these alternatives is sufficiently similar to the purpose of
RCRA deed notations to consider the RCRA restriction
language.
Resource Conservation and
Recovery Act
   General Facility Stan-
   dards and Security
   40 CFR 264 Subpart B

RCRA
   Preparedness and
   Prevention.
   40 CFR 264
   Subpart C
                                                                                Potentially
                                                                                Relevant  and
                                                                                Appropriate
Criteria will be considered during Remedial Design/Remedial
Action phases.

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                                                                        ARARs Specific to Remedial Alternative 3a: Capping Subareas 1,  2, 3,  7  and 8  (continued)
REQUIREMENTS/
  CRITERIA
                                             DESCRIPTION
                                                                                        EVALUATION
                                                                                         DECISION
                                                                                                                                                   ACTION TO BE TAKEN TO ATTAIN ARAR
Releases from Solid Waste
Management Units,
40 CFR 264 Subpart F
Vermont Hazardous Waste
Management Regulations,
10 VSA Ch. 159
Regulations pertaining to hazardous waste facilities requiring monitoring
and corrective action for units that manage solid waste.
 Potentially
 Relevant  and
Appropriate

 Potentially
 Relevant  and
Appropriate

 Potentially
 Relevant  and
Appropriate

 Potentially ARAR
These standards will be considered during the Remedial
Desing/Remedial Action Phases.
                                                                                                         If  a  contaminatated media  exhibits the  characteristic of a
                                                                                                         hazardous waste,  these  regulations are  applicable. If a
                                                                                                         contaminated  media is sufficiently similar to hazardous wastes
                                                                                                         regulated by  the  State  of  Vermont, these regulations are relevant
                                                                                                         and appropriate.  The requirements for storing hazardous wastes
                                                                                                         and designing,  sonstructing  and operation hazardous waste
                                                                                                         facilities will be considered during remedial design and remedial
                                                                                                         action.
Vermont Water Quality
Standards, 10 VSA Ch. 47,
EPR Ch. 1, and Vermont
NPDES Permit Program
Regulations, 10 VSA Ch.  4"

Vermont Air Pollution
Control Regulations,
10 VSA Ch. 23 ° 554
                              Establishes policy to protect and enhance the quality,  character and
                              usefulness of source water and to assure the public health;  control  the
                              discharge of wastes to the waters of the state,  prevent degradation  of high
                              quality waters and prevent, abate,  or control all  activities harmful to
                              water quality.
                                                                                Applicable
Lists hazardous contaminants and sets Hazard Limiting Values  and action
Limits for numerous compounds.  Identifies source registration and
pollution control requirements.

Establishes maximum 24-hour concentrations and annual geometric mean
ambient air quality standards for parliculate matter.
                                                                                                              Relevant  and
                                                                                                              Appropriate
                         These  criteria will be considered during design of cap placement
                         techniques.
                                                                                                         Surface water  quality presently meets Ambient Water Quality
                                                                                                         Criteria  (AWQC). However,  these standards will be
                                                                                                         considered  during  design  and  construction of the cap.
                         These  standards will be considered during design of cap
                         placement techniques.
                              Limits stormwater runoff off the Site.

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                                                                       ARARs Specific to Remedial Alternative 3a: Capping Subareas 1,  2,  3, 7 and 8  (continued)
REQUIREMENTS/
  CRITERIA
                                       DESCRIPTION
EVALUATION
DECISION
                                                                                                                                          ACTION TO BE TAKEN TO ATTAIN ARAR
                              Procedures  to  identify and protect significant wetlands and the values
                              and functions  which they serve in such a manner that the goal of no net
                              loss  of  such wetlands and their functions is achieved.
Applicable
                              This  law governs  all dams that are constructed in the State impounding
                              more  than 500,000  cubic  feet of water and sediment, except those dams
                              relating to  the generation of electrical power for public use.
                      If design calculations indicate that the volume  of  impounded
                      water may exceed 500,000 cubic feet, these rugulations would
                      apply to the design of the weir.  The requirements of  this  law
                      include; 1)  proper notification of state and local  offices; 2)
                      preparation of plans and specification for the project by  an
                      engineer; 3) determination of public good; and 4) oversight of
                      the construction of the project by an engineer.

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                                               APPENDIX C

                              STATE OF VERMONT DECLARATION OF CONCURRENCE






                                          September 16, 1998


Mary Jane O'Donnell Chief, ME/VT/CT Superfund Section
Office of Site Remediation and Restoration
U.S. Environmental Protection Agency,  Region 1
J.F. Kennedy Federal Building
Boston, Massachusetts 02203-0001

Re: Concurrence With The Pine Street Canal Record of Decision

Dear Mary Jane:

       This  letter will  confirm our concurrence in the  Pine  Street  Canal  Superfund Site  Record of
Decision (ROD) by the State of Vermont. Concurrence is based in large part from input by members of my
staff who have reviewed the Record of Decision Final Draft provided to them by the EPA Regional Project
Manager for the Pine Street Site. They have reported to me that the ROD comprehensively and accurately
addresses the chain of events and deliverables leading up to the selection of the site remedy.

       The  state  believes  that the selected remedy is  protective of human health and the environment,
meets all state reguirements that are applicable to the remedial action and is cost effective. We look
forward to working with EPA during the remedial design and remedial action phases of the Pine Street
Canal Superfund Site remedy.

       I  would like to take the opportunity to commend  you and your staff on a job well  done  in the
development of technically sound and acceptable remedy for the site. The formation of the Pine Street
Coordinating Council with local, municipal and regulatory representation was very effective in arriving
at a remedial solution that everyone can support.





cc: George Desch
    Stanley Corneille

              Regional Offices - Barre/Essex Jct/Pittsford'Rutland'N Springfield S: Johnsbury

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APPENDIX D
ADMINISTRATIVE RECORD INDEX
ADMINISTRATIVE RECORD INDEX

for the

Pine Street Canal NPL Site

1. 0 Pre-Remedial Records

1.2 Preliminary Assessment

1. "Preliminary Site Assessment and Site Inspection," Ecology and Environment, Inc.
(June 23, 1982).

2.0 Removal Response

Although not expressly listed in this Index, all documents contained in the December 20, 1988
Removal Administrative Record are incorporated by reference herein, and are expressly made apart
of this Preliminary Administrative Record.

3.0 Remedial Investigation (RI)

3.1 Correspondence

1. Memorandum from Robert F. Ramey, City of Burlington to Ross L. Gilleland, EPA Region
I (March 18, 1991). Concerning the attached "Appendix A - Zoning" reguirement.

3.2 Sampling and Analysis Data

The Sampling and Analysis Data for the Draft and Supplemental Remedial Investigations (RI)
may be reviewed, by appointment only, at EPA Region I,
Boston, Massachusetts.

3.4 Interim Deliverables

EPA Region I

Appendix A and B for the record cited in entry number 1 may be reviewed, by appointment
only, at EPA Region I, Boston, Massachusetts.

1. "Ambient Air Toxics Sampling and Analysis Results," EPA Region I
(November 1990).

Metcalf & Eddy, Inc.

2. "Chemical Quality Assurance Project Plan for Biological Studies," Metcalf & Eddy,
Inc. (June 1990).
3. "Final Health and Safety Plan for Supplemental Remedial Investigation/Feasibility
Study," Metcalf & Eddy, Inc. (September 1990).
4. "Final Quality Assurance Project Plan for Supplemental Remedial
Investigation/Feasibility Study," Metcalf & Eddy, Inc. (October 1990).
5. "Final Field Sampling Plan for Supplemental Remedial Investigation/Feasibility
Study," Metcalf & Eddy, Inc. (October 1990).

Peer Consultants

6. "Field Operations Plan for Pine Street Canal Site Remedial Investigation/Feasibility
Study," Peer Consultants (March 20, 1989).
7. "Quality Assurance Project Plan for Pine Street Canal Site Remedial
Investigation/Feasibility Study," Peer Consultants (March 20, 1989).
8. "Summary of Biological Survey Activities," Peer Consultants (September 1989).

3.5 Applicable or Relevant and Appropriate Reguirements (ARARs)

1. Letter from Robert B. Finucane, State of Vermont Agency of Natural Resources to Mary
Jane O'Donnell, EPA Region I (March 2, 1992). Concerning Vermont's regulatory
reguirements.

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       3.6    Remedial Investigation  (RI) Reports

             1.   "Draft Remedial Investigation Report - Volume IA," Peer Consultants  (May 1990).
             2.   "Draft Remedial Investigation Report - Volume IB," Peer Consultants  (May 1990).
             3.   "Draft Remedial Investigation Report - Volume III," Peer Consultants  (May 1990).
             4.   "Draft Remedial Investigation Report - Volume IV," Peer Consultants  (May 1990).
             5.   "Supplemental Remedial Investigation Final Report - Volume I," Metcalf & Eddy, Inc.
                  (March 1992).
             6.   "Supplemental Remedial Investigation Final Report - Volume II," Metcalf & Eddy, Inc.
                  (March 1992).
             7.   "Supplemental Remedial Investigation Final Report - Volume III," Metcalf & Eddy, Inc.
                  (March 1992).

       3.7    Work Plans and Progress Reports

             1.   "Draft Work  Plan for the Remedial Investigation/Feasibility Study," Perkins Jordan,
                  Inc.  (1986).
             2.   "Work Plan Volume  I - Technical - for Remedial Investigation/Feasibility Study," Peer
                  Consultants  (March 20, 1989).
             3.   "Draft Amendment for Work Plan Volume I - Technical for Remedial
                  Investigation/Feasibility Study, " Peer Consultants  (October 3, 1989) .
             4.   "Work Plan for Remedial Investigation/Feasibility Study Activities,"  (05-1L19)
                  Metcalf & Eddy, Inc.  (November 1989).
             5.   "Final Work  Plan for Biological Studies,"  (03-1L19) Metcalf & Eddy, Inc. (January
                  1990).
             6.   "Final Work  Plan for Supplemental Remedial Investigation/Feasibility Study,"
                  (10-1L19) Metcalf  & Eddy, Inc.  (August 1990).
             7.   "Ambient Air Toxics Sampling and Analysis Work Plan," EPA Region I  (August 1990) .

       3.9    Health Assessments

             1.   Memorandum from Susanne Simon, Department of Health & Human Services Centers for
                  Disease Control to Ross L. Gilleland, EPA Region I  (October 15, 1991). Concerning the
                  health consultation on the Jackson Terrace Apartments property.

4.0    Feasibility Study (FS)

       4.4    Interim Deliverables

             Reports

             1.   "Final Health and  Safety Plan for the Treatability Study," Metcalf  & Eddy,  Inc.
                  (September 1990).
             2.   "Treatability Study Quality Assurance Project Plan," Metcalf & Eddy, Inc.  (October
                  1990).
             3.   "Treatability Study - Final Report - Volume  I," Metcalf & Eddy, Inc.  (February 1992).
             4.   "Treatability Study - Final Report - Volume  II," Metcalf & Eddy, Inc.  (February
                  1992).

       4.7    Work Plans and Progress Reports

             1.   "Treatability Study Work Plan," Metcalf & Eddy, Inc.  (October 1990).

             Comments

             2.   Comments Dated January 11, 1991 from Groundwater Technology, Inc. for Nancy
                  Huelsberg, Green Mountain Power Corporation  on the October 1990 "Treatability Study
                  Work Plan," Metcalf & Eddy, Inc.
             3.   Comments Dated April 24, 1991 from Groundwater Technology, Inc. for Nancy Huelsberg,
                  Green Mountain Power Corporation on the October 1990 "Treatability  Study Work Plan,"
                  Metcalf & Eddy, Inc.

             Responses to Comments

             4.   Response Dated May 24, 1991 from Cinthia L. McLane, Metcalf & Eddy, Inc. to Comments
                  Dated January 11,  1991 from Groundwater Technology, Inc. for Nancy Huelsberg, Green
                  Mountain Power Corporation on the October 1990 "Treatability Study Work Plan,"
                  Metcalf & Eddy, Inc.
             5.   Response Dated March 10, 1992 from Cinthia L. McLane, Metcalf & Eddy, Inc.  to
                  Comments Dated April 24, 1991 from Groundwater Technology, Inc. for Nancy Huelsberg,
                  Green Mountain Power Corporation on the October 1990 "Treatability  Study Work Plan,"
                  Metcalf & Eddy, Inc.

10.0   Enforcement

       10.4   Interviews, Depositions and Affidavits

             1.   Memorandum from Ross L. Gilleland, EPA Region I to File (April 27,  1992). Concerning

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information about disposal practices at the site.

10.8 EPA Consent Decrees

1. Consent Decree, United States v. Green Mountain Power Corporation, New England
Electric System, and Vermont Gas Systems, Civil Action 88-307 (Judge Gagliardi) (June
22, 1990).

10.9 Pleadings

1. Complaint, United States v. Green Mountain Power Corporation, New England Electric
System, and Vermont Gas Systems, Civil Action 88-307 (April 20, 1988).

11.0 Potentially Responsible Party (PRP)

11.9 PRP-Specific Correspondence

City of Burlington

1. Letter from Paul G. Keough, EPA Region I to Peter A. Clavelle, Mayor of Burlington
(November 22, 1989). Concerning the status and time frame of work at the site.
2. Letter from Paul G. Keough, EPA Region I to Peter A. Clavelle, Mayor of Burlington
(April 10, 1990). Concerning release of part of the site to the State of Vermont for
highway development.
3. Letter from Christian M. Rascher, EPA Region I to Robert F. Ramey, City of Burlington
(May 23, 1990). Concerning transmittal of analytical data and sample location map of
the site.
4. Letter from Mark T. Eldridge, City of Burlington to Merrill S. Hohman, EPA Region I
(May 25, 1990). Concerning appointment of Robert F. Ramey as Special Projects Manager
for the City of Burlington.
5. Letter from Ross L. Gilleland, EPA Region I to Robert F. Ramey, City of Burlington
(May 21, 1991). Concerning transmittal of sample data.
6. Letter from William F. Ellis, McNeil & Murray (Attorney for City of Burlington) to
Ross L. Gilleland, EPA Region I (May 21, 1991) with attached access-to-property form.
Concerning reguest for all sample results to which the City of Burlington is legally
entitled.
7. Letter from Ross L. Gilleland, EPA Region I to William F. Ellis, McNeil & Murray
(Attorney for City of Burlington) (May 28, 1991). Concerning earlier transmittal of
sample results.
8. Letter from Ross L. Gilleland, EPA Region I to Robert F. Ramey, City of Burlington
(June 5, 1991). Concerning update of property lot numbers and owners.
9. Letter from Robert F. Ramey, City of Burlington to Ross L. Gilleland, EPA Region I
(June 14, 1991). Concerning current list of property owners near barge canal area.
10. Letter from Peter A. Clavelle, Mayor of Burlington to Julie D. Belaga, EPA Region I
(August 27, 1991). Concerning lack of communication from EPA regarding schedule
changes for site work.
11. Letter from Peter A. Clavelle, Mayor of Burlington to James M. Jeffords, U.S. Senate
(October 4, 1991). Concerning lack of communication from EPA regarding schedule
changes for site work.
12. Letter from Julie D. Belaga, EPA Region I to Peter A. Clavelle, Mayor of Burlington
(October 21, 1991). Concerning schedule changes for site work.
13. Letter from Merrill. S. Hohman, EPA Region I to Peter A. Clavelle, Mayor of
Burlington (December 17, 1991) with attached Letter from Ross L. Gilleland to Joseph
M. Kwasnik, New England Power Service (October 15, 1991). Concerning improvement in
communication with the City of Burlington.

Green Mountain Power Corporation

14. Letter from David 0. Ledbetter, Hunton & Williams (Attorney for Green Mountain Power
Corporation) to Margery L. Adams, EPA Region I (February 14, 1991). Concerning
transmittal of Comments Dated January 11, 1991 from Groundwater Technology, Inc. for
Nancy Huelsberg, Green Mountain Power Corporation on the October 1990 "Treatability
Study Work Plan," Metcalf & Eddy, Inc.
15. Cross-Reference: Comments Dated January 11, 1991 from Groundwater Technology, Inc.
for Nancy Huelsberg, Green Mountain Power Corporation on the October 1990
"Treatability Study Work Plan," Metcalf & Eddy, Inc. [Filed and cited as entry number
2 in 4.7 Work Plans and Progress Reports].
16. Letter from David 0. Ledbetter, Hunton & Williams (Attorney for Green Mountain Power
Corporation) to Margery L. Adams, EPA Region I (May 2, 1991). Concerning transmittal
of Comments Dated April 24, 1991 from Groundwater Technology, Inc. for Nancy
Huelsberg, Green Mountain Power Corporation on the October 1990 "Treatability Study
Work Plan," Metcalf & Eddy, Inc.
17. Cross-Reference: Comments Dated April 24, 1991 from Groundwater Technology, Inc. for
Nancy Huelsberg, Green Mountain Power Corporation on the October 1990 "Treatability
Study Work Plan," Metcalf & Eddy, Inc. [Filed and cited as entry number 3 in 4.7 Work
Plans and Progress Reports].

PRP Technical Committee Documents

-------
18. Letter from A. Norman Terreri, Green Mountain Power Corporation; Joseph M. Kwasnik,
New England Power Service; and Michael E. Sullivan, Vermont Gas Systems to Ross L.
Gilleland, EPA Region I (July 1, 1991). Concerning reguest for a meeting to discuss
technical issues related to the site.
19. Letter from Ross L. Gilleland, EPA Region I to A. Norman Terreri, Green Mountain
Power Corporation (July 19, 1991). Concerning acceptance of invitation for meeting
with PRP representatives.
20. Letter from Ross L. Gilleland, EPA Region I to Joseph M. Kwasnik, New England Power
Service (October 15, 1991). Concerning proposed meetings between EPA and PRP
representatives.
21. Letter from Margery L. Adams, EPA Region I to Karen K. O'Neill, Green Mountain Power
Corporation (October 15, 1991). Concerning decision not to release draft documents to
PRPs.
22. Letter from Ross L. Gilleland, EPA Region I to Joseph M. Kwasnik, New England Power
Service (November 4, 1991). Concerning attached address list of PRPs.
23. Letter from Karen K. O'Neill, Green Mountain Power Corporation to Margery L. Adams,
EPA Region I (November 7, 1991). Concerning proposed meetings between EPA and PRPs.
24. Letter from A. Norman Terreri, Green Mountain Power Corporation; Michael E. Sullivan,
Vermont Gas Systems; Andrew H. Aitken, New England Electric Systems; and Robert F.
Ramey, City of Burlington to R. Bradford Cawley, Southern Union Company (November 25,
1991) with attached address list. Concerning an invitation to participate in meetings
between EPA and PRPs.
25. Letter from A. Norman Terreri, Green Mountain Power Corporation to Michael Jarrett,
Citizen Oil Company (December 10, 1991) with attached address list. Concerning
minutes of PRP meeting held on December 6, 1991.
26. Letter from Joseph M. Kwasnik, New England Power Service to Michael Jasinski, EPA
Region I (January 20 1992). Concerning the attached:
A. Copies of invitation letters to PRPs
B. List of PRP Technical Committee.
27. Letter from Michael Jasinski and Ross L. Gilleland, EPA Region I to Joseph M.
Kwasnik, New England Power Service (January 30, 1992). Concerning ground rules for
informational meetings and the attached:
A. List of analytical data collected by EPA
B. "Presentation of Preliminary Investigation Results," Metcalf & Eddy, Inc.
28. Letter from Michael Jasinski, EPA Region I to Joseph M. Kwasnik, New England Power
Service (February 20, 1992). Concerning transmittal of two volumes of "Treatability
Study - Final Report," Metcalf & Eddy, Inc. (February 1992).
29. Letter from Michael Jasinski, EPA Region I to Joseph M. Kwasnik, New England Power
Service (April 10, 1992). Concerning transmittal of three volumes of "Supplemental
Remedial Investigation - Final Report," Metcalf & Eddy, Inc. (March 1992).

30. Letter from Michael Jasinski, EPA Region I to Joseph M. Kwasnik, New England Power
Service (April 22, 1992). Concerning transmittal of the May 1990 "Draft Remedial
Investigation Report," Peer Consultants.

Vermont Agency of Transportation

31. Letter from Paul R. Philbrook, Vermont Agency of Transportation to Christian M.
Rascher, EPA Region I (August 23, 1990) with attached map. Concerning permission to
perform construction for traffic-light system.
32. Letter from Ross L. Gilleland, EPA Region I to Paul R. Philbrook, Vermont Agency of
Transportation (December 4, 1990). Concerning EPA's reguest that VT AOT wait until
sample results are available before proceeding with construction.
33. Letter from Paul R. Philbrook, Vermont Agency of Transportation to Ross L. Gilleland,
EPA Region I (December 10, 1990). Concerning minor construction activity at Lakeside
Avenue.
34. Letter from Robert F. Ramey, City of Burlington to Mary Jane O'Donnell, EPA Region I
(December 20, 1990). Concerning reguest to proceed with minor construction at
Lakeside Avenue.
35. Letter from Ross L. Gilleland, EPA Region I to Paul R. Philbrook, Vermont Agency of
Transportation (January 18, 1991). Concerning contingencies for construction at
Lakeside Avenue.
36. Letter from Robert M. Murphy, Vermont Agency of Transportation to Ross L. Gilleland,
EPA Region I (January 29, 1991). Concerning contingent approval to perform minor
construction at Lakeside Avenue upon receipt of sample results.
37. Letter from Ross L. Gilleland, EPA Region I to Robert M. Murphy, Vermont Agency of
Transportation (May 16, 1991). Concerning withdrawal of wetlands permit application.
38. Letter from Ross L. Gilleland, EPA Region I to Robert M. Murphy, Vermont Agency of
Transportation (June 6, 1991). Concerning Confirmation of proposed highway alignment.
39. Letter from Robert M. Murphy, Vermont Agency of Transportation to Ross L. Gilleland,
EPA Region I (June 14, 1991). Concerning status of wetlands permit and the highway
alignment plan.
40. Letter from Patrick J. Garahan, Vermont Agency of Transportation to Julie D. Belaga,
EPA Region I (November 7, 1991). Concerning reguest for meeting to discuss site
issues.
41. Letter from Ross L. Gilleland, EPA Region I to Robert M. Murphy, Vermont Agency of
Transportation (November 21, 1991). Concerning EPA's understanding of the highway
project as it relates to the site and setting for the contingencies on minor

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construction at Lakeside Avenue.
42. Letter from Robert M. Murphy, Vermont Agency of Transportation to Ross L. Gilleland,
EPA Region I (December 5, 1991). Concerning clarification of modified highway
construction plans.
43. Letter from Julie D. Belaga, EPA Region I to Patrick J. Garahan, Vermont Agency of
Transportation (December 10, 1991). Concerning withdrawal of reguest for a meeting.
44. Memorandum from John H. Perkins, Vermont Agency of Transportation to File via Robert
M. Murphy, Vermont Agency of Transportation (March 17, 1992). Concerning the February
21, 1992 meeting.

11.12 PRP Related Documents

Blodgett Oven Company

1. "Subsurface Investigation," Aguatec, Inc. for Blodgett Oven Company (July 1989).
2. Letter from Craig H. Campbell, Mintz, Levin, Cohn, Ferris, Glovsky and Popeo (Attorney for
G.S. Blodgett Company) to Ross L. Gilleland and Margery L. Adams, EPA Region I (November
19, 1991) with maps. Concerning reguest to redelineate boundaries and attached November
1991 "Analytical Data to Support Exclusion of the Blodgett Property West of the Railroad
Tracks," Aguatec, Inc. for Blodgett Oven Company.

General Electric Company

3. "Summary of Environmental Sampling," Wehran Engineering Corporation for General Electric
Company (October 1989) .

Ultramar Petroleum, Inc.

4. "Environmental Site Assessment - Ultramar Petroleum, Inc."ERM-Northeast for Atlantic
Petroleum Company (November 1986).
5. Letter from Christopher H. Marraro, Kaye, Scholer, Fierman, Hays & Handler (Attorney for
Ultramar Petroleum, Inc.) to Margery L. Adams, EPA Region I (November 16,1990). Concerning
objection to certain analytical methods used at the Ultramar site.
6. Letter from Margery L. Adams to Christopher H. Manaro, Kaye, Scholer, Fierman, Hays &
Handler (Attorney for Ultramar Petroleum, Inc.) (March 4, 1991). Concerning response to
Mr. Marraro's November 16, 1990 letter with attached:
A. Letter from Patrick 0. Gwinn and Martha L. Zirbel, Metcalf & Eddy, Inc. to Ross L.
Gilleland, EPA Region I (January 18, 1991). Concerning response to Mr. Marraro's
November 16, 1990 letter.
B. Letter from Patrick 0. Gwinn and Martha L. Zirbel, Metcalf & Eddy, Inc. to Ross L.
Gilleland, EPA Region I (February 22, 1991). Concerning further clarification of
analytical methods.
C. Standard Practice for Identification of Waterborne Oils.
D. Appendix G - Analytical Method for Determining Fuel Oil Component in Soil/Sediment.

Vermont Agency of Transportation

7. "Final Summary - Burlington Administrative Action Environmental Statement," Vermont Agency
of Transportation and U.S. Department of Transportation (1977).
8 . "Burlington Southern Connector - Remedial Action and Highway Construction Study," Perkins
Jordan, Inc. for Vermont Agency of Transportation (October 1982).
9. "Draft Burlington Southern Connector - Remedial Action and Highway Construction Assessment
- Phase II," Perkins Jordan, Inc. for Vermont Agency of Transportation (January 1983).
10. "Burlington Southern Connector Permit Application - Design Report - Volume I," Perkins
Jordan, Inc. for Vermont Agency of Transportation (January 1984).
11. "Burlington Southern Connector Permit Application - Technical Appendices - Volume 2,"
Perkins Jordan, Inc. for Vermont Agency of Transportation (January 1984).
12. "Burlington Southern Connector Permit Application - Groundwater Treatment Plant Operations
and Maintenance Manual - Volume 3," Perkins Jordan, Inc. for Vermont Agency of
Transportation (January 1984).
13. "Southern Connector Subsurface Contamination Search," Aguatec, Inc. for Vermont Agency of
Transportation (June 1988).
14. "Wiessner Property and St. Johnsbury Trucking Sites Subsurface Contamination Delineation
Survey," Aguatec, Inc. for Vermont Agency of Transportation (February 1989).
15. "Evaluation of the Final Environmental Impact Statement for the Champlain
Parkway/Burlington Southern Connector," U.S. Department of Transportation and Vermont
Agency of Transportation (March 13, 1989).

13.0 Community Relations

13.1 Correspondence

1. Letter from Theresa Freeman, Vermonters Organized for Cleanup to Michael R. Deland,
EPA Region I (July 26, 1985). Concerning the reauthorization of Superfund.
2. Letter from Michael R. Deland, EPA Region I to Theresa Freeman, Vermonters Organized
for Cleanup (January 14, 1986). Concerning a status report on site activities.
3. Letter from Mark L. Wert, ICF Kaiser Engineers to Robert F. Ramey, City of Burlington
(June 5, 1990). Concerning information to be included in the community relations

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plan.
4. Letter from William J. Keogh Sr. to Christain M. Rascher, EPA Region I (September 4,
1990). Concerning lack of progress with site cleanup causing delay in construction of
the Southern Connector.
5. Letter from Ross L. Gilleland, EPA Region I to William J. Keogh Sr. (November 29,
1990). Concerning current and future activities at the site.
6. Letter from Ross L. Gilleland, EPA Region I to Cindy Houston (December 12, 1990).
Concerning receipt of information packet.

13.2 Community Relations Plans

1. "Community Relations Plan," EPA Region I (December 1990).

13.3 News Clippings/Press Releases

Press Releases

1. "Environmental News - EPA to Hold Public Meeting to Discuss Pine Street Barge Canal
Superfund Site," EPA Region I (March 22, 1989).
2. "Environmental News - EPA Moves Into New Phase of Remedial Investigation at the Pine
Street Canal Superfund Site in Burlington, Vermont," EPA Region I (August 31, 1990).
3. "Environmental News - EPA Announces Open House for Residents Near Pine Street Canal
Superfund Site in Burlington, Vermont," EPA Region I (November 23, 1990).
4. "Environmental News - Media Advisory," EPA Region I (November 23, 1990). Concerning
open house to be held at the site.
5. "Open House for the Pine Street Canal Superfund Site," EPA Region I (December 5,
1990).
6. "Environmental News - EPA Announces Two Weeks of Additional Field Studies at the Pine
Street Canal Superfund Site in Burlington, Vermont," EPA Region I (April 3, 1992).

13.5 Fact Sheets

1. "EPA Completes Plans," EPA Region I (March 1989). Concerning plans for conducting an
investigation into contamination at the site.
2. "EPA Conducts Biological Studies," EPA Region I (May 1990). Concerning plans to
conduct biological and aguatic field studies at the site.
3. "EPA Announces Results of Treatability Studies," EPA Region I (February 1992).
Concerning summary of major findings of the treatability studies.
4. "EPA Announces Results of Remedial Investigations," EPA Region I (April 1992).
Concerning findings of widespread contamination of soils, groundwater and sediments.

14.0 Congressional Relations

14.1 Correspondence

1. Letter from Curtis A. Moore, U.S. Senate to Eric Sapirstein, EPA Headguarters
(September 10, 1981). Concerning information received on two sites in Vermont.
2. Letter from Jack Woolley to Robert T. Stafford, U.S. Senate (September 30, 1981).
Concerning information on two sites in Vermont.
3. Letter from James M. Jeffords, Patrick J. Leahy and Peter Smith, U.S. Senate to Julie
D. Belaga, EPA Region I (March 14, 1990). Concerning lack of progress at the site and
a reguest for a meeting to be held in April 1990.
4. Memorandum from Bob Paguin, Office of Patrick J. Leahy, U.S. Senate to May 10, 1990
Meeting Participants (May 2, 1990). Concerning relocation of meeting to the Aiken
Forestry Research Lab in Burlington.
5. Letter from James M. Jeffords, U.S. Senate to Julie D. Belaga, EPA Region I (July 9,
1991). Concerning adherence to site schedules.
6. Letter from Julie D. Belaga, EPA Region I to James M. Jeffords, U.S. Senate (August
8, 1991). Concerning status report on activities at the site.

19.0 Resource Conservation and Recovery Act (RCRA) Records

Although not expressly listed in this Index, all documents contained in the September 1991
Resource Conservation and Recovery Act (RCRA) Administrative Record are incorporated by
reference herein, and are expressly made a part of this Preliminary Administrative Record.

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ADMINISTRATIVE RECORD ADDENDUM INDEX

for the

Pine Street Canal NPL Site

1. 0 Pre-Remedial Records

1.1 CERCLIS Site Discovery

1. "Site Identification," EPA Region I (July 9, 1981).

1.2 Preliminary Assessment

1. "Site Identification and Preliminary Assessment," EPA Region I (October 5, 1981).
2. "Site Identification and Preliminary Assessment," EPA Region I (May 27, 1982).

3.0 Remedial Investigation (RI)

3.1 Correspondence

1. Letter from John A. Malter, Vermont Agency of Environmental Conservation to Richard
C. Boynton, EPA Region I (November 20, 1986). Concerning the State's decision to
discontinue contracting for site studies.
2. Letter from Richard C. Boynton, EPA Region I to John A. Malter, Vermont Agency of
Environmental Conservation (December 18, 1986). Concerning the State's decision not
to continue with site studies.
3. Letter from Karle L. Snyder, U.S. Department of Transportation Federal Highway
Administration to Paula Fitzsimmons, EPA Region I (April 13, 1989). Concerning the
transmittal of boring logs and the attached February 22, 1985 letter from Elizabeth
A. Higgins, EPA Region I.

3.2 Sampling and Analysis Data

1. "Technical Memorandum - Summary of Sampling Modifications - Biological Assessment,"
Metcalf & Eddy, Inc. (May 15, 1990).
2. Letter from Andrew Beliveau, Metcalf & Eddy, Inc. to Deb Szaro, EPA Region I
(September 27, 1990). Concerning the attached development of total PAH/carcinogenic
PAH method.
3. Memorandum from Joseph Montanaro, EPA Region I to Daniel Granz, EPA Region I (May 7,
1992). Concerning the attached low-level purgeable organic analyses.
4. Memorandum from Peter Philbrook, Shirish Vora and Richard Siscanaw, EPA Region I to
Daniel Granz, EPA Region I (May 13, 1992). Concerning the attached gas
chromatography-mass spectrometry analysis of extractable organics in agueous samples.
5. Memorandum from Peter Philbrook, Shirish Vora, ESAT and Richard Siscanaw, EPA Region
I to Daniel Granz, EPA Region I (May 14, 1992). Concerning the attached gas
chromatography-mass spectrometry analysis of extractable organics in agueous samples.
6. Memorandum from Daniel S. Granz, EPA Region I to Michael Jasinski, EPA Region I (May
21, 1992) . Concerning PAH data from well samples.
7. Letter from Martha L. Zirbel, Metcalf & Eddy, Inc. to Michael Jasinski, EPA Region I
(June 26, 1992). Concerning the attached analysis of coal tar samples.
8. Letter from Christopher M. Crandell, The Johnson Company to Michael Jasinski, EPA
Region I (July 1, 1992). Concerning the attached:
A. Map of sampling locations
B. Table 1 - Fuel Characterization
C. Table 2 - Hazardous Waste Characterization
D. Table 3 - Asphalt Batch Plant Characteristics
E. Laboratory analysis reports.
9. Commercial Testing & Engineering Co. Analysis Report No. 71-34861 for the The Johnson
Company (July 9, 1992). Handwritten note regarding viscosity reading is from The
Johnson Company.
10. "START Program - Computer Assisted Site Evaluation of Carcinogenic PAH Contamination
in Soil and Sediment," EPA Region I (October 2, 1992).

3.4 Interim Deliverables

1. "Draft Technical Memorandum - Review of Site Information and Contaminant
Information," Metcalf & Eddy, Inc. (June 1990).
2. Letter from Gary P. Kjelleren, General Electric to Ross Gilleland, EPA Region I (June
13, 1991). Concerning the attached:
A. "CERCLA Oversight," General Electric (November 1990)
B. "Draft - Report on Oversight for the CERCLA Field Activities Conducted at the
GE, Lakeside Avenue Facility, Burlington, Vermont," Wehran Engineering for
General Electric (February 1990).

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3. Letter from Gary P. Kjelleren, General Electric to Michael Jasinski, EPA Region I
(July 13, 1992). concerning transmittal of the attached April 1992 "Oversight Report
for EPA Activities on the GE Site on April 16 and 20, 1992."

3.6 Remedial Investigation (RI) Reports

Reports

1. "Technical Memorandum No. 14 - Pine Street Canal - Supplemental RI/FS - Task 3,"
Metcalf & Eddy, Inc. (June 16, 1992).

Comments

The documents upon which entry numbers 2 through 5 comment are filed and cited as entry
numbers 5 through 7 in 3.6 Remedial Investigation (RI) Reports of the May 18, 1992 Initial
Administrative Record for this site.

2. Comments Dated July 1, 1992 from Gary P. Kjelleren, General Electric on the March
1992 "Supplemental Remedial Investigation Final Report - Volumes I - III," Metcalf &
Eddy, Inc.
3. Comments Dated July 1, 1992 from Gary P. Kjelleren, General Electric on the March
1992 Supplemental Remedial Investigation Final Report," Metcalf & Eddy, Inc., the
February 1992 "Treatability Study Final Report," Metcalf & Eddy, Inc., and the May
1992 "Baseline Risk Assessment Final Report," Metcalf & Eddy, Inc.
4. Comments Dated July 10, 1992 from Joseph M. Kwasnik for A. Norman Terreri, Green
Mountain Power Corporation for the PRP Technical Committee on the March 1992
Supplemental Remedial Investigation Final Report," Metcalf & Eddy, Inc., the February
1992 "Treatability Study Final Report," Metcalf & Eddy, Inc., and the May 1992
"Baseline Risk Assessment Final Report," Metcalf & Eddy, Inc.
5. Comments Dated July 24, 1992 from Robert R. Dill, Whiting Company on the March 1992
"Supplemental Remedial Investigation Final Report - Volumes I - III," Metcalf & Eddy,
Inc.

3.7 Work Plans and Progress Reports

Reports

1. Letter from Martha L. Zirbel, Metcalf & Eddy, Inc. to Michael Jasinski, EPA Region I
(April 7, 1992). Concerning the attached:
A. "Field Sampling Plan Addendum," (April 6, 1992)
B. "Quality Assurance Project Plan Addendum," (April 6, 1992).
2. "Groundwater (monitoring and production) Well Sampling - Spring 1992," EPA Region I
(April 8, 1992) .

Comments

The documents upon which entry number 1 comment are filed and cited as entry numbers 6 and
7 in 3.4 Interim Deliverables and entry number 2 in 3.7 Work Plan and Progress Reports of
the May 18, 1992 Initial Administrative Record for this site.

3. Comments Dated April 12, 1989 from Gary P. Kjelleren and Douglas E. Seely, Wehran
Engineering for General Electric on the March 20, 1989 "Field Operations Plan for
Pine Street Canal Site Remedial Investigation/Feasibility Study," "Quality Assurance
Project Plan for Pine Street Canal Remedial Investigation/Feasibility Study," and
"Work Plan Volume I - Technical - for Remedial Investigation/Feasibility Study," PEER
Consultants.

3.9 Health Assessments

1. Memorandum from Tammie A. McRae, Department of Health & Human Services Agency of
Toxic Substances and Disease Registry to Suzanne Simon, EPA Region I (October 29,
1992). Concerning a health consultation for the site.

3.10 Endangerment Assessments

1. "Baseline Risk Assessment Final Report," Metcalf & Eddy, Inc. (May 1992).

Comments

2. Comments Dated July 1, 1992 from Gary P. Kjelleren, General Electric on the "Baseline
Risk Assessment Final Report," Metcalf & Eddy, Inc. (May 1992).
3. Cross-Reference: Comments Dated July 1, 1992 from Gary P. Kjelleren, General Electric
on the March 1992 Supplemental Remedial Investigation Final Report," Metcalf & Eddy,
Inc., the February 1992 "Treatability Study Final Report," Metcalf & Eddy, Inc., and
the May 1992 "Baseline Risk Assessment Final Report," Metcalf & Eddy, Inc. [Filed and
cited as entry number 3 in 3.6 Remedial Investigation (RI) Reports].
4. Cross-Reference: Comments Dated July 10, 1992 from Joseph M. Kwasnik for A. Norman

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Terreri, Green Mountain Power Corporation for the PRP Technical Committee on the
March 1992 Supplemental Remedial Investigation Final Report," Metcalf & Eddy, Inc.,
the February 1992 "Treatability Study Final Report," Metcalf & Eddy, Inc., and the
May 1992 "Baseline Risk Assessment Final Report," Metcalf & Eddy, Inc. [Filed and
cited as entry number 4 in 3.6 Remedial Investigation (RI) Reports].
5. Comments Dated July 22, 1992 from Robert Dill, Whiting Company on the July 10, 1992
Comments from Joseph M. Kwasnik for A. Norman Terreri, Green Mountain Power
Corporation for the PRP Technical Committee on the March 1992 Supplemental Remedial
Investigation Final Report," Metcalf & Eddy, Inc., the February 1992 "Treatability
Study Final Report," Metcalf & Eddy, Inc., and the May 1992 "Baseline Risk Assessment
Final Report," Metcalf & Eddy, Inc.

4.0 Feasibility Study (FS)

4.1 Correspondence

1. Letter from A. Norman Terreri, Green Mountain Power Corporation to Julie Belaga, EPA
Region I (May 6, 1992). Concerning the PRP Technical Committee's reguest to extend
the review period for various feasibility studies.
2. Letter from Peter A. Clavelle, Mayor of Burlington to Julie Belaga, EPA Region I (May
8, 1992). Concerning support for the PRP Technical Committee's reguest to extend the
review period for various feasibility studies.
3. Letter from William E. Ahearn, Vermont Agency of Natural Resources to Mary Jane
O'Donnell, EPA Region I (May 11, 1992). Concerning support for PRP Technical
Committee's reguest to extend the review period for various feasibility studies.
4. Letter from Karen K. O'Neill, Green Mountain Power Corporation to Ross Gilleland, EPA
Region I (May 13, 1992). Concerning inclusion of Comments Dated January 11, 1991 from
Groundwater Technology, Inc. for Green Mountain Power Corporation on the October 1990
"Treatability Study Work Plan," Metcalf & Eddy, Inc. in the Administrative Record.
5. Letter from Todd G. Schwendeman, Groundwater Technology, Inc. to Ross Gilleland, EPA
Region I (May 14, 1992). Concerning release from copyright restrictions on the
Comments Dated January 11, 1991 from Groundwater Technology, Inc. for Green Mountain
Power Corporation on the October 1990 "Treatability Study Work Plan," Metcalf & Eddy,
Inc.
6. Letter from Julie Belaga, EPA Region I to Peter A. Clavelle, Mayor of Burlington (May
29, 1992). Concerning EPA's approval of a 60-day extension for review of various
feasibility studies.
7. Letter from Julie Belaga, EPA Region I to A. Norman Terreri, Green Mountain Power
Company (May 29, 1992) with attached letter from Julie Belaga, EPA Region I to Peter
A. Clavelle, Mayor of Burlington. Concerning EPA's approval of a 60-day extension for
the completion of the Feasibility Study and issuance of a Proposed Plan.
8. Letter from Michael Jasinski, EPA Region I to Joseph M. Kwasnik, New England Power
Service (June 5, 1992). Concerning the transmittal of several remedial documents and
the attached "Draft - Remedial Action Objectives for the Pine Street Canal Site."
9. Letter from Joseph M. Kwasnik, New England Power Service to Michael Jasinski, EPA
Region I (June 10, 1992). Concerning the attached "Anticipated Schedule for the
Development of Additional Remedial Alternative Information to EPA."
10. Letter from Mary Jane O'Donnell for Michael Jasinski, EPA Region I to Joseph M.
Kwasnik; New England Power Service (June 12, 1992). Concerning EPA's approval of The
Johnson Company to perform sampling and analysis activities for the PRP Technical
Comittee.
11. Letter from Julie Belaga, EPA Region I to Mark T. Eldridge, City of Burlington (July
2, 1992). Concerning zoning issues as they pertain to remediation at the site.
12. Letter from Julie Belaga, EPA Region I to Robert F. Ramey, City of Burlington (July
2, 1992). Concerning EPA's review of a containment remedial alternative for the site
which involves capping.
13. Letter from Peter A. Clavelle, Mayor of Burlington to Julie Belaga, EPA Region I
(August 27, 1992). Concerning a reguest for a personal briefing of the Feasibility
Study and the Proposed Plan.
14. Letter from Howard Dean, Governor of Vermont and Peter Clavelle, Mayor of Burlington
to Julie Belaga, EPA Region I (October 26, 1992). concerning the hope that EPA will
approve the PRP Technical Committee's remediation plan.

4.2 Sampling and Analysis Data

1. Letter from Gary P. Kjelleren, General Electric to Michael Jasinski, EPA Region I
(February 28, 1992). Concerning the attached water-guality results from the oldest
well on GE's property.
2. Letter from Joseph M. Kwasnik, New England Power Service to Michael Jasinski, EPA
Region I (June 5, 1992). Concerning transmittal of the attached June 1992 "Sampling
and Analysis Work Plan for Limited Supplemental Feasibility Study, " The Johnson
Company for The PRP Technical Committee.
3. "Amendment to the Sampling and Analysis Work Plan for Limited Supplemental
Feasibility Study," The Johnson Company for the PRP Technical Committee (June 11,
1992).
4. Letter from Alfred F. Clancy and Martha L. Zirbel, Metcalf & Eddy, Inc. to Michael
Jasinski, EPA Region I (Aug. - 5, 1992). Concerning the Tier I validation performed
on TCLP inorgarnics analytical data packages from Lancaster Laboratories.

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5. Letter from Alfred F. Clancy and Martha L. Zirbel, Metcalf & Eddy, Inc. to Michael
Jasinski, EPA Region I (August 5, 1992). Concerning the Tier I validation performed
on TCLP organic analytical data packages from Lancaster Laboratories.

Comments

6. Comments Dated June 12, 1992 from Michael Jasinski, EPA Region I on the June 1992
"Sampling & Analysis Work Plan for Limited Supplemental Feasibility Study," The
Johnson Company for the PRP Technical Committee.

The remaining Sampling and Analysis Data for the Feasibility Study (FS) may be reviewed,
by appointment only, at EPA Region I, Boston, Massachusetts.

4.4 Interim Deliverables

Reports

1. Technical Memorandum - Treatability Study," Metcalf & Eddy, Inc. (Financial
information is withheld as CONFIDENTIAL).
2. "Technical Memorandum No. 2 - Treatability Study - Pumping Test Plan," Metcalf &
Eddy, Inc. (August 15, 1990) (Financial information is withheld as CONFIDENTIAL).
3. "Technical Memorandum No. 3 - Treatability Study," Metcalf & Eddy, Inc.
4. "Technical Memorandum No. 4 - Treatability Study - Bioremediation Literature Search,"
Metcalf & Eddy, Inc.
5. "Technical Memorandum No. 5 - Treatability Study - Trial Pumping Test Results,"
Metcalf & Eddy, Inc. (September 13, 1990).
6. "Technical Memorandum No. 6 - Treatability Study," Metcalf & Eddy, Inc.
7. "Technical Memorandum No. 7 - Treatability Study - Task 7," Metcalf & Eddy, Inc.
(January 4, 1991).
8. "Technical Memorandum No. 8 - Treatability Study," Metcalf & Eddy, Inc.
9. "Site Health and Safety Plan," The Johnson Company for Green Mountain Power
Corporation (June 1992).
10. "A Stage IA Cultural Resources Survey of the Pine Street Canal Superfund Site," John
Milner Associates for Metcalf & Eddy, Inc. (1992).

Comments

The documents upon which entry numbers 11 and 12 comment are filed and cited as entry
numbers 3 and 4 in 4.4 Interim Deliverables of the May 18, 1992 Initial Administrative
Record for this site.

11. Cross-Reference: Comments Dated July 1, 1992 from Gary P. Kjelleren, General Electric
on the March 1992 Supplemental Remedial Investigation Final Report," Metcalf & Eddy,
Inc., the February 1992 "Treatability Study Final Report," Metcalf & Eddy, Inc., and
the May 1992 "Baseline Risk Assessment Final Report," Metcalf & Eddy, Inc. [Filed
and cited as entry number 3 in 3.6 Remedial Investigation (RI) Reports].
12. Cross-Reference: Comments Dated July 10, 1992 from Joseph M. Kwasnik for A. Norman
Terreri, Green Mountain Power Corporation for the PRP Technical Committee on the
March 1992 Supplemental Remedial Investigation Final Report," Metcalf & Eddy, Inc.,
the February 1992 "Treatability Study Final Report," Metcalf & Eddy, Inc., and the
May 1992 "Baseline Risk Assessment Final Report," Metcalf & Eddy, Inc. [Filed and
cited as entry number 4 in 3.6 Remedial Investigation (RI) Reports].

4.5 Applicable or Relevant and Appropriate Reguirements (ARARs)

1. Letter from Arthur D. Aldrich, Vermont Agency of Transportation to Eric Gilbertson,
Vermont Agency of Development and Community Affairs (September 10, 1984). Concerning
historical information about the site. Meeting Notes, Vermont Agency of Development
and Community Affairs and Vermont Advisory Council on Historic Preservation (August
7, 1985). Concerning shipwrecks in the canal not be endangered by the cleanup.
Letter from David Skinas, Vermont Agency of Development and Community Affairs to
Stanley Corneille, Vermont Agency of Natural Resources (January 26, 1988). Concerning
possible impact of cleanup activities to the canal and associated historic resources.
4. Letter from Stanley Corneille, Vermont Agency of Natural Resources to Paula L.
Fitzsimmons, EPA Region I (February 4, 1988). Concerning transmittal of a copy of the
January 26, 1988 letter from David Skinas, Vermont Agency of Development Community
Affairs.
5. Letter from Giovanna Peebles, Vermont Agency of Development and Community Affairs and
Paula L. Fitzsimmons, EPA Region I (February 23, 1989). Concerning EPA's
responsibility for carrying out archaeological studies of known shipwrecks at the
site.
6. "Urban Renewal Plan for the Waterfront Revitalization District - A Revitalization
Strategy for the 1990s and Beyond," Burlington Planning Commission (September 24,
1990).
7. "Burlington Municipal Development Plan (pages 14, 15, 44, 97, 100, and 3 maps),"
Burlington City Council, Mayor of Burlington, and the Burlington Planning Commission
(June 1991).
8. Letter from David Webster, EPA Region I to William Ahearn, Vermont Agency of Natural

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Resources (January 3, 1992). Concerning Vermont's regulatory reguirements.
9. Memorandum from Giovanna Peebles, Vermont Agency of Development and Community Affairs
to Robert B. Finucane and Stanley Corneille, Vermont Agency for Natural Resources
(January 15, 1992) with attached map. Concerning EPA's compliance with Section 106 of
the National Historic Preservation Act.
10. Letter from Robert B. Finucane, Vermont of Agency of Natural Resources to Mary Jane
O'Donnell, EPA Region I (March 2, 1992). Concerning Vermont's regulatory
reguirements.
11. Letter from Robert B. Finucane, Vermont of Agency of Natural Resources to Mary Jane
O'Donnell, EPA Region I (October 22, 1992). Concerning groundwater reclassification
at the site.
12. Letter from Peter A. Clavelle, Mayor of Burlington to Jube Belaga, EPA Region I
(October 26, 1992). Concerning groundwater reclassification at the site and the
attached:
A. "Draft - Interim Procedures for the Submission and Review of Proposals for the
Reclassification of Ground Water to Class IV," Secretary of the Agency of
Natural Resources (October 13, 1992)
B. "Draft - Hazardous Materials Management Division Policy to Map Class IV Ground
Water Areas," Department of Environmental Conservation (October 13, 1992)
C. Title 10, Vermont Statutes Annotated, Chapter 48, Groundwater Protection
(November 30, 1988).
13. Letter from Robert F. Ramey, City of Burlington to Ross Gilleland, EPA Region I
(October 26, 1992). concerning attached excerpts from Code of Ordinances pertaining
to potable water.
14. Memorandum from Stephen Mangion, EPA Region I to Sheila Eckman, EPA Region I
(November 3, 1992). Concerning ground water classification at the site.

4.6 Feasibility Study (FS) Reports

1. "Feasibility Study - Final Report - Volume I," Metcalf & Eddy, Inc. (November 1992).
2. "Feasibility Study - Final Report - Volume II," Metcalf & Eddy, Inc. (November 1992).
3. "Feasibility Study - Final Report - Volume III," Metcalf & Eddy, Inc. (November
1992).

4.7 Work Plans and Progress Reports

1. Memorandum from Barbara Wyskowski, Metcalf & Eddy, Inc. to Martha L. Zirbel, Metcalf
& Eddy, Inc. (July 6, 1992). Concerning oversight of field work for the Limited
Feasibility Study at the site.

4.9 Proposed Plans for Selected Remedial Action

1. "EPA Proposes Cleanup Plan for the Pine Street Canal Superfund Site," EPA Region I
(November 1992).
10.0 Enforcement
10.1 Correspondence
10.
11.
12.
13.
Letter from Merrill S. Hohman, EPA Region I to Charles M. Samuelson (November 6,
1992). Concerning the Proposed Plan for site cleanup.
Letter from Merrill S. Hohman, EPA Region I to Robert H. Penniman (November 6, 1992).
Concerning the Proposed Plan for site cleanup.
Letter from Merrill S. Hohman, EPA Region I to Philip H. Hoff (November 6, 1992).
Concerning the Proposed Plan for site cleanup.
Letter from Merrill S. Hohman, EPA Region I to Thomas A. Farrell (November 6, 1992).
Concerning the Proposed Plan for site cleanup.
Letter from Merrill S. Hohman, EPA Region I to George P. Barrett (November 6, 1992).
Concerning the Proposed Plan for site cleanup.
Letter from Merrill S. Hohman, EPA Region I to James Fitzgerald, Central Vermont
Railroad (November 6, 1992). Concerning the Proposed Plan for site cleanup.
Letter from Merrill S. Hohman, EPA Region I to Charles A. Cairns, Champlain Oil
Company (November 6, 1992). Concerning the Proposed Plan for site cleanup.
Letter from Merrill S. Hohman, EPA Region I to The Augsbury Corporadon, c/o Atlantic
Fuels Marketing Corp. (November 6, 1992). Concerning the Proposed Plan for site
cleanup.
Letter from Merrill S. Hohman, EPA Region I to President, Allied-Signal, Inc.
(November 6, 1992). Concerning the Proposed Plan for site cleanup.
Letter from Merrill S. Hohman, EPA Region I to Richard Grundler, Robert Perrin,
Charles Hadden, Richard Reed, Stanley Smith, Stuart Jacobs, Robert Watson, Charles
Shea, Stan Fersing (formerly The Leverage Group) (November 6, 1992). Concerning the
Proposed Plan for site cleanup.
Letter from Merrill S. Hohman, EPA Region I to Stan Cyphers, Uhlman Co. (November 6,
1992). Concerning the Proposed Plan for site cleanup.
Letter from Merrill S. Hohman, EPA Region I to George L. Lindemann, Southern Union
Company (November 6, 1992). Concerning the Proposed Plan for site cleanup.
Letter from Merrill S. Hohman, EPA Region I to John W. Rowe, New England Power
Service (November 6, 1992). Concerning the Proposed Plan for site cleanup.

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14. Letter from Merrill S. Hohman, EPA Region I to Robert M. Furek, Heublein, Inc.
(November 6, 1992). Concerning the Proposed Plan for site cleanup.
15. Letter from Merrill S. Hohman, EPA Region I to Robert Heinemann, U.S. Department of
Commerce (November 6, 1992). Concerning the Proposed Plan for site cleanup.

10.3 State and Local Enforcement Records

1. Memorandum from W. William Martinez, Vermont Department of Water Resources to A.
William Albert, Vermont Department of Water Resources (July 18, 1968). Concerning oil
spilled into Lake Champlain and action taken to contain the spill.
2. Memorandum from Water Quality Section, Vermont Department of Water Resources to A.
William Albert, Vermont Department of Water Resources (July 23, 1968). Concerning
meeting notes discussing oil pollution caused by the Burlington Gas Works.
3. Report of Investigation of E.B. & A.C. Whiting Co., Army Corps of Engineers, Case
#77-064 (June 2, 1977).
4. Report of Investigation of General Electric, Army Corps of Engineers, Case #78-218.
Concerning the attached:
A. Letter from Phillip W. McGrade, Army Corps of Engineers to General Electric
(January 11, 1979). Concerning placement of fill material in wetlands area
adjacent to the site.
B. Letter from W.N. Aswad, General Electric to Phillip W. McGrade, Army Corps of
Engineers (January 19, 1979). Concerning material inadvertently deposited at the
site.
C. Report of Investigation, Martha Abair, Army Corps of Engineers.
D. Letter from D.E. Momot, General Electric to G.A. Laraway, Army Corps of
Engineers (September 14, 1979). Concerning transmittal of a work plan describing
GE's proposal to remove fill.
E. Letter from Phillip W. McGrade, Army Corps of Engineers to D.E. Momot, General
Electric (December 14, 1979). Concerning GE's violation of Federal statutes by
performing work at the site without an Army permit.
F. General Location Map, Burlington Harbor, Vermont (1974).

10.5 General Negotiations

1. Special-Notice Letter from Merrill S. Hohman, EPA Region I to List (February 23,
1988). Concerning a demand for reimbursement of costs incurred, and those expected to
be incurred, in response to the environmental problems at the site. Letter was sent
to the following:
Michael Jarrett, Citizens Oil Company
Bernard Sanders, Mayor of Burlington
Derrick Davis, Davis Development Corporation
Christine Farrell
Louis Farrell, L.E. Farrell Company, Inc.
Robert McLaughlin, G.S. Blodgett Company
Karen K. O'Neill, Green Mountain Power
Susan C. Crampton, Vermont Agency of Transportation
Derrick Davis, Maltex Partnership
Anette S. Lewis, New England Electric Service
Christopher Marraro for Ultramar Petroleum
Andrew Field, Vermont Development Credit Corporation
Douglas Wacek, Vermont Gas Systems
John Pennington, Vermont Railroad
Robert R. Dill, E.B. & A.C. Whiting Company, Inc.
W.N. Aswad, General Electric
William Milaschewski, St. Johnsbury Trucking.

10.7 EPA Administrative Orders

1. Letter from Ira W. Leighton for Merrill S. Hohman, EPA Region I to Thomas R. Viall,
U.S. Department of Justice (May 12, 1989). Concerning the attached Administrative
Order for Access.

10.8 EPA Consent Decrees

1. Consent Decree, United States v. Green Mountain Power Corp., New England Electric
System, and Vermont Gas Systems, Inc., United States District Court for the District
of Vermont, Civil Action No. 88-307 (June 22, 1990).

10.10 Trial Documents

1. The following documents were reproduced in response to a reguest for production of
documents:
A. News of Green Mountain Power Corporation (October 1928)
B. News of Green Mountain Power Corporation (December 1928)
C. News of Green Mountain Power Corporation (August 1929)
D. News of Green Mountain Power Corporation (September 1929)
E. News of Green Mountain Power Corporation (October 1929)
F. News of Green Mountain Power Corporation (November 1929)

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G. "Tar-Like Substance in Lake Traced to Source, Stopped," Burlington Free Press,
Burlington, VT (June 9, 1966)
H. "Burlington's Gas House Comes Down," Burlington Free Press, Burlington, VT
(November 21, 1966)
I. "Hanoi After U.S. Attack?," Burlington Free Press, Burlington, VT (May 29, 1967)
J. "Officials Continue Battle Against Flow of Sludge," (July 24, 1968)
K. "Workers Try to Dam the Pollution."

11.0 Potentially Responsible Party (PRP)

11.2 Contractor Related Correspondence

1. Letter from Christopher M. Crandell, The Johnson Company for the PRP Technical
Committee to Michael Jasinski, EPA Region I (June 23, 1992). Concerning field work
performed at the site.
2. Letter from Christopher M. Crandell, The Johnson Company for the PRP Technical
Committee to Michael Jasinski, EPA Region I (August 11, 1992). Concerning remedial
alternative technology cost estimate.

11.9 PRP-Specific Correspondence

G.S. Blodgett International Corp.

1. Letter from William A. Sullivan Jr., EPA Headguarters to G.S. Blodgett International
Corp. (March 5, 1982). Concerning notice of potential liability.

Citizens Oil Company

2. Letter from Merrill S. Hohman, EPA Region I to President or General Manager, Citizens
Oil Company (May 4, 1987). Concerning notice of potential liability and a reguest for
information.

City of Burlington

3. Letter from Merrill S. Hohman, EPA Region I to Bernard Sanders, Mayor of Burlington
(May 4, 1987). Concerning notice of potential liability and a reguest for
information.
4. Letter from Paul Keough for Julie Belaga, EPA Region I to Peter A. Clavelle, Mayor of
Burlington (January 24, 1992). Concerning response to the December 6, 1991 letter
expressing concerns over delays at site.

The maps associated with entry numbers 5 and 6 may be reviewed, by appointment only, at
EPA Region 1, Boston, Massachusetts.

5. Letter from Robert F. Ramey, City of Burlington to Julie Belaga, EPA Region I (June
5, 1992). Concerning transmittal of the attached analysis and recommendation from the
Burlington Conservation Board regarding potential EPA wetlands remediation strategy.
6. Cross-Reference: Letter from Julie Belaga, EPA Region I to Robert F. Ramey, City of
Burlington (July 2, 1992). Concerning EPA's review of a containment remedial
alternative for the site which involves capping [Filed and cited as 4.1.12 in 4.1
Correspondence].
7. "Aspects of the Pine Street Barge Canal Area: Additional Information Relative to the
Supplemental Remedial Investigation (RI), Urban Storm Water Run-off, and Local
Topology," (July 14, 1992) with attached:
A. "Lake Champlain Lake Levels," (September 1976)
B. "Wiessner Property Subsurface Contamination Study," Vermont Agency of
Transportation (August 1989) .
8. Letter from Peter A. Clavelle, Mayor of Burlington to Julie Belaga, EPA Region I
(August 10, 1992). Concerning the Ultramar tank farm property.
9. Letter from Robert F. Ramey, City of Burlington to Ross Gilleland, EPA Region I
(September 1, 1992). Concerning attached comments on the August 1992 "Feasibility
Study-Like Analysis, Proposed Remedial Action Plan," PRP Technical Committee.
10. Letter from Julie Belaga, EPA Region I to Peter A. Clavelle, Mayor of Burlington
(September 11, 1992) with attached map. Concerning the Ultramar tank farm property.
11. Letter from Julie Belaga, EPA Region I to Peter A. Clavelle, Mayor of Burlington
(September 21, 1992). Concerning a proposed meeting between EPA Region I and the City
of Burlington to discuss cleanup options.
12. Letter from Peter A. Clavelle, Mayor of Burlington to Ross Gilleland, EPA Region I
(October 2, 1992). Concerning outstanding issues of remediation design between the
City and the PRP Technical Committee.

City of Burlington

13. Cross-Reference: Letter from Michael Jasinski, EPA Region I to Joseph M. Kwasnik, New
England Power Service for the PRP Technical Committee (October 2, 1992). Concerning
transmittal of the 1992 "A Stage IA Cultural Resources Survey of the Pine Street
Canal Superfund Site," John Milner Associates for Metcalf & Eddy, Inc. [Filed and
cited as entry number 31 in 11.9 PRP-Specific Correspondence].

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14. Letter from Peter A. Clavelle, Mayor of Burlington to Ross Gilleland, EPA Region I
(October 9, 1992). Concerning closure on outstanding issues raised by the City.
15. Cross-Reference: Letter from Howard Dean, Governor of Vermont and Peter Clavelle,
Mayor of Burlington to Julie Belaga, EPA Region I (October 26, 1992). Concerning the
hope that EPA will approve the PRP Technical Committee's remediation plan [Filed and
cited as entry number 4.1.14 in 4.1 Correspondence].

Davis Development Corporation

16. Letter from Merrill S. Hohman, EPA Region I to Rick Davis, Davis Development
Corporation (May 4, 1987). Concerning notice of potential liability and a reguest for
information.

Farrell, Louis, E.

17. Letter from Merrill S. Hohman, EPA Region I to Louis E. Farrell (May 4, 1987).
Concerning notice of potential liability and a reguest for information.

General Electric

18. Letter from Merrill S. Hohman, EPA Region I to President or General Manager, General
Electric (November 30, 1987). Concerning notice of potential liability, an invitation
to attend an enforcement activities meeting, and a demand for reimbursement of past
costs.

Green Mountain Power Company

19. Letter from William A. Sullivan Jr., EPA Headguarters to Green Mountain Power Company
(March 5,1982). Concerning notice of potential liability.

Maltex Partnership

20. Letter from Merrill S. Hohman, EPA Region I to The Maltex Partnership (May 4, 1987).
Concerning notice of potential liability and a reguest for information.

PRP Technical Committee

New England Power Service

21. Letter from Joseph M. Kwasnik, New England Power Service to Michael Jasinski, EPA
Region I (July 31, 1992). Concerning transmittal of the attached Letter from Sylvia
K. Lowrance, EPA Headguarters to Douglas H. Green, Piper & Marbury (June 11, 1992)
discussing guidance for application of RCRA to some remedial alternatives being
evaluated at the site.
22. "Draft - Preliminary Review of Remedial Technologies," The Johnson Company for Green
Mountain Power Corporation for the PRP Technical Committee (May 1992).
23. Letter from A. Norman Terreri, Green Mountain Power Corporation for the PRP Technical
Committee to Michael Jasinski, EPA Region I (July 21, 1992). Concerning transmittal
of the attached:
A. Letter from Sylvia K. Lowrance, EPA Headguarters to C. Richard Bozek, Edison
Electric Institute (July 1, 1992) .
B. "Attachment A - Supplemental Site Sampling and Analysis Report for the Pine
Street Canal Site," The Johnson Company for the PRP Technical Committee (July
1992) .
C. "Attachment B - Alternative Remedial Technology Identification and Screening
Report for the Pine Street Canal Site," The Johnson Company for the PRP
Technical Committee (July 1992).
24. Letter from A. Norman Terreri, Green Mountain Power Corporation for the PRP Technical
Committee to Michael Jasinski, EPA Region I (July 29, 1992). Concerning the attached
list of possible site remedies.
25. Letter from A. Norman Terreri, Green Mountain Power Corporation for the PRP Technical
Committee to Michael Jasinski, EPA Region I (August 5, 1992). Concerning transmittal
of the attached "PRP Technical Committee Proposed Remedial Plan," the PRP Technical
Committee (August 1992).
26. Letter from Gregory B. Johnson, The Johnson Company for the PRP Technical Committee
to Michael Jasinski, EPA Region I (August 10, 1992). Concerning transmittal of the
attached replacement for Figure 1 in the "PRP Technical Committee Proposed Remedial
Plan."
27. Letter from James Howley, The Johnson Company for the PRF Technical Committee to
Michael Jasinski, EPA Region I (August 10, 1992). Concerning the attached cost
estimate.
28. Letter from Gregory B. Johnson, The Johnson Company for the PRP Technical Committee
to Michael Jasinski, EPA Region I (August 12, 1992). Concerning transmittal of the
attached revised page 2 of the "PRP Technical Committee Proposed Remedial Plan."
29. Letter from A. Norman Terreri, Green Mountain Power Corporation for the PRP Technical
Committee to Ross Gilleland, EPA Region I (August 26, 1992). Concerning the attached
"Feasibility Study-Like Analysis, Proposed Remedial Action Plan," PRP Technical
Committee (August 1992).

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30. Letter from George B. Johnson, The Johnson Company for the PRP Technical Committee to
Michael Jasinski, EPA Region I (September 3, 1992). Concerning replacement of the
attached Figure 3 in the Feasibility Study-Like. Analysis report.

PRP Technical Committee

31. Letter from Michael Jasinski, EPA Region I to Joseph M. Kwasnik, New England Power
Service for the PRP Technical Committee (October 2, 1992). Concerning transmittal of
the 1992 "A Stage IA Cultural Resources Survey of the Pine Street Canal Superfund
Site," John Milner Associates for Metcalf & Eddy, Inc.

St. Johnsbury Trucking

32. Letter from Merrill S. Hohman, EPA Region I to President or General Manager, St.
Johnsbury Trucking (November 30, 1987). Concerning notice of potential liability, an
invitation to attend an enforcement activities meeting, and a demand for
reimbursement of past costs.

Ultramar Petroleum

33. Letter from Merrill S. Hohman, EPA Region I to President or General Manager, Ultramar
Petroleum (May 4, 1987). Concerning notice of potential liability and a reguest for
information.

Vermont Agency of Transportation

34. Memorandum from John H. Perkins, Vermont Agency of Transportation to File (March 17,
1992). Concerning February 21, 1992 meeting with EPA.

Vermont Development Credit Corporation

35. Letter from Merrill S. Hohman, EPA Region I to President or General Manager, Vermont
Development Credit Corporation (November 30, 1987) with attached meeting agenda.
Concerning an invitation to attend an enforcement activities meeting and a demand for
reimbursement of past costs.

Vermont Gas Works

36. Letter from William A. Sullivan Jr., EPA Headguarters to Vermont Gas Works (March 5,
1982). Concerning notice of potential liability.

E.B.& A.C. Whiting Company

37. Memorandum from John A. Malter, Vermont Department of Water Resources to Donald
Manning, Vermont Department of Water Resources (October 31, 1977). Concerning the
attached E.B. & A.C. Whiting Company Application #77-22 permit reguest.
38. Letter from Merrill S. Hohman, EPA Region I to President or General Manager, E.B. &
A.C. Whiting Company (November 30, 1987). Concerning notice of potential liability,
an invitation to attend an enforcement activities meeting, and a demand for
reimbursement of past costs.

11.11 PRP-Specific Evidence

General Electric

1. Letter from D.E. Momot, General Electric to G.A. Laraway, Army Corps of Engineers
(September 14, 1979) with attached maps. Concerning GE's proposal to remove fill.
2. Letter from G.A. Laraway, Army Corps of Engineering, D.E. Momot, General Electric
(September 18, 1879). Concerning GE's proposal to remove fill.
3. List of Spills Since August 1985 (October 29, 1987).

13.0 Community Relations

13.3 News Clippings/Press Releases

News Clippings

1. "No State Action Yet on Pine St. Toxic Wastes," Vermont Vanguard Press, Burlington,
VT (April 24-May 1, 1981).
2. "Barge Canal, Dump State's Candidates for Superfund Aid," Burlington Free Press,
Burlington, VT (July 23, 1981).
3. "$1.6 Billion War Launched on 114 Toxic Waste Sites," Burlington Free Press,
Burlington, VT (October 24, 1981).
4. "Barge Canal Listed as Hazardous Site," Burlington Free Press, Burlington, VT
(October 24, 1981).
5. "Canal Dump Dangerous Says EPA. Rutland Herald, Rutland, VT (July 30, 1982).
6. "Super Fund May Aid in Canal Cleanup," Rutland Herald, Rutland VT (July 31, 1982).
7. "Huge Amounts of Waste in Canal Dump Pose a Major Problem for Authorities," Sunday

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Rutland Herald, Barre, VT (August 1, 1982).
8. "EPA Finds Benzene in Barge Canal," Burlington Free Press, Burlington, VT (August 2,
1982) .
9. "PCB Deposit Found in Pine Street Barge Canal," Burlington Free Press, Burlington, VT
(January 19, 1983) .
10. "Water Quality Unaffected by Barge Canal's Wastes," Caledonia Record, St. Johnsbury,
VT (January 19, 1983) .
11. "Federal Agency Allots $400,000 for Barge Canal," Burlington Free Press, Burlington,
VT (March 9, 1985).
12. "Waste Cleanup Begins," Times-Argus, Barre, VT (October 1, 1985).
13. "Burlington Barge Canal Cleanup About to Begin," Burlington Free Press, Burlington,
VT (October 2, 1985).
14. "EPA Completes Initial Cleanup of Barge Canal," Burlington Free Press, Burlington, VT
(December 6, 1985).

Press Releases

15. "Environmental News -EPA Announces Public Meeting to Present Remedial Investigation
and Risk Assessment Results for the Pine Street Canal Superfund Site in Burlington,
Vermont," EPA Region I (July 1, 1992).

16.0 Natural Resource Trustee

16.4 Trustee Notification Form and Selection Guide

1. Letter from Merrill S. Hohman, EPA Region I to William Patterson, U.S. Department of
the Interior (June 1987). Concerning the attached notification form.
2. Letter from Merrill S. Hohman, EPA Region I to Sharon Christopherson, National
Oceanic and Atmospheric Administration (June 1987). Concerning the attached
notification form.

17.0 Site Management Records

17.4 Site Photographs/Maps

Site photographs and maps may be reviewed, by appointment only, at EPA Region I, Boston,
Massachusetts.

17.7 Reference Documents

1. U.S. Department of the Interior. Fish and Wildlife Service. Classification of
Wetlands and Deepwater Habitats of the United States (FWS/OBS-79/31), December 1979.
2. U.S. Department of the Interior. Fish and Wildlife Service. Habitat Suitability Index
Models: Beaver (FWS/OBS-82/10.30 Revised), April 1983.
3. U.S. Army Corps of Engineers. District, New York. Evaluation of the 1980 Capping
Operations at the Experimental Mud Dump Site. New York Bright Apex - Final Report,
(Technical Report D-83-3), October 1983.
4. "Fact Sheet: A Five-Minute Look at Section 106 Review," Advisory Council on Historic
Preservation (revised October 1984).
5. "Summary of ASTM DG38 Type IV Test - Specific Guidelines for Gundline HD Chemical
Resistance," Gundle (1984).
6. "Town Gas - An Overview," The Brooklyn Union Gas Company (May 1985).
7. U.S. Army Corps of Engineers. Waterways Experiment Station. Effectiveness of Capping
in Isolating Contaminated Dredged Material From Biota and the Overlying Water - Final
Report, (Technical Report D-85-10), November 1985.
8. U.S. Department of the Interior. Fish and Wildlife Service. Polycyclic. Aromatic
Hydrocarbon Hazards to Fish, Wildlife and Invertebrates: A Synoptic Review
(Biological Report 85(1.11)), May 1987.
9. U.S. Army Corps of Engineers. Wetlands Research Program. Wetland Evaluation Technigue
(WET) Volume II: Methodology (Operational Draft), October 1987.
10. "Co-Treatment of Manufactured Gas Plant Site Groundwaters with Municipal Wastewaters
- Final Topical Reports," Gas Research Institute (June 1987-August 1988).
11. "Fact Sheet: Working With Section 106," Advisory Council on Historic Preservation
(October 1988).
12. U.S. Army Corps of Engineers. Waterways Experiment Station. New Bedford Harbor
Superfund Project, Acushnet River Estuary Engineering Feasibility Study of Dredging
and Dredged Material Disposal Alternatives: Report 10, Evaluation of Dredging and
Dredging Control Technologies (Technical Report EL-88-15), November 1988.
13. U.S. Army Corps of Engineers. Waterways Experiment Station. New Bedford Harbor
Superfund Project. Acushnet River Estuary Engineering Feasibility Study of Dredging
and Dredged Material Disposal Alternatives: Report 11. Evaluation of Conceptual
Dredging and Disposal Alternatives (Technical Report EL-88-15), July 1989.
14. U.S. Environmental Protection Agency. Office of Research and Development.
Reguirements for Hazardous Waste Landfill Design, Construction and Closure,
(EPA/625/4-89/022), August 1989.
15. U.S. Environmental Protection Agency. Bioremediation of Contaminated Surface Soils
(EPA/600/9-89/073), August 1989.
16. U.S. Environmental Protection Agency. Seminar on Site Characterization for Subsurface

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Remediations (CERI-89-224), September 1989.
17. "Engineering-Scale Demonstration of Thermal Desorption Technology for Manufactured
Gas Plant Site Soils," Illinois Hazardous Waste Research and Information Center
(November 1989).
18. Memorandum from Henry L. Longest and Bruce M. Diamond, EPA Headguarters to Patrick M.
Tobin, EPA Region IV (June 21,1990). Concerning protective cleanup level for lead in
ground water.
19. U.S. Department of the Interior. Fish and Wildlife Service. Evaluating Soil
Contamination (Biological Report 90(2)), July 1990.
20. "MPG Update," Gas Research Institute Environment and Safety Research Department
(August 1990).
21. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Solvent Extraction Treatment (EPA/540/2-90/013), September 1990.
22. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Slurry Biodegradation (EPA/54012-90/016), September 1990.
23. U.S. Environmental Protection Agency. Office of Research and Development Soliditech.
Inc. Solidification/Stabilization Process: Applications Analysis Report
(EPA/540/A5-89/005), September 1990.
24. U.S. Environmental Protection Agency. Risk Reduction Engineering Laboratory. Chemfix
Technologies. Inc. Solidification/Stabilization Process - Volume I
(EPA/540/5-89/011a) , September 1990.
25. "Groundwater Contamination by Creosote," Waterloo Center for Groundwater Research
(November 6, 1990).

Maps associated with entry number 26 may be reviewed, by appointment only, at EPA Region
I, Boston, Massachusetts.

26. "Exxon/Flynn Avenue Terminal - An Environmental Assessment of Soils, Groundwater, and
Warehousing Facilities," Wagner, Heindel and Noyes, Inc. (February 28, 1991).
27. "MGP Update," Gas Research Institute Environment and Safety Research Department
(March 1991).
28. U.S. Environmental Protection Agency. Office of Research and Development. Dense
Nonagurous Phase-Liguids, March 1991.
29. U.S. Environmental Protection Agency. Robert S. Kerr Environmental Research
Laboratory. Dense Nonagueous-Phase Liguids--A Workshop Summary (EPA/600), April
16-18, 1991.
30. U.S. Environmental Protection Agency. Office of Research and Development. Handbook -
Remadiation of Contaminated Sediments, (EPA/625/6-911028), April 1991.
31. U.S. Envirorimental Protection Agency. Innovative Treatment Technologies: Overview
and Guide to Information Sources (EPA/540/9-91/002), October 1991.
32. Letter from Dean A. Grover, Wagner, Heindel, and Noyes, Inc. to Nancy Manley, Vermont
Agency of Natural Resources (November 19, 1991) with attached map. Concerning a
reguest for 1272 order.
33. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Superfund Innovative Technology Evaluation Program: Technology Profiles Fourth
Edition (EPA/540/5-91/008), November 1991.
34. Letter from Dean A. Grover, Wagner, Heindel, and Noyes, Inc. to Nancy Manley, Vermont
Agency of Natural Resources (December 6, 1991). Concerning the attached calculations
for the groundwater pre-treatment system.
35. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Estimating Potential for Occurrence of DNAPL at Superfund Sites (9355.4-07FS),
January 1992.
36. U.S. Environmental Protection Agency. Office of Research and Development. Dermal
Exposure Assessment: Principles and Applications-Interim Report, (EPA/600/8-91/011B),
January 1992.
37. U.S. Environmental Protection Agency. SITE Demonstration Bulletin: Slurry
Biodegradation, IT Corporation (EPA/540/M5-91/009), February 1992.
38. Memorandum from Joseph E. Shefchek, Edison Electric Institute to EEI Manufactured Gas
Plant Subcommittee and Task Force (March 18, 1992). Concerning the attached:
A. Letter from C. Richard Bozek, Edison Electric Institute to Elizabeth W.LaPointe,
EPA Headguarters (March 17, 1992). Concerning transmittal of the draft "Proposed
MGP Remediation Waste Guidance."
B . "Proposed MGP Remediation Waste Guidance."
39. U.S. Environmental Protection Agency. Office of Air Quality, Planning and Standards.
Estimation of Air Impacts for the Excavation of Contaminated Sol Air/Superfund
National Technical Guidance Study Series (EPA/450/1-92-004), March 1992.
40. Letter from Edward F. Neuhauser, Niagara Mohawk Power Corporation to Joseph M.
Kwasnik, New England Power Service (April 8, 1992). Concerning the attached "South
Glens Falls MGP Waste Disposal Site Source Removal Report Summary."
41. Memorandum from Don R. Clay, EPA Headguarters to Waste Management Division Directors,
EPA Regions I, IV, V, VII; Emergency and Remedial Response Division Director, EPA
Region II; Air and Waste Management Division Director, EPA Region II; Hazardous Waste
Management Division Directors, EPA Regions III,IV,IX; Hazardous Waste Division
Director EPA Region X; and Environmental Services Division Directors EPA Regions I,
VI, VII (May 27, 1992). Concerning considerations in groundwater remediation (OSWER
Directive 9283.1-06).
42. Utter from Brian D. Kooiker, Vermont Agency of Natural Resources to
Kenneth Vogel, Exxon Company (July 16, 1992). Concerning the attached

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                "1272 Order - Findings of Fact."
         43.     "Organic Fluid Effects on the Permeability of Soil-Bentonite Slurry Walls,"
                Jeffrey C.  Evans,  Woodward-Clyde Consultants, Hsai-Yang Fang and
                Irwin J. Kugelman, Lehigh University.

19.0   Resource  Conservation  and Recovery Act (RCRA) Records

       19.1   Correspondence

             1.   Letter from E. Michael  Thomas, Goodwin, Proctor & Hoar to Douglas Luckerman, EPA
                  Region I (June 22, 1992).  Concerning transmittal of attached map of GE Lakeside
                  Avenue Facility.
             2.   Letter from David Webster, EPA Region I to John Begin, General Electric  (July 9,
                  1992). Concerning RCRA  corrective action permit
             3.   Letter from Gary P. Kjelleren, General Electric to Douglas Luckerman, EPA Region I
                  (August 13, 1992). Concerning status of RCRA corrective action permit

       19.4   RCRA Facility Inspection Reports

             1    "Final RFA Sampling Visit  Report - General Electric Facility Burlington, Vermont -
                  RCRA  Facility Assessment," Versar, Inc.  (June 29, 1989).

       19.6   Notifications of Hazardous Waste Activity

             1    Letter from W.N. Aswad,  General Electric to Sites Notification, EPA Region  I  (June
                  1981). Concerning the attached notification form.

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ADMINISTRATIVE RECORD ADDENDUM II INDEX

for the

Pine Street Canal NPL Site

3.0 Remedial Investigation (RI)

3.2 Sampling and Analysis Work

1. Letter from Clarence A. Callahan, EPA Region IX to Susan Svirsky, EPA Region I (March
30, 1993). Concerning the results of the earthworm and amphibian (FETAX) bioassays.

3.4 Interim Deliverables

1. "Technical Memorandum No. 14 - Pine Street Canal -Supplemental RI/FS,": Metcalf &
Eddy, Inc. (November 23, 1992).

2. Quality Assurance Program Plan (QAPP) and Field Sampling Plan (FSP) addenda, Metcalf
& Eddy, Inc. (February 16, 1993).

3. "Standard Guide for Conducting the Frog Embryo Teratogenesis Assay-Xenopus (Fetax),
ASTM E 1439 91 and "Standard Procedures for the Earthworm, Eisenia Foetida Andrei
(Annelida: Oligochaeta: Lumbricidae), Artificial Soil, Acute Toxicity Bioassay,"
David C. Wilborn, ManTech Environmental Technology, Inc. (March 1992)

4. "Technical Memorandum No. 17 -Supplemental RI/FS- Analyses and Toxicity Testing
Results for Samples Collected in February, 1993, "Metcalf & Eddy, Inc. (April 1993)

3.9 Health Assessments

1. "What you need to know about toxic substances commonly found at Superfund hazardous
waste sites...ATSDR Public Health Statement PAHs," U.S. Department of Health and
Human Services. (December 1990) Concerning what PAHs are, how exposure may occur and
possible health effects, medical tests available to determine exposure, and sources
of further information.

2. "Agency for Toxic Substances and Disease Registry [ATSDR] Toxicology Profile
Information Sheet," U.S. Department of Health and Human Services. (Fall 1992)
Concerning the hazardous substances that have been found at National Priorities List
(NPL) sites, and have been ranked based on freguency of occurrence, toxicity, and
potential for human exposure.

3. ATSDR's Health Consultations on the Pine Street Canal," U.S. Department of Health and
Human Services. (February 1993) Concerning what ATSDR is, how it got involved with
the site, and ATSDR's Health Consultations.

4.0 Feasibility Study

4.5 Applicable or Relevant and Appropriate Reguirements

1. Hazardous Materials Management Division Policy to Map Class IV Ground Water Areas
(Revised), William E. Ahearn, Director (November 16, 1992).

2. Letter from David Butterfield, Chief, Resource Management Section, Water Supply
Division, Vermont Agency of Natural Resources to Interested Parties (December 9,
1992). Inviting comments on revisions to Vermont's ground water protection rule and
strategy.

3. Public Notice of Vermont Agency of Natural Resources Hearing on December 21, 1992
(undated).

4. Rationale for Reclassifying Groundwater at the Pine Street Barge Canal Site
(undated).

5. Pine Street Barge Canal Class IV Groundwater Area, by Hazardous Materials Management
Division, Vermont Department of Environmental Protection (undated). Concerning
proposal to reclassify groundwater at the Site.

9.0 State Coordination

9.1 Correspondence

1. Letter from Curt McCormack, Chair, Vermont House Committee on Natural Resources and

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Energy, to Julie Belaga, EPA Region I Regional Administrator. (November 24, 1993)
Concerning a reguest for an extension of the review period for the proposed plan for
the Pine Street Canal Superfund Site.

2. Letter from George E. Little, Chair, Vermont Senate Natural Resources and Energy
Committee and Member, Lake Champlain Management Conference, to Julie Belaga, EPA
Region I Regional Administrator. (November 27, 1993) concerning a reguest for a
postponement of the December 8, 1992 public hearing.

3. Letter from Julie Belaga, EPA Region I Regional Administrator to George E. Little,
State of Vermont. (December 22, 1992) Concerning a reguest for an extension to the
comment period and a delay in the public hearing date for the proposed cleanup plan.

4. Letter from Julie Belaga, EPA Region I Regional Administrator to Curt McCormack,
State of Vermont. (December 22, 1992) Concerning a reguest for an extension to the
comment period and a delay in the public hearing date for the proposed cleanup plan.

11.0 Potentially Responsible Party (PRP)

11.9 PRP-Specific Correspondence

City of Burlington

1. Letter from Peter Clavelle, Mayor of Burlington, to Julie Belaga, EPA Region I
Regional Administrator. (August 27, 1992) Concerning the delivery of the FS and
Proposed Plan.

2. Letter from David Webster, EPA Region I Maine and Vermont Waste Management Branch
Chief to Peter Clavelle, Mayor of Burlington. (November 18, 1992) Concerning a
reguest for an EPA representative to attend the City Council Meeting to listen to the
discussion regarding the Site.

PRP Technical Committee

1. Letter from Sheila Eckman, EPA Remedial Project Manager for Pine Street Barge Canal
Superfund Site, to Joseph M. Kwasnik, Water & Solid Waste Programs Manager for New
England Power Service Company. (November 6, 1992) concerning 2 copies of the three
(3) volume Feasibility Study Final Report for the PRP Technical Committee's use and
distribution.

2. Letter from Christopher Crandall, Vice President, The Johnson Company, Inc., to
Sheila Eckman, EPA Remedial Project Manager. (December 7, 1992). Concerning intended
sampling at the site starting on December 10, 1992.

3. Letter from Margery Adams, EPA Region I Assistant Regional Counsel, to Christopher
Crandall, The Johnson Company, Inc. (December 8, 1992) Concerning The Johnson
Company's intention to undertake subsurface sampling at the Pine Street Canal Site on
December 10, 1992.

4. Letter from Karen Krug O'Neill, Green Mountain Power Corporation, to Margery Adams,
EPA Region I Assistant Regional Counsel. (December 23, 1992). Concerning response to
Ms. Adams' December 8, 1992 letter to The Johnson Company.

5. Letter from Joseph Kwasnik, New England Power Service, to Ross Gilleland, EPA
Remedial Project Manager. (January 11, 1993). Concerning the PRPs' relationship with
EPA.

6. "Pine Street Superfund Site PRP/State/EPA/TAG meeting - 1/22/93 Notes," from Ross
Gilleland (January 24, 1993). Concerning meeting with PRP Technical Committee and
Vermont DEC.

7. Letter and attached workplan from A. Norman Terreri, Vice President, Green Mountain
Power Corporation on behalf of the PRP Technical Committee, to Sheila Eckman, EPA
Remedial Project Manager. (February 10, 1993). Concerning the PRPs Technical
Committee's intention to collect soil samples, install piezometers, and sample all
wells on the Site, beginning on February 22, 1993.

8. "Pine Street Superfund Site PRP/State/EPA/TAG meeting - 2/16/93 Notes," from Sheila
Eckman (February 20, 1993) Concerning the areas the State is working on and what the
PRPs are looking at.

9. Letter from Mary Jane O'Donnell, EPA Region I Maine and Vermont Waste Management to
A. Norman Terreri, Green Mountain Power Corporation. (February 24, 1993). Concerning
response to Mr. Terreri's February 10, 1993 letter.

10. Memorandum from Martin L. Johnson, The Johnson Company, Inc. to Pine Street Canal
Potentially Responsible Parties, Ross Gilleland - U.S. EPA, Bill Ahearn - Vermont
ANR, Lori Fisher - Lake Champlain Committee, Ken Carr - U.S. Fish and Wildlife, Al

-------
Mclntosh - Vermont Water Resources, and Lake Study Center - UVM. (March 8, 1993)
Concerning the fax transmission list of names, list of upcoming meeting involving
Pine Street, and agenda for the April 15, 1993 meeting at Green Mountain Power
headguarters.

11. Memorandum from Martin L. Johnson, The Johnson Company, Inc. to U.S. EPA, ANR, LCC,
U.S.F.W., Consultants, and PRPs. (March 18, 1993) Concerning the agenda for the March
29, 1993 scientific meeting and suggested topics for Future meetings.

12. Memorandum from Martin L. Johnson, The Johnson Company, Inc. to Pine Street Canal
Potentially Responsible Parties, Ross Gilleland - U.S. EPA, Bill Ahearn - Vermont
ANR, Lori Fisher - Lake Champlain Committee, Ken Carr - U.S. Fish and Wildlife, Al
Mclntosh - Vermont Water Resources, and Lake Study Center - UVM. (March 24, 1993)
Concerning the fax transmission list of names, and list of updated meeting involving
Pine Street.

13. Letter from Ross Gilleland, EPA Remedial Project Manager for Pine Street Barge Canal
Superfund Site, to Joseph M. Kwasnik, Water & Solid Waste Programs Manager for New
England Power Service Company. (March 25, 1993) Concerning the scheduling of upcoming
PRP Technical Committee meetings with EPA, VT ANR, PCC, and USFWS.

14. Letter from Mary Jane O'Donnell, EPA Region I Maine and Vermont Waste Management
Section Chief to A. Norman Terreri, Green Mountain Power Corporation. (March 25,
1993) Concerning the PRPs' plan to conduct sampling at the Pine Street Canal Site in
order to develop a hydrologic model of groundwater flow.

15. Letter from Ross Gilleland, EPA Remedial Project Manager for Pine Street Barge Canal
Superfund Site, to Martin L. Johnson, The Johnson Company, Inc. (March 26, 1993)
Scheduling corrections and reguests.

16. Memorandum from Stanley Corneille, Site Manager Pine street Barge Canal Superfund
Site, State of Vermont Agency of Natural Resources, to Ross Gilleland, EPA Remedial
Project Manager for Pine Street Barge Canal Superfund Site. (March 30, 1993)
Concerning the synopsis of the scientific meeting held at the Green Mountain Power
office Building on March 29, 1993.

17. Letter from Ross Gilleland, EPA Remedial Project Manager for Pine Street Barge Canal
Superfund Site, to Joseph M. Kwasnik, Water & Solid Waste Programs Manager for New
England Power service Company. (March 30, 1993) concerning a copy the Field Sampling
Plan and Quality Assurance Project Plan for the earthworm and frog embryo toxicity
testing, as reguested by Sonja Schuyler of The Johnson Company, Inc.

Southern Union

1. Letter from Merrill S. Hohman, EPA Region I Director of the Waste Management
Division, to George L. Lindemann, President of Southern Union Company. (November 24,
1992) Concerning a notice of potential liability at Pine Street Canal Superfund Site.

UGI Corporation

1. Letter from Merrill S. Huhman, EPA Region I Director of the Waste Management
Division, to James A. Sutton, President of UGI Corporation. (November 24, 1992)
Concerning a notice of potential liability at Pine Street Canal Superfund site.

Ultramar/LASMO

1. "Pine Street Superfund Site, EPA Meeting with Lasmo, March 18, 1993," from Margery
Adams, EPA Region I Assistant Regional Counsel (March 24, 1993). Concerning Lasmo's
proposal for additional studies at the Site.

2. Letter from Jerry L. Pickerill, President of LASMO America Limited, to Mr. A. Norman
Terreri, Green Mountain Power Corporation. (March 29, 1993) Concerning the PRP
Technical Committee Meeting LASMO held with EPA Region I on March 18, 1993; names,
addresses and phone numbers attached.

Whiting Company

1. Letter from Robert R. Dill to Michael Jasinski and Ross Gilleland, EPA Remedial
Project Manager for Pine Street Barge Canal Superfund Site. (July 24, 1992)
Concerning comments on the Remedial Investigation and other subjects that were
discussed at the July public meeting.
13.0 Community Relations

13.1 Correspondence
Letter from: Lori Fisher, Executive Director, Lake Champlain Committee; Ned Farguhar,
Executive Director, Vermont Natural Resources Council; Susan Alden, Natural Resources

-------
Chair, Champlain Valley League of Women Voters; Aaron J. Goldberg, Chairperson,
Burlington Conservation Board; Ray Gonda, Chair, Vermont Group Sierra Club; and Joan
Mulhern, Program Director, VPIRG, to Julie Belaga, EPA Region I Regional
Administrator. (November 19, 1992) Concerning a reguest to postpone the public
hearing on the proposed plan for the Pine Street Canal Superfund Site until April 15,
1993, and extend the comment period until May 15, 1993.

13.4 Public Meetings

1. "Minutes of Pine Street Public Meeting, November 16, 1992." Concerning the Site
history, Remedial Investigation, Risk Assessment, Feasibility Study, presentation of
EPA proposed plan, and guestions and comments from the public followed by EPA
response.

2. "6 March 1993, Pine Street Barge Canal Superfund Site Public Forum." Concerning the
outline of times, speakers and presented subjects.

3. "Pine Street Canal Superfund Site Lake Champlain Committee Public Meeting...April 6,
1993," from Sheila Eckman. (April 13, 1993) Concerning LCC's preliminary comments on
EPA's human health and ecological risk assessment.

13.7 Technical Assistance Grants

1. Letter from Julie Belaga, EPA Region I Regional Administrator to Lori Fisher,
Executive Director of the Lake Champlain Committee (LCC). (December 7, 1992)
Concerning LCC's approval for a Technical Assistance Grant.

2. Letter from Roger C. Binkerd, Vice President of aguatec, Inc. to Lori Fisher,
Executive Director of the Lake Champlain Committee (LCC). (January 12, 1993)
Concerning a proposal to be advisor to LCC on the Pine Street Barge Canal Superfund
Site.

3. Letter from Henry G. Burrell, EPA Region I Grants Information & Management Section
Chief to Lori Fisher, Executive Director of the Lake Champlain Committee (LCC).
(February 22, 1993) Concerning EPA support in the selection of aguatec, Inc. as
Technical Advisor.

4. Letter from Lori Fisher, Executive Director of the Lake Champlain Committee (LCC), to
Michael J. McGagh, EPA Region I TAG Program Manager. (August 7, 1992) Concerning
LCC's intent to apply for a Superfund Technical Assistance Grant for work an the Pine
Street Barge Canal Site.

5. "LAKE CHAMPLAIN COMMITTEE ISSUE ALERT The Barge Canal: At a Crossroads." (1993)
Concerning the background of the site, Barge Canal Chronology, LCC's role, and how
the public can become involved.

14.0 Congressional Relations

14.1 Correspondence

1. Letter from: Patrick Leahy, U.S. Senator; James Jeffords, U.S. Senator; Bernard
Sanders, U.S. Representative; Howard Dean, M. D., Governor of Vermont; and Peter
Clavelle, Mayor of Burlington, to Julie Belaga, EPA Region I Regional Administrator
to George E. Little, State of Vermont. (November 24, 1992) Concerning a reguest to
extend the public comment period until the Spring of 1993.

2. Letter from Bernard Sanders, Member of Congress of the United States House of
Representatives, Vermont, At Large, to Sheila Eckman and Ross Gilleland, EPA Remedial
Project Managers for Pine Street Barge Canal Superfund Site. (December 9, 1992)
concerning public meetings on November 16, 1993, November 23, 1993, and December 8,
1993, which raised serious concerns from area residents and business owners about the
potential for adverse effects on human health with EPA's proposed remediation plan
for Pine Street Barge Canal Superfund Site.

3. Letter from Ross Gilleland, EPA Remedial Project Manager for Pine Street Barge Canal
Superfund Site, to Jim Schumacher, Office of Congressman Bernard Sanders. (February
23, 1993) Concerning an update on the status of issues including: additional test
results, the 1990 Draft PEER Risk Assessment, listing of EPA meetings with the State
and public since November, and Upcoming Public Events.

4. "Statement of Merrill S. Hohman Director, Region I Waste Management Division United
States Environmental Protection Agency before the Natural Resources Committee Vermont
House of Representatives Montpelier, Vermont." (March 16, 1993) Concerning an
appropriate remedy and EPA procedure in arriving at the proposed plan for the Pine
Street Superfund Site in Burlington, Vermont.

-------
ADMINISTRATIVE RECORD INDEX

ADDENDUM III

for the

Pine Street Canal NPL Site

4.0 Feasibility Study (FS)

4.9 Proposed Plans for Selected Remedial Action

The Proposed Plan is located in the November 6, 1992 "Pine Street Canal NPL Site
Administrative Record Addendum I" cited as entry number 1 in 4.9 Proposed Plans for
Selected Remedial Action.

Comments (cited alphabetically)

1. Comments Dated April 29, 1993 from William E. Ahearn, Vermont Agency of Natural
Resources on the November 1992 Proposed Plan.
2. Comments Dated May 7,1993 from Katharine Palmer Antinozzi on the November 1992
Proposed Plan.

Attachments associated with entry number 3 may be reviewed, by appointment only, at the
EPA Region 1 Records Center in Boston, Massachusetts.

3. Comments Dated May 13, 1993 from Michael G. Barsotti on the November 1992 Proposed
Plan with attached:
A. "Delta Park Field Guide," Trinity College (1989)
B. "Drinking Water and Petroleum Hydrocarbon Product Contamination," Tighe & Bond,
Inc. (March 18, 1993)
C. Site photographs (March 1993)
D. "Elemental Solution," Molten Metal Technology, Inc. (1993).
4. Comments Dated February 11, 1993 from Margaret Barnes on the November 1992 Proposed
Plan.
5. Comments Dated April 20, 1993 from Alice C. Bassett on the November 1992 Proposed
Plan.
6. Comments Dated February 14, 1993 from Thomas C. Bates on the November 1992 Proposed
Plan.
7. Comments Dated December 10, 1992 from Marcel Beaudin on the November 1992 Proposed
Plan.
8. Comments Dated February 12, 1993 from Wilfred and Ann Bilodeau on the November 1992
Proposed Plan.
9. Comments Dated May 12, 1993 from Samuel A. Hartwell, G.S. Blodgett Corporation on the
November 1992 Proposed Plan.
10. Comments Dated February 12, 1993 from a Burlington Resident on the November 1992
Proposed Plan.
11. Comments Dated May 4, 1993 from City Council, City of Burlington on the November 1992
Proposed Plan.
12. Comments Dated May 17, 1993 from Peter C. Brownell, Mayor - City of Burlington on the
November 1992 Proposed Plan.
13. Comments Dated May 17, 1993 from Tom Racine, City of Burlington - Public Works on the
November 1992 Propose Plan.

4.9 Proposed Plans for Selected Remedial Action (cont'd.)

14. Comments Dated May 4, 1993 from Aaron J. Goldberg, Burlington Conservation Board on
the November 1992 Proposed Plan.
15. Comments Dated May 13, 1993 from Wayne M. Senville, Burlington Planning Commission on
the November 1992 Proposed Plan.
16. Comments Dated January 20, 1993 from Rich Newman, Burlington Transportation and
Parking Council on the November 1992 Proposed Plan.
17. Comments Dated February 16,1993 from Ernest R. Carlson on the November 1992 Proposed
Plan.
18. Comments Dated March 1, 1993 from Roland T. Limoge, Champlain Elementary School on
the November 1992 Proposed Plan.
19. Comments Dated December 10, 1992 from Charles A. Cairns, Champlain Oil Company, Inc.
on the November 1992 Proposed Plan.
20. Comments Dated February 19, 1993 from Walter D. Gundel et al, Champlain Valley
Cardiovascular Associates on the November 1992 Proposed Plan.
21. Comments Dated February, 11, 1993 from Marcella C. Chapman on the November 1992
Proposed Plan.
22. Comments Dated May 3. 1993 from Marcella C. Chapman on the November 1992 Proposed

-------
Plan.
23. Comments Dated February 12,1993 from David K. Boraker, Chromogen on the November 1992
Proposed Plan.
24. Comments Dated April 11, 1993 from Grant Crichfield on the November 1992 Proposed
Plan.
25. Comments Dated February 22, 1993 from John Cunavelis on the November 1992 Proposed
Plan.
26. Comments Dated March 5, 1993 from John Cunavelis on the November 1992 Proposed Plan.

Attachments associated with entry number 27 may be reviewed, by appointment only, at the
EPA Region 1 Records Center in Boston, Massachusetts.

27. Comments Dated April 20, 1993 from Theodore D. Trowbridge, Dehydro-Tech Corporation
on the November 1992 Proposed Plan.
A. "Carver-Greenfield Process for a Cleaner Environment," Dehydro-Tech Corporation
B. "Use of the Carver-Greenfield Process for the Cleanup of Petroleum-Contaminated
Soils," Dehydro-Tech Corporation (October 1990)
C. The Carver-Qreenfield Procgss. Dahydro-Tech Corporation - Applications Analysis
Report, U.S. Environmental Protection Agency (EPA/540/AR-92/002) August 1992
D. "The Carver-Green Process," El Digest (December 1992).
28. Comments Dated April 4,1993 from Brian Dempsey on the November 1992 Proposed Plan.
29. Comments Dated February 12,1993 from Robert and Cynthia Desseau on the November 1992
Proposed Plan.
30. Comments Dated December 10, 1992 from Maurice R. Diette on the November 1992 Proposed
Plan.
31. Comments Dated March 23, 1993 from Charles Billion Jr. on the November 1992 Proposed
Plan.
32. Comments Dated May 1, 1993 from Ann G. Dinse on the November 1992 Proposed Plan.
33. Comments Dated January 21, 1993 from Peter Collins and David Gray, Downtown
Burlington Development Association on the November 1992 Proposed Plan.
34. Comments Dated February 15, 1993 from Glenn R. Erickson on the November 1992 Proposed
Plan.
35. Comments Dated April 13, 1993 from Glenn R. Erickson on the November 1992 Proposed
Plan.
36. Comments Dated February 19, 1993 from Constance B. and Marshall H. Hall on the,
November 1992 Proposed Plan.
37. Comments Dated February 16, 1993 from R.L. Hallen on the November 1992 Proposed Plan.
38. Comments Dated May 17, 1993 from Peter R. Hannah on the November 1992 Proposed Plan.
39. Comments Dated February 11, 1993 from Eloise R. Hedbor on the November 1992 Proposed
Plan.
40. Comments Dated November 17, 1992 from Gregory S. Hennemuth on the November 1992
Proposed Plan.
41. Comments Dated February 15, 1993 from Fred G. Hill on the November 1992 Proposed
Plan.
42. Comments Dated February 15, 1993 from Frances G. Hutchison on the November 1992
Proposed Plan.
43. Comments Dated March 4, 1993 from Edward S. Irwin on the November 1992 Proposed Plan.
44. Comments Dated March 10, 1993 from Edward S. Irwin on the November 1992 Proposed
Plan.
45. Comments Dated March 25, 1993 from Edward S. Irwin on the November 1992 Proposed
Plan.

Attachment associated with entry numnber 46 may be reviewed, by appointment only, at the
EPA Region I Records Center in Boston, Massachusetts.

46. Comments Dated March 18, 1993 from Robert Warren, IWT Corporation on the November
1992 Proposed Plan with attached "Advanced Chemical Fixation."
47. Comments Dated March 28,1993 from Sally P. Johnson on the November 1992 Proposed
Plan.

Attachment associated with entry number 48 may be reviewed, by appointment only, at the
EPA Region I Records Center in Boston, Massachusetts.

48. Comments Dated December 7, 1992 from Richard H. Turnbell, Kipin Industries, Inc. on
the November 1992 Proposed Plan with attached company portfolio.
49. Comments Dated May 15, 1993 from Lori M. Fisher, Lake Champlain Committee on the
November 1992 Proposed Plan.
50. Comments Dated February 12, 1993 from Zachary Leader on the November 1992 Proposed
Plan.
51. Comments Dated May 4, 1993 from Susan Alden, League of Women Voters of the Champlain
Valley on the November 1992 Proposed Plan.
52. Comments Dated April 2, 1993 from Derek Lefebvre on the November 1992 Proposed Plan.
53. Comments Dated February 11, 1993 from Jerold F. Lucey on the November 1992 Proposed
Plan.
54. Comments Dated December 7, 1992 from Rafael Mares on the November 1992 Proposed Plan.
55. Comments Dated February 21, 1993 from Colin and Earla Sue McNaull on the November
1992 Proposed Plan.
56. Comments Dated February 12, 1993 from Rosemary O'Brien on the November 1992 Proposed

-------
Plan.
57. Comments Dated March 16, 1993 from A. Joyce Shailor, OCF Associates on the November
1992 Proposed Plan.
58. Comments Dated April 10, 1993 from A. Joyce Shailor, OCF Associates on the November
1992 Proposed Plan.
59. Comments Dated March 3, 1993 from Dan O'Connell on the November 1992 Proposed Plan.
60. Comments Dated February 14, 1993 from Stephen Page on the November 1992 Proposed
Plan.
61. Comments Dated April 29, 1993 from Pine Street Arts & Business Association on the
November 1992 Proposed Plan.
62. Comments Dated February 18, 1993 from Jacqueline Proveneker on the November 1992
Proposed Plan.
63. Comments Dated February 13, 1993 from Beatrice J. Ramsey on the November 1992
Proposed Plan.
64. Comments Dated February 12, 1993 from Dennis R. Reichardt on the November 1992
Proposed Plan.
65. Comments Dated February 18, 1993 from Eugene H. Russell on the November 1992 Proposed
Plan.
66. Comments Dated March 9, 1993 from Karle L. Snyder on the November 1992 Proposed Plan.
67. Comments Dated November 17, 1992 from Caroline Stoudt on the November 1992 Proposed
Plan.
68. Comments Dated December 10, 1992 from James Smurro on the November 1992 Proposed
Plan.
69. Comments Dated April 28, 1993 from Katherine Teetor on the November 1992 Proposed
Plan.
70. Comments Dated February 17, 1993 from Betty G. Tucker on the November 1992 Proposed
Plan.
71. Comments Dated May 14, 1993 from Christopher H. Marraro, Howrey & Simon (Attorney for
Ultamar Petroleum) on the November 1992 Proposed Plan.
72. Comments Dated January 4, 1993 from Richard J. Bartlett, University of Vermont on the
November 1992 Proposed Plan
73. Comments Dated May 4, 1993 from Richard J. Bartlett, University of Vermont on the
November 1992 Proposed Plan.
74. Comments Dated May 14,1993 from Nancy J. Hayden, University of Vermont on the
November 1992 Proposed Plan.
75. Comments Dated May 4, 1993 from Bernard Sanders, U.S. House of Representatives on the
November 1992 Proposed Plan.
76. Comments Dated May 5, 1993 from Patrick J. Leahy and James Jeffords, U.S. Senate and
Bernard Sanders U.S. House of Representatives on the November 1992 Proposed Plan.
77. Comments Dated May 14,1993 from Patrick J. Leahy, U.S. Senate on the November 1992
Proposed Plan.
78. Comments Dated December 2, 1992 from Ray Unsworth on the November 1992 Proposed Plan.
79. Comments Dated April 10, 1993 from Harry Varney Jr. on the November 1992 Proposed
Plan.
80. Comments Dated April 9, 1993 from Charles R. Ross Jr. et al, Vermont House of
Representatives on the November 1992 Proposed Plan.
81. Comments Dated April 28, 1993 from Donald M. Hooper, Vermont Secretary of State on
the November 1992 Proposed Plan.
82. Comments Dated May 14, 199 3 from Lisa Borre, Vermont Citizens Advisory Committee on
Lake Champlain's Future on the November 1992 Proposed Plan.
83. Comments Dated April 2, 1993 from Eugene Viens Sr. on the November 1992 Proposed
Plan.
84. Comments Dated May 14,1993 from Eugene Viens Sr. on the November 1991 Proposed Plan.
85. Comments Dated February 12, 1993 from Dinny Weed on the November 1992 Proposed Plan.
86. Comments Dated February 15, 1993 from Lea Wood on the November 1992 Proposed Plan.

Comments from the PRP Technical Committee

87. Comments Dated April 5, 1993 from Joseph M. Kwasnik, New England Power Service for
the PRP Technical Committee on the November 1992 Proposed Plan (Document Number One -
Evaluation of EPA's Technical Assumptions Concerning the Potential for Migration of
Free Product and Contaminated Ground Water).
88. Comments Dated May 10, 1993 from Joseph M. Kwasnik, New England Power Service for the
PRP Technical Committee on the November 1992 Proposed Plan (Document Number Two -
Evaluation of EPA's Technical Assumptions Concerning Human Health Risk Assessment).
89. Comments Dated May 10, 1993 from Joseph M. Kwasnik, New England Power Service for the
PRP Technical Committee on the November 1992 Proposed Plan (Document Number Three -
Evaluation of EPA's Technical Assumptions Concerning Ecological Preliminary
Remediation Goals).
90. Comments Dated May 10, 1993 from Joseph K Kwasnik, New England Power Service for the
PRP Technical Committee on the November 1992 Proposed Plan (Document Number Four -
Evaluation of EPA's Technical Assumptions Concerning Wetland Preservation).
91. Comments Dated May 13, 1993 from Joseph M. Kwasnik, New England Power Service for the
PRP Technical Committee on the November 1992 Proposed Plan (Document Number Five -
Evaluation of the Implementability of EPA Proposed Remedial Alternative SR-2B).
92. Comments Dated May 13,1993 from Joseph M. Kwasnik, New England Power Service for the
PRP Technical Committee on the November 1992 Proposed Plan (Document Number Six -
Evaluation of the Proposed Remedy SR-2B Against the Feasibility Study (FS) Criteria).

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             93.  Comments Dated May 13, 1993 from Joseph M. Kwasnik, New England Power Service for the
                  PRP Technical Committee on the November 1992 Proposed Plan  (Document Number Seven -
                  Summary of PRP Technical Committee Comments and Recommended Response Alternative).

             The map associated with entry number 94 is oversized and may be reviewed, by appointment
             only, at the EPA Region I Records Center in Boston, Massachusetts.

             94.  "Directed Feasibility Study Remedial Alternative SR-9," PRP Technical Committee  (May
                  14,1993).
13.0   Community  Relations

       13.4   Public Meetings
             1.   Transcript, Public Hearing on the Proposed Plan  (May 4, 1993)
                  Presenters: David Webster and Ross Gilleland, EPA Region I.
                  Commenters: William Ahearn
                             Susan Alden
                             Rich Bartlett
                             Michael Barsotti
                             Peter Brownell
                             Tom Burke
                             Sharon Bushor
                             Steve Conant
                             Peter Cook
                             Paul Cook
                             Dean Corren
                             Mark Eldridge
                             Barbara Felitti
                             Lori Fisher
                             Matthew Gardy
                             Aaron Goldberg
                             Mark Kanubluh
                             Gary Kelleren
                             Alan Quackenbush
                             Mary Sullivan
                             Karen Unsworth
                             Roger Verville
                             David Weinstein

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                                            Pine  Street Canal

                                         Administrative Record

                                              Addendum IV

                                                  Index

                                         Compiled: June 4, 1998

                                      Prepared by EPA-New England

                               Office of Site Remediation and Restoration



                                          With assistance from

                                                  ads
                                         2070 Chain Bridge Road
                                              Vienna,  VA 22182
                               ADMINISTRATIVE RECORD  INDEX
                                    PINE STREET CANAL
                                    All Operable Units

01.06         SITE ASSESSMENT  -   HAZARD RANKING SYSTEM PACKAGES

Title:        Notice  of  NPL  Site  Listing.
Authors:      ENVIRONMENTAL  PROTECTION AGENCY
Date:         July 31, 1995
Format:       MISCELLANEOUS                No.  Pgs:   2
AR No.        01.06.1                       Document No.   000360
                                                                    10/07/98
                                                                        Page
03.01

Title:
Addressee:
Authors:
Date:
Format:
AR No.

Title:
Addressee:
Authors:
Date:
Format:
AR No.

Title:
Addressee:
Authors:
Date:
Format:
AR No.

Title:
Addressee:
Authors:
Date:
Format:
AR No.

Title:
Addressee:
Authors:
Date:
REMEDIAL INVESTIGATION - CORRESPONDENCE

Fishing by Asian Community in the Pine Street Barge Canal.
PHILIP HARTER
MARTY FELDMAN - LIGHTWORKS INC.
June 3, 1994
MEMORANDUM                  No. Pgs:  1
03.01.1                      Document No.  000632

Completion of Phase I - ARI Field Work.
ROSS GILLELAND - EPA REGION I
GREGORY JOHNSON - JOHNSON COMPANY
December 16, 1994
LETTER                           No. Pgs:  2
03.01.2                          Document No.  000326

Estimate of Mass Flux of Benzene to the Lake through the  Sand Lens.
PINE ST FATE & TRANSPORT TECH WORK GROUP
SETH PITKIN - JOHNSON COMPANY
February 17, 1995
MEMORANDUM                      No. Pgs:  3
03.01.3                          Document No.  000003
Muskrat Autopsy.
ROSS GILLELAND EPA REGION I
GREGORY JOHNSON
April 24, 1995
LETTER
03.01.4
JOHNSON COMPANY

     No. Pgs:  1
      Document No.  000334
Mobilization of Phase IIA Studies by PRP's.
PINE STREET COORDINATING COUNCIL
GREGORY JOHNSON - JOHNSON COMPANY
April 25, 1995

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Format:
AR No.
MEMORANDUM
03.01.5
No. Pgs:  1
 Document No.  000335
Title:       Response  to  Greg  Johnson's April  25,  1995
               Memorandum Regarding Mobilization for the 1995 Field Season.
Addressee:   DR. MARTIN JOHNSON  -  JOHNSON  COMPANY
Authors:     SHEILA ECKMAN  - ENVIRONMENTAL PROTECTION AGENCY
Date:        May 3,  1995
Format:      LETTER                       No.  Pgs:   2
AR No.       03.01.6                      Document  No.   000453

Title:       Notice of Noncompliance.
Addressee:   DR. MARTIN JOHNSON  -  JOHNSON  COMPANY
Authors:     LINDA  MURPHY - EPA  REGION I
Date:        April  22, 1996
Format:      LETTER                       No.  Pgs:   2
AR No.       03.01.7                      Document  No.   000345

Title:       PRPs Noncompliance  in Regards to  the  Data  Validation Reguirements
Addressee:   DR. MARTIN JOHNSON         JOHNSON COMPANY
Authors:     MARY JANE 0'DONNELL       ENVIRONMENTAL PROTECTION AGENCY
Date:        April  22, 1996
Format:      LETTER                     No. Pgs:   2
AR No.       03.01.8                      Document  No.   000346

Title:       Response  to  EPA's Notice of Noncompliance.
Addressee:   LINDA  MURPHY - ENVIRONMENTAL  PROTECTION  AGENCY
Authors:     GREGORY JOHNSON - JOHNSON COMPANY
Date:        April  25, 1996
Format:      LETTER                       No.  Pgs:   2
AR No.       03.01.9                      Document  No.   000622

Title:       Urban  Runoff Report.
Addressee:   DR. MARTIN JOHNSON  -  JOHNSON  COMPANY
Authors:     SHEILA ECKMAN, ROSS GILLELAND, MARGERY ADAMS  - ENVIRONMENTAL PROTECTION AGENCY
Date:        May 1,  1996
Format:      LETTER                       No.  Pgs:   2
AR No.       03.01.10                      Document  No.   000347

Title:       EPA's  Letter Dated  May 1, 1996 Regarding the  Urban Runoff Report Data.
Addressee:   SHEILA ECKMAN  - ENVIRONMENTAL PROTECTION AGENCY
Authors:     DR. MARTIN JOHNSON  -  JOHNSON  COMPANY
Date:        May 3,  1996
Format:      LETTER                       No.  Pgs:   1
AR No.       03.01.11                      Document  No.   000348

Title:       Followup  On  EPA's Letter of April 22  Regarding the
               PRP's Noncompliance  with  Regard  to the Data Validation Reguirements.
Addressee:   DR. MARTIN JOHNSON  -  JOHNSON  COMPANY
Authors:     MARY JANE 0'DONNELL -     EPA REGION  I
Date:        May 15, 1996
Format:      LETTER                       No.  Pgs:   2
AR No.       03.01.12                      Document  No.   000312
03.02
             REMEDIAL  INVESTIGATION  -  SAMPLING & ANALYSIS  DATA
Title:       Analytical  Results  of  15  Polynuclear Aromatic
              Hydrocarbon Samples Recieved on September 20,  22,
Addressee:   CHRIS  CRANDELL  -  JOHNSON  COMPANY
Authors:      JEFFREY  CURRAN  -  IEA
Date:        October  28,  1994
Format:      SAMPLING AND ANALYSIS  DAT  No.  Pgs:  11
AR No.       03.02.1                       Document No.   000007
                                                   and  23,  1994.
Title:        Split  Sampling  Report,  December  1994, ARI  Phase  I  Summer 1994  Studies.
Addressee:    SHEILA ECKMAN - ENVIRONMENTAL  PROTECTION AGENCY
Authors:       METCALF &  EDDY
Date:         February 1995
Format:       REPORT,  STUDY                No.  Pgs:   60
AR No.        03.02.2                     Document No.   000005
Title:        Fish  Testing  of  Young  Bullheads.
Addressee:    ALAN  STRASSER -            PINE ST CANAL ECOLOGICAL WORKINGROUP
Authors:      KENNETH  CARR  - US  FISH AND WILDLIFE  SERVICE
Date:         May 26,  1995
Format:       MEMORANDUM                         No. Pgs:  1
AR No.        03.02.3                            Document No.  000008

-------
Title:       Table  of  Co-Located Metals  and  PAH  Results  for  Pine  St.
Addressee:   ROSS GILLELAND  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:      GREGORY JOHNSON - JOHNSON COMPANY
Date:        July 6, 1995
Format:      SAMPLING  AND ANALYSIS  DAT    No. Pgs:  11
AR No.       03.02.4                       Document No.   000009
Canal.
Title:       Data  Summary  for  Focus Areas  for  Toxicity  Testing
              Requested by Ken Carr during 7/10 Conference Call.
Addressee:   ECOLOGICAL WORK GROUP
Authors:      SONJA SCHUYLER  -  JOHNSON  COMPANY
Date:        July  14,  1995
Format:      SAMPLING  AND ANALYSIS DAT  No. Pgs:  7
AR No.       03.02.5                       Document No.   000010

Title:       Analytical Results  for Samples  Received  by
               Inchscape  Testing Services - Aguatech Laboratories on October 19,  1995.
Addressee:   KAREN WEDLOCK-HUNT  - METCALF  &  EDDY
Authors:      KAREN CHIRGWIN  -  INCHSCAPE  TESTING SERVICES
Date:        November  30,  1995
Format:      LETTER                       No.  Pgs:  10
AR No.       03.02.6                       Document No.   000014

Title:       Sediment  Toxicity Analyses.
Addressee:   SONJA SCHUYLER  -  JOHNSON  COMPANY
Authors:      JOHN  WILLIAMS - INCHSCAPE TESTING SERVICES
Date:        December  22,  1995
Format:      REPORT, STUDY               No. Pgs:  40
AR No.       03.02.7                     Document No.   000011

Title:       CADRE Data Review and Tier  III  Data Validation  Deliverables.
Addressee:   CHRISTINE CLARK - ENVIRONMENTAL PROTECTION AGENCY
Authors:      CONSTANCE LAPITE, DR. BRIAN TUCKER - METCALF  &  EDDY
Date:        January 29, 1996
Format:      SAMPLING  AND ANALYSIS DAT  No. Pgs:  19
AR No.       03.02.8                     Document No.   000012

Title:       Tier  III  Data Validation  on Grain Size Analytical Data .
Addressee:   CHRISTINE CLARK - ENVIRONMENTAL PROTECTION AGENCY
Authors:      CONSTANCE LAPITE, DR. BRIAN TUCKER - METCALF  &  EDDY
Date:        February  21,  1996
Format:      SAMPLING  AND ANALYSIS DAT  No. Pgs:  3
AR No.       03.02.9                       Document No.   000013

Title:       Tier  III  Validation on Inorganic  Data From 10 Low Level  Soil  and 2  Agueous  Samples.
Addressee:   CHRISTINE CLARK - ENVIRONMENTAL PROTECTION AGENCY
Authors:      MEG HIMMEL, BRUCE LIVINGSTON  -  METCALF & EDDY
Date:        February  26,  1996
Format:      SAMPLING  AND ANALYSIS DAT  No. Pgs:  10
AR No.       03.02.10                      Document No.   000015

Title:       CARDRE Data Review  and Resubmittal of the  Tier  III Data  Validation.
Addressee:   CHRISTINE CLARK - ENVIRONMENTAL PROTECTION AGENCY
Authors:      MEG HIMMEL, BRUCE LIVINGSTON  -  METCALF & EDDY
Date:        March 18, 1996
Format:      SAMPLING  AND ANALYSIS DAT    No.   Pgs:    15
AR No.       03.02.11                        Document  No.   000017
  *Attached to Document No.  000013 In  03.02

Title:       Region I  Review of  Inorganic  Contract Laboratory  Data  Package.
Addressee:   MEG HIMMEL - METCALF & EDDY
Authors:      CHESTER LABNET
Date:        March 20, 1996
Format:      SAMPLING  AND ANALYSIS DAT    No.   Pgs:    22
AR No.       03.02.12                        Document  No.   000030

Title:       Tier  III  Validation on Analytical Data from Reanalysis of  Eight  Sediment Samples.
Addressee:   CHRISTINE CLARK - ENVIRONMENTAL PROTECTION AGENCY
Authors:      MEG HIMMEL, BRUCE LIVINGSTON  -  METCALF & EDDY
Date:        March 21, 1996
Format:      SAMPLING  AND ANALYSIS DAT    No.   Pgs:    4
AR No.       03.02.13                        Document  No.   000018
  *Attached to Document No.  000013 In  03.02
Title:        Pine  Street  Biological  Samples.
Addressee:    KAREN WEDLOCK-HUNT  - METCALF  &  EDDY
Authors:      KENNETH  CARR -  US FISH  AND WILDLIFE  SERVICE
Date:         May 13,  1996

-------
Format:
AR No.
MEMORANDUM
03.02.14
No. Pgs:  8
 Document No.  000019
Title:       Review  of Metcalf and Eddy Validation Letters of  2/26/96, 3/18/96,  and  3/21/96.
Addressee:   SHEILA  ECKMAN - ENVIRONMENTAL PROTECTION AGENCY
Authors:      HUGO CAZON  - JOHNSON COMPANY
Date:        May 20,  1996
Format:      LETTER                        No. Pgs:  2
AR No.       03.02.15                      Document No.   000020

Title:       User's  Manual for the Pine Street Canal Site Database.
Addressee:   SHEILA  ECKMAN - ENVIRONMENTAL PROTECTION AGENCY
Authors:      TAMMY FORTIER - JOHNSON COMPANY
Date:        June 1996
Format:      LETTER                        No. Pgs:  20
AR No.       03.02.16                      Document No.   000265

Title:       Response to Johnson Company Review  of M & E's Validation Letters.
Addressee:   SHEILA  ECKMAN - ENVIRONMENTAL PROTECTION AGENCY
Authors:      MARTHA  ZIRBEL - METCALF & EDDY
Date:        July 1,  1996
Format:      LETTER                        No. Pgs:  4
AR No.       03.02.17                      Document No.   000021

Title:       Pine Street Canal Superfund Site, Data Validation Services.
Addressee:   CHRIS CRANDELL - JOHNSON COMPANY
Authors:      KIM WATSON  - TRILLIUM, INC.
Date:        August  1, 1996
Format:      SAMPLING AND ANALYSIS DAT    No.  Pgs:   13
AR No.       03.02.18                      Document No.   000022

Title:       Addendum to the Data Validation Report for  Pine
               Street Superfund  Site,  South Burlington, VT -metals in Soil Samples.
Addressee:   JOHNSON COMPANY
Authors:      TRILLIUM, INC.
Date:        August  7, 1996
Format:      REPORT, STUDY                No. Pgs:   14
AR No.       03.02.19                      Document No.   000023

Title:       Addendum to the Data Validation Report for  Pine Street  Superfund  Site,
               South  Burlington, VT-  Inorganic Analysis Data  -  Metals in  Soil.
Addressee:   JOHNSON COMPANY
Authors:      TRILLIUM, INC.
Date:        August  7, 1996
Format:      REPORT, STUDY                No. Pgs:   15
AR No.       03.02.20                      Document No.   000024

Title:       Addendum to the Data Validation Report for  Pine Street  Superfund  Site,
              South Burlington,  VT-Inorganic Analysis Data - Metals and Cyanide in Sediment
Addressee:   JOHNSON COMPANY
Authors:      TRILLIUM, INC.
Date:        August  7, 1996
Format:      REPORT, STUDY                No. Pgs:   15
AR No.       03.02.21                      Document No.   000025

Title:       Addendum to the Data validation Report for  Pine
               Street Superfund  Site,  South Burlington, VT
               Inorganic  Analysis  Data  - Metals  and Cyanide  in  soil.
Addressee:   JOHNSON COMPANY
Authors:      TRILLIUM, INC.
Date:        August  7, 1996
Format:      REPORT, STUDY                No. Pgs:  28
AR No.       03.02.22                           Document No.    000026

Title:       Revised Addendum to the Data Validation Report for  Pine Street  -
               Inorganic  Analysis  Data  - Metals  and Cyanide  in  Sediment.
Addressee:   JOHNSON COMPANY
Authors:      TRILLIUM, INC.
Date:        August  14,  1996
Format:      REPORT, STUDY                No. Pgs:  14
AR No.       03.02.23                      Document No.   000027
Title:       Evaluated Data  from Fish Tissue Analysis.
Addressee:   SHEILA ECKMAN - ENVIRONMENTAL PROTECTION AGENCY
Authors:      METCALF  & EDDY
Date:        September 3, 1996
Format:      LETTER                        No. Pgs:  12
AR No.       03.02.24                      Document No.   000028

-------
Title:       Review  of  Johnson Company's  Data Validation Memos
               and Comparison of  Data with Results Presented in Risk Management Database.
Addressee:   SHEILA  ECKMAN  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     MARTHA  ZIRBEL  -  METCALF  &  EDDY
Date:        October 10,  1996
Format:      LETTER                         No.  Pgs:  4
AR No.       03.02.25                       Document No.  000029
Title:       Contract  Laboratory  Status  Report.
Addressee:   ENVIRONMENTAL  PROTECTION AGENCY
Authors:      TEXAS ASM GEOCHEMICAL & ENVIRONMENTAL
Date:        October 15, 1996
Format:      SAMPLING  AND ANALYSIS DAT   No. Pgs:  17
AR No.       03.02.26                      Document No.
                                                         000031
Title:        Fish Bile Data Analysis.
Addressee:    SHEILA  ECKMAN - ENVIRONMENTAL  PROTECTION AGENCY
Authors:      BRUCE LIVINGSTON, MARTHA  ZIRBEL  - METCALF  &  EDDY
Date:         October 17,  1996
Format:       LETTER                     No. Pgs:   8
AR No.        03.02.27                     Document No.  000032

Title:        Split-Sampling Report  for the  Phase  IIB
              Additional Remedial Investigation Sampling Round-October 1995.
Addressee:    ENVIRONMENTAL PROTECTION  AGENCY
Authors:      METCALF & EDDY
Date:         December 1996
Format:       REPORT,  STUDY                No. Pgs:  68
AR No.        03.02.28                     Document No.  000033

Title:        Results of  Data Analysis  Undertaken  to Answer
              Outstanding Issues Discussed at the January 15th Meetings.
Addressee:    PINE STREET COORDINATING  COUNCIL
Authors:      CHRIS CRANDELL -  JOHNSON  COMPANY
Date:         February 24, 1997
Format:       MEMORANDUM                   No. Pgs:  18
AR No.        03.02.29                     Document No.  000034
03.03
             REMEDIAL  INVESTIGATION  -  SCOPES  OF WORK
Title:       Data Gap Analysis  and  Suggestions  For  Further   Study—Draft.
Authors:     ENVIRONMENTAL  PROTECTION AGENCY
Date:        October 13,  1993
Format:      NOTES-GENERAL                No. Pgs:   20
AR No.       03.03.1                      Document  No.  000039

Title:       Outline for  the Ecological  Scope of Work -  Draft.
Authors:     ENVIRONMENTAL  PROTECTION AGENCY
Date:        March  22,  1994
Format:      NOTES-MEETING                No. Pgs:  15
AR No.       03.03.2                      Document  No.  000035

Title:       Outline for  the Ecological  Scope of Work -  Revised  Draft.
Authors:     ENVIRONMENTAL  PROTECTION AGENCY
Date:        May 12, 1994
Format:      NOTES-MEETING                No. Pgs:  20
AR No.       03.03.3                      Document  No.  000036

Title:       Comments from  the  PRPs  on the  Draft Ecological  Statement  of Work.
Addressee:   PINE STREET  COORDINATING COUNCIL
Authors:     DANIEL FINKELSTEIN
Date:        May 12, 1994
Format:      MEMORANDUM                     No. Pgs: 7
AR No.       03.03.4                      Document  No.  000037

Title:       Comments on  the Statement of Work.
Addressee:   PHILIP HARTER
Authors:     LAPSE  TEAM
Date:        June 8, 1994
Format:      MEMORANDUM                  No. Pgs:  6
AR No.       03.03.5                      Document  No.  000170
Title:       Comments  from Respondents  on Appendix A  (Draft  #6  -  4/26/95)  -  Statement  of Work
               Additional  Remedial Investigation and Feasibility Study - Phase II.
Addressee:   PINE  STREET COORDINATING COUNCIL
Authors:     PHILIP HARTER
Date:        May 12, 1995

-------
Format:
AR No.
LIST
03.03.6
No. Pgs: 4
Document No. 000214
Title:       Comments  on  the  State  of Vermont's  Proposal  for  Fish Sampling in Pine  Street  Canal.
Addressee:   STANLEY CORNEILLE  - VT DEPT.  OF  ENVIRONMENTAL  CONSERVATION
Authors:      SONJA  SCHUYLER - JOHNSON COMPANY
Date:        May  15, 1995
Format:      LETTER                       No.  Pgs:  3
AR No.       03.03.7                       Document  No.  000038

Title:       Modifications to the SOW Developed  for the Phase II
              ARI Work Plan at the  Pine Street Canal Site.
Addressee:   SHEILA ECKMAN -  ENVIRONMENTAL PROTECTION AGENCY
Authors:      DR.  MARTIN JOHNSON - JOHNSON  COMPANY
Date:        October 9, 1995
Format:      LETTER                       No.  Pgs:  4
AR No.       03.03.8                       Document  No.  000627

Title:       Potential Additional Work Under  Administrative Order by Consent.
Addressee:   PINE STREET  COORDINATING COUNCIL
Authors:      PHILIP HARTER, ALAN STRASSER
Date:        June 3, 1996
Format:      MEMORANDUM                    No.  Pgs:  1
AR No.       03.03.9                       Document  No.  000349

Title:       SOW  for Drums Discovered at the  Pine Street  Canal  Site.
Addressee:   ROSS GILLELAND - ENVIRONMENTAL PROTECTION  AGENCY
Authors:      GREGORY JOHNSON  -  JOHNSON COMPANY
Date:        June 21,  1996
Format:      LETTER                       No.  Pgs:  2
AR No.       03.03.10                      Document  No.  000350

Title:       EPA  Comments on  SOW for Submerged Drums.
Addressee:   DR.  MARTIN JOHNSON - JOHNSON  COMPANY
Authors:      SHEILA ECKMAN -  ENVIRONMENTAL PROTECTION AGENCY
Date:        June 22,  1996
Format:      LETTER                       No.  Pgs:  2
AR No.       03.03.11                      Document  No.  000351
03.04
             REMEDIAL  INVESTIGATION  -  INTERIM DELIVERABLES
Title:        Status  Report  of  Phase  I  Submerged  Drum Investigation.
Addressee:    SHEILA  ECKMAN  - ENVIRONMENTAL  PROTECTION AGENCY
Authors:       GREGORY JOHNSON -  JOHNSON COMPANY
Date:         November 20, 1996
Format:       LETTER                       No. Pgs:  3
AR No.        03.04.1                     Document  No.  000625
03.06
             REMEDIAL  INVESTIGATION  -  REMEDIAL  INVESTIGATION  REPORTS
Title:       Disapproval  of Additional  Remedial  Investigation Report  -  May,
Addressee:   DR. MARTIN JOHNSON  -  JOHNSON  COMPANY
Authors:     SHEILA ECKMAN -  EPA REGION I
Date:        June  5,  1996
Format:      LETTER                       No.  Pgs:  1
AR No.       03.06.1                       Document  No.  000314
                                                               1996.
Title:       Comments  on  the ARI  Phase  II      Report.
Addressee:   JOHNSON COMPANY
Authors:     AL MCINTOSH, MARY WATZIN - LAPSE  TEAM
Date:        October 11,  1996
Format:      MEMORANDUM                    No.  Pgs:  10
AR No.       03.06.2                       Document No.
                                                        000040
Title:       Disapproval with Modification  Reguired  of
              Additional Remedial Investigation Report - August 1996.
Addressee:   CHRIS  CRANDELL  - JOHNSON  COMPANY
Authors:     MARY JANE  0'DONNELL  -  ENVIRONMENTAL  PROTECTION AGENCY
Date:        October  15, 1996
Format:      LETTER                      No.  Pgs: 40
AR No.       03.06.3                      Document No.  000041
Title:       Disapproval with Modifications  of ARI.
Addressee:   MARGERY ADAMS  - EPA REGION  I
Authors:      DAVID  LEDBETTER - HUNTON AND      WILLIAMS
Date:        November  14, 1996

-------
Format:
AR No.
LETTER
03.06.4
No. Pgs: 1
Document No. 000337
Title:       Comments  on  the  Pine  Street  Barge  Canal  Site
              Additional Remedial Investigation - August 1996.
Addressee:   CHRIS  CRANDELL - JOHNSON  COMPANY
Authors:     STANLEY CORNEILLE - VT  DEPT.  OF ENVIRONMENTAL  CONSERVATION
Date:        November  15,  1996
Format:      LETTER                       No. Pgs:  3
AR No.       03.06.5                       Document  No.  000042

Title:       EPA Comments  on  the Additional Remedial
              Investigation Report Dated December 19, 1996.
Addressee:   CHRIS  CRANDELL - JOHNSON  COMPANY
Authors:     SHEILA ECKMAN -  ENVIRONMENTAL PROTECTION AGENCY
Date:        January 31,  1997
Format:      LETTER                       No. Pgs:  6
AR No.       03.06.6                       Document  No.  000626

Title:       PRP Responses to Comments on Draft Revision No.2
              of the Additional Remedial Investigation Report - December 1996.
Addressee:   SHEILA ECKMAN -  ENVIRONMENTAL PROTECTION AGENCY
Authors:     CHRIS  CRANDELL - JOHNSON  COMPANY
Date:        March  14,  1997
Format:      LETTER                       No. Pgs:  15
AR No.       03.06.7                       Document  No.  000043

Title:       EPA Comments  to  the PRP Responses  to Comments  on
              Draft Revision  No. 2 of  the  Additional  Remedial  Investigation.
Addressee:   CHRIS  CRANDELL - JOHNSON  COMPANY
Authors:     SHEILA ECKMAN -  ENVIRONMENTAL PROTECTION AGENCY
Date:        March  26,  1997
Format:      LETTER                       No. Pgs:  1
AR No.       03.06.8                       Document  No.  000044

Title:       Final  Revisions  to the  PRP Responses to  Draft
              Revision No. 2  of the Additional Remedial Investigation.
Addressee:   PINE STREET  COORDINATING  COUNCIL
Authors:     CHRIS  CRANDELL - JOHNSON  COMPANY
Date:        April  10,  1997
Format:      MEMORANDUM                   No. Pgs:  4
AR No.       03.06.9                       Document  No.  000045

Title:       EPA Comments  to  PRP Responses to Comments  on  the
              Draft Revision  No. 2 of  the Additional  Remedial Investigation.
Addressee:   CHRIS  CRANDELL - JOHNSON  COMPANY
Authors:     SHEILA ECKMAN -  ENVIRONMENTAL PROTECTION AGENCY
Date:        April  14,  1997
Format:      LETTER                       No. Pgs:  1
AR No.       03.06.10                      Document  No.  000046

Title:       EPA Comments  on  the Revised  Section 8.3.1  of  the
              Draft Additional Remedial Investigation.
Addressee:   CHRIS  CRANDELL - JOHNSON  COMPANY
Authors:     SHEILA ECKMAN -  ENVIRONMENTAL PROTECTION AGENCY
Date:        May 1, 1997
Format:      LETTER                       No. Pgs:  1
AR No.       03.06.11                      Document  No.  000047

Title:       Additional Remedial Investigation  - Volume I  Report  -  Draft Final  Revision No.  3.
Addressee:   ENVIRONMENTAL PROTECTION  AGENCY
Authors:     JOHNSON COMPANY
Date:        July 3, 1997
Format:      REPORT, STUDY                No. Pgs:  436
AR No.       03.06.12                      Document  No.  000260

Title:       Additional Remedial Investigation  - Volume II  -
              Figures and  Plates - Draft Final Revision No. 3.
Addressee:   ENVIRONMENTAL PROTECTION  AGENCY
Authors:     JOHNSON COMPANY
Date:        July 3, 1997
Format:      REPORT, STUDY                No. Pgs:  235
AR No.       03.06.13                      Document  No.  000261
Title:       Additional  Remedial  Investigation  - Volume  III  - Appendices  -  Draft  Final  Revision No.  3.
Addressee:   ENVIRONMENTAL  PROTECTION AGENCY
Authors:      JOHNSON  COMPANY
Date:        July  3,  1997

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Format:
AR No.
REPORT,  STUDY
03.06.14
No. Pgs: 867
Document No. 000262
Title:       Additional  Remedial  Investigation  - Volume  IV - Appendices  -  Draft  Final  Revision No.  3.
Addressee:   ENVIRONMENTAL  PROTECTION AGENCY
Authors:      JOHNSON  COMPANY
Date:        July  3,  1997
Format:      REPORT,  STUDY                 No. Pgs:  953
AR No.       03.06.15                      Document  No. 000263
03.07
             REMEDIAL  INVESTIGATION  - WORK PLANS AND  PROGRESS  REPORTS
Title:        Standard  Operating  Procedure  for  Sediment  and Sludge  Sampling.
Addressee:    ENVIRONMENTAL  PROTECTION AGENCY
Authors:       JOHNSON COMPANY
Date:         October 1990
Format:       REPORT, STUDY                 No.  Pgs:  24
AR No.        03.07.1                       Document  No.  000049

Title:        Final  Report,  Determination of Analytical  Methods  for PAHs.
Addressee:    ANGELO CARASEA -  ENVIRONMENTAL PROTECTION  AGENCY
Authors:       MICHAEL ZIMMERMAN -  ICF TECHNOLOGY
Date:         January 28, 1994
Format:       REPORT, STUDY                 No.  Pgs:  26
AR No.        03.07.2                       Document  No.  000050

Title:        Monthly Progress  Report for Phase I ARI Studies -  July 1994.
Addressee:    ROSS GILLELAND -  ENVIRONMENTAL PROTECTION  AGENCY
Authors:       CHRIS  CRANDELL -  JOHNSON COMPANY
Date:         July 1994
Format:       REPORT, STUDY                 No.  Pgs:   2
AR No.        03.07.3                       Document  No.  000057

Title:        Response  to Johnson  Company's Letter Reguesting
              Approval to Send Samples from the Site to QUANTIX.
Addressee:    DR. MARTIN JOHNSON  - JOHNSON  COMPANY
Authors:       JEFF PADGETT - ENVIRONMENTAL  PROTECTION AGENCY
Date:         July 26,  1994
Format:       LETTER                       No.  Pgs:  3
AR No.        03.07.4                       Document  No.  000002

Title:        Partial Approval  with Conditions  of Phase  I ARI Work  Plan—Mobilization.
Addressee:    DR. MARTIN JOHNSON  - JOHNSON  COMPANY
Authors:       MARY JANE 0'DONNELL  - ENVIRONMENTAL PROTECTION AGENCY
Date:         July 26,  1994
Format:       LETTER                       No.  Pgs:  10
AR No.        03.07.5                       Document  No.  000054

Title:        Monthly Progress  Report for Phase I ARI Studies -
              August 1994,  Minutes  for the Monthly  Progress Meeting.
Addressee:    ROSS GILLELAND -  EPA REGION I
Authors:       CHRIS  CRANDELL -  JOHNSON COMPANY
Date:         August 1994
Format:       LETTER                       No.  Pgs:   6
AR No.        03.07.6                       Document  No.  000207

Title:        Partial Approval  with Conditions  of Phase  I ARI
              Work  Plan Activities  - Comments/Conditions Set #2.
Addressee:    DR. MARTIN JOHNSON  - JOHNSON  COMPANY
Authors:       MARY JANE 0'DONNELL  - ENVIRONMENTAL PROTECTION AGENCY
Date:         August 10, 1994
Format:       LETTER                       No.  Pgs:  17
AR No.        03.07.7                       Document  No.  000056

Title:        Use of Quantix Immunoassay Methodology at  Pine
              Street Barge Canal  Superfund Site.
Addressee:    ROSS GILLELAND -  ENVIRONMENTAL PROTECTION  AGENCY
Authors:       SONJA  SCHUYLER -  JOHNSON COMPANY
Date:         August 12, 1994
Format:       LETTER                       No.  Pgs:  13
AR No.        03.07.8                       Document  No.  000629
Title:       Response  to  the  Comments/Conditions  Set  #  2.
Addressee:   ROSS  GILLELAND - EPA REGION  I
Authors:     CHRIS  CRANDELL - JOHNSON  COMPANY
Date:        August 17, 1994
Format:      LETTER                      No.  Pgs:  7

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AR No.
              03.07.9
                                           Document  No.  000333
Title:       Response  to  the  Comments/Conditions  Set  #  2.
Addressee:   ROSS  GILLELAND - EPA REGION  I
Authors:     CHRIS  CRANDELL - JOHNSON  COMPANY
Date:        August 19, 1994
Format:      LETTER                      No.  Pgs:  37
AR No.       03.07.10                     Document  No.  000332

Title:       Partial Approval of  Phase I  ARI Work Plan—Procedures  for  Field Data Collection of
              Storm Water Sediment Investigations and Preliminary Air Assessment.
Addressee:   DR. MARTIN JOHNSON - JOHNSON COMPANY
Authors:     MARY  JANE 0'DONNELL  - ENVIRONMENTAL  PROTECTION AGENCY
Date:        August 30, 1994
Format:      LETTER                      No.  Pgs:  3
AR No.       03.07.11                     Document  No.  000058

Title:       Monthly Progress Report for  Phase I  ARI  Studies -  September  1994.
Addressee:   ROSS  GILLELAND - ENVIRONMENTAL PROTECTION  AGENCY
Authors:     CHRIS  CRANDELL - JOHNSON  COMPANY
Date:        September 1994
Format:      REPORT, STUDY                No.  Pgs:  5
AR No.       03.07.12                     Document  No.  000060

Title:       Partial Approval with Conditions  of  Preliminary
              Air Assessment  Portions  of  Phase  I ARI Work Plan.
Addressee:   DR. MARTIN JOHNSON - JOHNSON COMPANY
Authors:     MARY  JANE 0'DONNELL  - ENVIRONMENTAL  PROTECTION AGENCY
Date:        September 1, 1994
Format:      LETTER                      No.  Pgs:  5
AR No.       03.07.13                     Document  No.  000055

Title:       Comments  on  Certain  Activities in the  Phase  I  Work Plan.
Addressee:   DR. MARTIN JOHNSON - JOHNSON COMPANY
Authors:     MARY  JANE 0'DONNELL  - ENVIRONMENTAL  PROTECTION AGENCY
Date:        September 2, 1994
Format:      LETTER                      No. Pgs: 14
AR No.       03.07.14                     Document  No.  000052

Title:       Response  to  the  Comments/Conditions  Sets #3  and
              #4 of the Draft ARI Phase I Work  Plan Documents.
Addressee:   ROSS  GILLELAND - ENVIRONMENTAL PROTECTION  AGENCY
Authors:     CHRIS  CRANDELL - JOHNSON  COMPANY
Date:        September 13, 1994
Format:      LETTER                      No.  Pgs:  32
AR No.       03.07.15                     Document  No.  000053

Title:       Field  Operations Plan, Revision 1, Draft Additional Remedial Investigation Phase I.
Addressee:   ROSS  GILLELAND - ENVIRONMENTAL PROTECTION  AGENCY
Authors:     CHRIS  CRANDELL - JOHNSON  COMPANY
Date:        September 20, 1994
Format:      REPORT, STUDY                No.  Pgs:  46
AR No.       03.07.16                     Document  No.  000630

Title:       Monthly Progress Report for  Phase I  ARI  Studes -  October 1994.
Addressee:   ROSS  GILLELAND - ENVIRONMENTAL PROTECTION  AGENCY
Authors:     CHRIS  CRANDELL - JOHNSON  COMPANY
Date:        October 1994
Format:      REPORT, STUDY                No.  Pgs:  30
AR No.       03.07.17                     Document  No.  000063

Title:       Full Approval of Phase I  ARI Work Plan.
Addressee:   DR. MARTIN JOHNSON - JOHNSON COMPANY
Authors:     MARY  JANE 0'DONNELL  - ENVIRONMENTAL  PROTECTION AGENCY
Date:        October 12,  1994
Format:      LETTER                      No.  Pgs:  11
AR No.       03.07.18                     Document  No.  000059

Title:       Comments  on  the  Stormwater Inlet  Sampling  Plan.
Addressee:   SHEILA ECKMAN -  ENVIRONMENTAL PROTECTION AGENCY
Authors:     AL MCINTOSH  - UNIVERSITY  OF  VERMONT
Date:        October 21,  1994
Format:      MEMORANDUM                   No.  Pgs:  1
AR No.       03.07.19                     Document  No.  000191
Title:       Response  to  Comments/Conditions  Set  #5,  Phase  I ARI Work  Plan.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL PROTECTION AGENCY
Authors:     CHRIS  CRANDELL  -  JOHNSON  COMPANY

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Date:
Format:
AR No.
October 28,
LETTER
03.07.20
                          1994
No. Pgs: 9
Document No. 000061
Title:       Monthly  Progress  Report  for  Phase  I ARI  Studies  -  November  1994.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     CHRIS CRANDELL  -  JOHNSON COMPANY
Date:        November 1994
Format:      REPORT,  STUDY                 No. Pgs:  26
AR No.       03.07.21                     Document  No. 000064

Title:       Phase I  Additional  Remedial  Investigation
              Groundwater Sampling Methodology at the Pine Street Canal Site.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     SETH  PITKIN  - JOHNSON COMPANY
Date:        November 1,  1994
Format:      LETTER                        No. Pgs:  4
AR No.       03.07.22                     Document  No. 000062

Title:       Issues Pertaining to Field Work Associated  with
              the Pine Street Barge Canal  Superfund Site Phase  I ARI.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     CHRIS CRANDELL  -  JOHNSON COMPANY
Date:        November 18, 1994
Format:      LETTER                        No. Pgs:  3
AR No.       03.07.23                     Document  No. 000628

Title:       Monthly  Progress  Report  for  Phase  I ARI  Studies  -  December  1994.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     CHRIS CRANDELL  -  JOHNSON COMPANY
Date:        December 1994
Format:      REPORT,  STUDY                 No. Pgs:  4
AR No.       03.07.24                     Document  No. 000066

Title:       Completion of Phase I ARI Field Work.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     GREGORY  JOHNSON - JOHNSON COMPANY
Date:        December 16, 1994
Format:      LETTER                        No. Pgs:  2
AR No.       03.07.25                     Document  No. 000065

Title:       Monthly  Progress  Report  for  Phase  I ARI  Studies  -  January 1995.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     CHRIS CRANDELL  -  JOHNSON COMPANY
Date:        January  1995
Format:      REPORT,  STUDY                 No. Pgs:  2
AR No.       03.07.26                     Document  No. 000051

Title:       Monthly  Progress  Report  for  Phase  I ARI  Studies  -  February  1995.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     CHRIS CRANDELL  -  JOHNSON COMPANY
Date:        February 1995
Format:      REPORT,  STUDY                 No. Pgs:  2
AR No.       03.07.27                     Document  No. 000067

Title:       Working  Paper on  Alternative Approach  to Toxicity  Testing.
Addressee:   SUSAN SVIRSKY - EPA REGION I
Authors:     AL MCINTOSH, MARY WATZIN - UNIVERSITY  OF VERMONT
Date:        March 22, 1995
Format:      MEMORANDUM                    No. Pgs:  3
AR No.       03.07.28                     Document  No. 000257

Title:       Monthly  Progress  Report  for  Phase  I ARI  Studies  -  April  1995.
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:     GREGORY  JOHNSON -          JOHNSON COMPANY
Date:        April 1995
Format:      REPORT,  STUDY                 No. Pgs:  1
AR No.       03.07.29                     Document  No. 000208

Title:       Fish  Sampling and Analysis.
Addressee:   PINE  STREET  COORDINATING COUNCIL
Authors:     STANLEY  CORNEILLE - VT DEPT.  OF ENVIRONMENTAL CONSERVATION
Date:        April 21, 1995
Format:      MEMORANDUM                    No. Pgs:  3
AR No.       03.07.30                     Document  No. 000068
Title:
Addressee:
Monthly Progress Report for Phase IIA ARI Studies - May 1995.
ROSS GILLELAND - ENVIRONMENTAL PROTECTION AGENCY

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Authors:      GREGORY  JOHNSON  -  JOHNSON  COMPANY
Date:        May  1995
Format:      REPORT,  STUDY                 No. Pgs:   2
AR No.       03.07.31                     Document No.  000075

Title:       EPA's Comments on  Vermont's  Proposal for  Fish  Sampling.
Addressee:   STANLEY  CORNEILLE  - VT  DEPT.  OF ENVIRONMENTAL  CONSERVATION
Authors:      SHEILA ECKMAN -  EPA REGION I
Date:        May  1, 1995
Format:      LETTER                        No. Pgs:   2
AR No.       03.07.32                      Document  No.  000069

Title:       EPA  Comments on  Phase IIA  Work Plan.
Addressee:   DR.  MARTIN JOHNSON - JOHNSON COMPANY
Authors:      SHEILA ECKMAN -  ENVIRONMENTAL PROTECTION  AGENCY
Date:        May  4, 1995
Format:      LETTER                        No. Pgs:   2
AR No.       03.07.33                      Document  No.  000070

Title:       Review of Avian  Dietary Study Work  Plan and  Phase  II  -  Ecological  Statement  of Work.
Addressee:   ROSS GILLELAND - ENVIRONMENTAL PROTECTION AGENCY
Authors:      AL MCINTOSH, MARY  WATZIN - UNIVERSITY  OF  VERMONT
Date:        May  10,  1995
Format:      MEMORANDUM                    No. Pgs:   2
AR No.       03.07.34                     Document No.  000071

Title:       Response to Comments Received from  EPA on Avian Dietary Study.
Addressee:   SHEILA ECKMAN -  ENVIRONMENTAL PROTECTION  AGENCY
Authors:      GREGORY  JOHNSON  -  JOHNSON  COMPANY
Date:        May  19,  1995
Format:      LETTER                        No. Pgs:   2
AR No.       03.07.35                      Document  No.  000073

Title:       Letter Concerning  Format for Work Plan -  Phase IIB.
Addressee:   SHEILA ECKMAN -  ENVIRONMENTAL PROTECTION  AGENCY
Authors:      GREGORY  JOHNSON  -          JOHNSON COMPANY
Date:        May  19,  1995
Format:      LETTER                        No. Pgs:   1
AR No.       03.07.36                      Document  No.  000074

Title:       Monthly  Progress Report for  Phase IIA  ARI  Studies  - June 1995.
Addressee:   ROSS GILLELAND - ENVIRONMENTAL PROTECTION AGENCY
Authors:      GREGORY  JOHNSON  -  JOHNSON  COMPANY
Date:        June 1995
Format:      REPORT,  STUDY                 No. Pgs:   2
AR No.       03.07.37                      Document  No.  000079

Title:       Additional Remedial Investigation,  Draft  Phase
              IIB Work Plan,   Pine Street Canal Site, Burlington, VT.
Addressee:   ENVIRONMENTAL PROTECTION AGENCY
Authors:      JOHNSON  COMPANY
Date:        June 30, 1995
Format:      WORK PLAN                     No. Pgs:  76
AR No.       03.07.38                      Document  No.  000076

Title:       Comments on the  Johnson Co.  Suggestions for  Toxicity  Test Sites.
Addressee:   ROSS GILLELAND - EPA REGION  I
Authors:      AL MCINTOSH - UNIVERSITY OF  VERMONT
Date:        June 30, 1995
Format:      MEMORANDUM                    No. Pgs:   2
AR No.       03.07.39                      Document  No.  000223

Title:       Monthly  Progress Report for  Phase IIA  ARI  Studies  - July 1995.
Addressee:   ROSS GILLELAND - ENVIRONMENTAL PROTECTION AGENCY
Authors:      CHRIS CRANDELL - JOHNSON COMPANY
Date:        July 1995
Format:      REPORT,  STUDY                 No. Pgs:   2
AR No.       03.07.40                      Document  No.  000089

Title:       Approval of Phase  IIA Work Plan.
Addressee:   DR.  MARTIN JOHNSON - JOHNSON COMPANY
Authors:      MARY JANE 0'DONNELL - ENVIRONMENTAL PROTECTION AGENCY
Date:        July 6,  1995
Format:      LETTER                        No. Pgs:   2
AR No.       03.  07.41                    Document No.  000078
Title:
Addressee:
Letter Approving Phase IIA Additional Remedial Investigation Work Plan with Conditions
DR. MARTIN JOHNSON - JOHNSON COMPANY

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Authors:     MARY  JANE  0'DONNELL  -  EPA REGION  I
Date:        July  6,  1995
Format:      LETTER                        No.  Pgs:   2
AR No.       03.07.42                      Document  No.  000591

Title:       Sampling Locations for Toxicity Tests.
Addressee:   ECOLOGICAL WORK GROUP
Authors:     SHEILA  ECKMAN,  SUSAN SVIRSKY  - EPA  REGION  I
Date:        July  11, 1995
Format:      MEMORANDUM                   No.  Pgs:   2
AR No.       03.07.43                      Document  No.  000225

Title:       Comments on  the Selection of  Sample Sites  for  Toxicity Testing.
Addressee:   SHEILA  ECKMAN  - EPA  REGION I
Authors:     KENNETH CARR -  US DEPARTMENT  OF INTERIOR
Date:        July  12, 1995
Format:      LETTER                        No.  Pgs:   3
AR No.       03.07.44                      Document  No.  000224

Title:       Biotoxicity  Method Summaries  for  Toxicity  Evaluations.
Addressee:   SONJA SCHUYLER  - JOHNSON  COMPANY
Authors:     JOHN  WILLIAMS  - INCHSCAPE TESTING SERVICES
Date:        July  14, 1995
Format:      REPORT, STUDY                 No.  Pgs:  24
AR No.       03.07.45                      Document  No.  000080

Title:       Review  Comments--Additional Remedial  Investigation Phase  IIB Work Plan.
Addressee:   SHEILA  ECKMAN  - ENVIRONMENTAL PROTECTION AGENCY
Authors:     METCALF &  EDDY
Date:        July  20, 1995
Format:      MEMORANDUM                   No.  Pgs:   5
AR No.       03.07.46                      Document  No.  000081

Title:       Comments on  the Phase  IIB Workplan.
Addressee:   SHEILA  ECKMAN  - ENVIRONMENTAL PROTECTION AGENCY
Authors:     STANLEY CORNEILLE -  VT DEPT.  OF ENVIRONMENTAL  CONSERVATION
Date:        July  25, 1995
Format:      LETTER                        No.  Pgs:   2
AR No.       03.07.47                      Document  No.  000083

Title:       Disapproval  of  Phase IIB  Work Plan.
Addressee:   DR. MARTIN JOHNSON         -  JOHNSON COMPANY
Authors:     MARY  JANE  0'DONNELL  -  ENVIRONMENTAL PROTECTION AGENCY
Date:        July  27, 1995
Format:      LETTER                        No.  Pgs:   7
AR No.       03.07.48                      Document  No.  000084

Title:       Review  of  Protocols  from  Inchscape  Testing Services.
Addressee:   SHEILA  ECKMAN  - ENVIRONMENTAL PROTECTION AGENCY
Authors:     AL MCINTOSH, MARY WATZIN  - UNIVERSITY  OF VERMONT
Date:        July  27, 1995
Format:      MEMORANDUM                   No.  Pgs:   1
AR No.       03.07.49                      Document  No.  000085

Title:       Phase IIB  Sediment and Toxicity Tests—Areas for  Discussion.
Date:        July  27, 1995
Format:      NOTES-GENERAL                     No.  Pgs:  3
AR No.       03.07.50                          Document  No.  000218

Title:       Comments Regarding the Biomarker  Study.
Addressee:   SONJA SCHUYLER  - JOHNSON  COMPANY
Authors:     AL MCINTOSH, MARY WATZIN  - UNIVERSITY  OF VERMONT
Date:        July  31, 1995
Format:      MEMORANDUM                       No.  Pgs:  2
AR No.       03.07.51                          Document  No.  000086

Title:       Monthly Progress Report for Phase IIA  and  B ARI Studies - August 1995.
Addressee:   ROSS  GILLELAND  - ENVIRONMENTAL PROTECTION  AGENCY
Authors:     GREGORY JOHNSON - JOHNSON COMPANY
Date:        August  1995
Format:      REPORT, STUDY                     No.  Pgs:  2
AR No.       03.07.52                          Document  No.  000094
Title:        Schedule  for  Resubmittal  of  Phase  IIB Work  Plan.
Addressee:    DR. MARTIN  JOHNSON  -  JOHNSON COMPANY
Authors:      SHEILA ECKMAN -  EPA REGION I
Date:         August 2, 1995
Format:       LETTER                          No. Pgs: 1

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AR No.
              03.07.53
                                               Document No.  000320
Title:       Technical Memorandum—Review  Comments--Biotoxicity Method  Summaries
              for Toxicity Evaluations.
Addressee:   ENVIRONMENTAL PROTECTION  AGENCY
Authors:      METCALF  & EDDY
Date:        August 3, 1995
Format:      MEMORANDUM                        No.  Pgs:  3
AR No.       03.07.54                          Document  No.000087
Title:       Comments  on  Fish  Biomarker  Study  Protocols.
Addressee:   GREGORY JOHNSON -  JOHNSON COMPANY
Authors:     SHEILA ECKMAN  - EPA REGION  I
Date:        August 3,  1995
Format:      MEMORANDUM                        No.  Pgs:  1
AR No.       03.07.55                           Document  No.
                                                              000319
Title:       Review  of Biotoxicity Method  Summaries  (Standard
              Test Conditions and Procedures) for Toxicity Evaluations.
Addressee:   SHEILA  ECKMAN  - ENVIRONMENTAL PROTECTION AGENCY
Authors:     PATTI LYNNE TYLER  - ENVIRONMENTAL  PROTECTION AGENCY
Date:        August  9, 1995
Format:      MEMORANDUM                          No. Pgs: 5
AR No.       03.07.56                            Document No.  000088

Title:       EPA Comments on Biotoxicity Method Summaries
              (Standard Test Conditions and Procedures)  for Toxicity Evaluations.
Addressee:   DR. MARTIN JOHNSON - JOHNSON  COMPANY
Authors:     MARY JANE 0'DONNELL - EPA REGION I
Date:        August  21, 1995
Format:      LETTER                              No. Pgs: 5
AR No.       03.07.57                            Document No.  000219

Title:       Approval of Phase  IIB Work Plan -  Part  I.
Addressee:   DR. MARTIN JOHNSON - JOHNSON  COMPANY
Authors:     MARY JANE 0'DONNELL - EPA REGION I
Date:        August  21, 1995
Format:      LETTER                              No. Pgs: 1
AR No.       03.07.58                            Document No.  000318

Title:       Toxicity Test  Sample Location Revisions.
Addressee:   ECOLOGICAL WORK GROUP
Authors:     SONJA SCHUYLER - JOHNSON  COMPANY
Date:        August  28, 1995
Format:      SAMPLING AND ANALYSIS DAT         No. Pgs:  11
AR No.       03.07.59                            Document No.  000090

Title:       Final Sampling and Analysis Plan,  Pine  Street Canal  Site,  Burlington, VT.
Addressee:   ENVIRONMENTAL  PROTECTION  AGENCY
Authors:     METCALF & EDDY
Date:        September 1995
Format:      REPORT, STUDY                       No. Pgs: 141
AR No.       03.07.60                            Document No.  000092

Title:       Monthly Progress Report for Phase  IIA and  IIB ARI  and  the  AFS  -  September  1995.
Addressee:   ROSS GILLELAND - EPA REGION I
Authors:     CHRIS CRANDELL - JOHNSON  COMPANY
Date:        September 1995
Format:      REPORT, STUDY                       No. Pgs: 2
AR No.       03.07.61                            Document No.  000317
Title:       Toxicity Testing.
Addressee:   ECOLOGICAL WORK GROUP
Authors:      SONJA  SCHUYLER -  JOHNSON  COMPANY
Date:        September 12, 1995
Format:      MEMORANDUM
AR No.       03.07.62
No. Pgs: 6
 Document No. 000093
Title:       Toxicity Testing  Proposal.
Addressee:   PINE  STREET COORDINATING  COUNCIL
Authors:     PHILIP HARTER, ALAN  STRASSER
Date:        September  21,  1995
Format:       MEMORANDUM
AR No.       03.07.63
 No. Pgs: 9
 Document No. 000173
Title:       Comments  on  the Draft  Post-Screening  Field
              Investigation Work Plan and the ARI Phase IIB Work Plan.
Addressee:   CHRIS CRANDELL -  JOHNSON COMPANY

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Authors:      STANLEY  CORNEILLE  - VT  DEPT.
Date:         September  29,  1995
Format:       LETTER
AR No.        03.07.64
                                           OF  ENVIRONMENTAL  CONSERVATION
                                    No. Pgs: 2
                                    Document No.
                                                               000091
Title:       Monthly  Progress  Report  for  Phase  IIA and  IIB ARI  and the AFS  -  October 1995.
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:      GREGORY  JOHNSON - JOHNSON  COMPANY
Date:        October  1995
Format:      REPORT,  STUDY                        No.  Pgs: 2
AR No.       03.07.65                             Document No.  000316

Title:       Approval  of Phase IIB Work Plan.
Addressee:   DR. MARTIN JOHNSON - JOHNSON COMPANY
Authors:      MARY  JANE 0'DONNELL - ENVIRONMENTAL  PROTECTION AGENCY
Date:        October  3, 1995
Format:      LETTER                               No.  Pgs: 2
AR No.       03.07.66                             Document No.  000095

Title:       Monthly  Progress  Report  for  Phase  IIA and  IIB ARI  and the AFS  -  November 1995.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION  AGENCY
Authors:      GREGORY  JOHNSON - JOHNSON  COMPANY
Date:        November  1995
Format:      REPORT,  STUDY                        No.  Pgs: 2
AR No.       03.07.67                             Document No.  000098

Title:       Monthly  Progress  Report  for  Phase  IIA and  IIB ARI  and the AFS  -  December 1995.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION  AGENCY
Authors:      GREGORY  JOHNSON - JOHNSON  COMPANY
Date:        December  1995
Format:      REPORT,  STUDY                        No.  Pgs: 2
AR No.       03.07.68                             Document No.  000101

Title:       Pine  Street Canal Work Plan  for Supplemental
              Baseline Ecological  Risk Assessment  - 2nd Draft.
Authors:      ENVIRONMENTAL PROTECTION AGENCY
Date:        December  4, 1995
Format:      WORK  PLAN                            No. Pgs: 11
AR No.       03.07.69                             Document No.  000096
Title:        Pine  Street  Canal Work  Plan  for  Supplemental
              Baseline Ecological Risk Assessment  (Attachments A & B)
Authors:      ENVIRONMENTAL  PROTECTION AGENCY
Date:         December  4,  1995
Format:       WORK  PLAN                            No.  Pgs:  105
AR No.        03.07.70                             Document  No.  000097
                                                         - 2nd Draft.
Title:       Comments  on Work  Plan  for  Supplemental  Baseline  Risk  Assessment  -  Draft.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     CHRIS  CRANDELL  -  JOHNSON COMPANY
Date:        December  4, 1995
Format:      LETTER                              No.  Pgs:  5
AR No.       03.07.71                             Document  No.  000100

Title:       Comments  on Supplemental Baseline  Ecological  Risk Assessment  - Draft.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     LAPSE  TEAM
Date:        December  19,  1995
Format:      MEMORANDUM                           No.  Pgs:  1
AR No.       03.07.72                             Document  No.  000099

Title:       Monthly Progress  Report for  Phase  IIA and IIB ARI and the AFS -  January 1996.
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:     GREGORY JOHNSON -  JOHNSON  COMPANY
Date:        January 1996
Format:      REPORT, STUDY                        No. Pgs: 2
AR No.       03.07.73                              Document No. 000309

Title:       Draft  Agenda  for  Ecological  Work Group  Meeting and  Draft Response  to Comments  Received
              on the Supplemental Baseline Ecological Risk Assessment.
Addressee:   PHILIP HARTER - PINE ST CANAL ECOLOGICAL WORKINGROUP
Authors:     SHEILA ECKMAN,  SUSAN SVIRSKY -  ENVIRONMENTAL  PROTECTION AGENCY
Date:        January 18, 1996
Format:      LETTER                               No. Pgs: 8
AR No.       03.07.74                              Document No. 000102
Title:
Addressee:
Reguest for Comments on the Ecological Risk Assessment Work Plan.
STANLEY CORNEILLE - VT DEPT. OF ENVIRONMENTAL CONSERVATION

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Authors:      SHEILA  ECKMAN  - EPA  REGION  I
Date:         January 25,  1996
Format:       LETTER
AR No.        03.07.75
No. Pgs:
Document No. 000315
Title:       Monthly  Progress  Report  for  Phase  IIA and  IIB ARI  and  the AFS  -  February  1996.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION  AGENCY
Authors:      GREGORY  JOHNSON -  JOHNSON  COMPANY
Date:        February 1996
Format:      REPORT,  STUDY                          No.  Pgs:  2
AR No.       03.07.76                              Document  No.  000103

Title:       Monthly  Progress  Report  for  Phase  IIA and  IIB ARI  and  the AFS  -  March  1996.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION  AGENCY
Authors:      GREGORY  JOHNSON -  JOHNSON  COMPANY
Date:        March 1996
Format:      REPORT,  STUDY                          No.  Pgs:  2
AR No.       03.07.77                              Document  No.  000104

Title:       Monthly  Progress  Report  for  Phase  IIA and  IIB ARI  and  the AFS  -  April  1996.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION  AGENCY
Authors:      GREGORY  JOHNSON -  JOHNSON  COMPANY
Date:        April 1996
Format:      REPORT,  STUDY                          No.  Pgs:  2
AR No.       03.07.78                              Document  No.  000105

Title:       Monthly  Progress  Report  for  Phase  IIA and  IIB ARI  and  the AFS  -  May  1996.
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:      GREGORY  JOHNSON -  JOHNSON  COMPANY
Date:        May 1996
Format:      REPORT,  STUDY                          No.  Pgs:  2
AR No.       03.07.79                              Document  No.  000313

Title:       Monthly  Progress  Report  for  Phase  IIA and  IIB ARI  and  the AFS  -  June 1996.
Addressee:   SHEILA ECKMAN - ENVIRONMENTAL PROTECTION AGENCY
Authors:      GREGORY  JOHNSON -  JOHNSON  COMPANY
Date:        June  1996
Format:      REPORT,  STUDY                          No.  Pgs:  2
AR No.       03.07.80                              Document  No.  000106

Title:       Monthly  Progress  Report  for  Phase  IIA and  IIB ARI  and  the AFS  -  July 1996.
Addressee:   SHEILA ECKMAN - ENVIRONMENTAL PROTECTION AGENCY
Authors:      GREGORY  JOHNSON -  JOHNSON  COMPANY
Date:        July  1996
Format:      REPORT,  STUDY                          No.  Pgs:  2
AR No.       03.07.81                              Document  No.  000107

Title:       Monthly  Progress  Report  for  Phase  IIA and  IIB ARI  and  the AFS  -  August 1996.
Addressee:   SHEILA ECKMAN - ENVIRONMENTAL PROTECTION AGENCY
Authors:      GREGORY  JOHNSON -  JOHNSON  COMPANY
Date:        August 1996
Format:      REPORT,  STUDY                           No.  Pgs: 1
AR No.       03.07.82                               Document No.  000108

Title:       Monthly  Progress  Report  for  Phase  IIA and  IIB ARI  and  the AFS  -  September 1996.
Addressee:   SHEILA ECKMAN - ENVIRONMENTAL PROTECTION AGENCY
Authors:      GREGORY  JOHNSON -  JOHNSON  COMPANY
Date:        September 1996
Format:      REPORT,  STUDY                           No.  Pgs: 1
AR No.       03.07.83                               Document No.  000109

Title:       Work  Plan for Investigation, Retrieval, and Disposal of  Submerged  Drums.
Addressee:   ENVIRONMENTAL PROTECTION AGENCY
Authors:      JOHNSON  COMPANY
Date:        September 16, 1996
Format:      WORK  PLAN                               No.  Pgs: 13
AR No.       03.07.84                               Document No.  000110

Title:       Monthly  Progress  Report  for  Phase  IIA and  IIB ARI  and  the AFS  -  October 1996.
Addressee:   SHEILA ECKMAN - ENVIRONMENTAL PROTECTION AGENCY
Authors:      GREGORY  JOHNSON -  JOHNSON  COMPANY
Date:        October  1996
Format:      REPORT,  STUDY                           No.  Pgs: 2
AR No.       03.07.85                               Document No. 000048
Title:       Comments  on  the Work  Plan  for  Investigation,  Retrieval,  and  Disposal  of  Submerged  Drums.
Addressee:   CHRIS CRANDELL -  JOHNSON COMPANY
Authors:     MARY JANE 0'DONNELL -  ENVIRONMENTAL  PROTECTION AGENCY

-------
Date:        October  10,  1996
Format:      LETTER
AR No.       03.07.86
No. Pgs: 2
Document No. 000352
Title:       Response  to  Comments  to  the Work  Plan  for
              Investigation, Retrieval, and Disposal of Submerged Drums.
Addressee:   SHEILA  ECKMAN  - ENVIRONMENTAL  PROTECTION AGENCY
Authors:      GREGORY JOHNSON -  JOHNSON COMPANY
Date:        October 30,  1996
Format:      MEMORANDUM                              No.  Pgs:  3
AR No.       03.07.87                                Document  No.  000353

Title:       Monthly Progress Report  for Phase IIA  and  IIB ARI and  the  AFS  -  November 1996.
Addressee:   SHEILA  ECKMAN  - ENVIRONMENTAL  PROTECTION AGENCY
Authors:      GREGORY JOHNSON -  JOHNSON COMPANY
Date:        November  1996
Format:      REPORT, STUDY                           No.  Pgs:  2
AR No.       03.07.88                                Document  No.  000111

Title:       Monthly Progress Report  for the ARI  and the  AFS - December 1996.
Addressee:   ROSS  GILLELAND - ENVIRONMENTAL PROTECTION  AGENCY
Authors:      GREGORY JOHNSON -  JOHNSON COMPANY
Date:        December  1996
Format:      REPORT, STUDY                            No. Pgs: 2
AR No.       03.07.89                                 Document No.  000112

Title:       Monthly Progress Report  for the ARI  and the  AFS - January  1997.
Addressee:   ROSS  GILLELAND - EPA  REGION I
Authors:      GREGORY JOHNSON -  JOHNSON COMPANY
Date:        January 1997
Format:      REPORT, STUDY                            No. Pgs: 2
AR No.       03.07.90                                 Document No.000311

Title:       Monthly Progress Report  for the ARI  and the  AFS - February 1997.
Addressee:   ROSS  GILLELAND - EPA  REGION I
Authors:      GREGORY JOHNSON -  JOHNSON COMPANY
Date:        February  1997
Format:      REPORT, STUDY                              No. Pgs:  2
AR No.       03.07.91                                   Document  No.  000310

Title:       Monthly Progress Report  for the ARI  and the  AFS - March 1997.
Addressee:   ROSS  GILLELAND - EPA  REGION I
Authors:      GREGORY JOHNSON -  JOHNSON COMPANY
Date:        March 1997
Format:      REPORT, STUDY                              No. Pgs:  4
AR No.       03.07.92                                   Document  No.  000308

Title:       Monthly Progress Report  for the ARI  and the  AFS - April 1997.
Addressee:   ROSS  GILLELAND - EPA  REGION I
Authors:      GREGORY JOHNSON -  JOHNSON COMPANY
Date:        April 1997
Format:      REPORT, STUDY                              No. Pgs:  2
AR No.       03.07.93                                   Document  No.  000282

Title:       Monthly Progress Report  for the ARI  and the  AFS - May  1997.
Addressee:   ROSS  GILLELAND - ENVIRONMENTAL PROTECTION  AGENCY
Authors:      GREGORY JOHNSON -  JOHNSON COMPANY
Date:        May 1997
Format:      REPORT, STUDY                                No. Pgs:  1
AR No.       03.07.94                                     Document No. 000113

Title:       Monthly Progress Report  for the ARI  and the  AFS - June  1997.
Addressee:   ROSS  GILLELAND - EPA  REGION I
Authors:      GREGORY JOHNSON -  JOHNSON COMPANY
Date:        June  1997
Format:      REPORT, STUDY                          No. Pgs: 1
AR No.       03.07.95                               Document No. 000200

Title:       Monthly Progress Report  for the ARI  and the  AFS - July  1997.
Addressee:   ROSS  GILLELAND - EPA  REGION I
Authors:      GREGORY JOHNSON -  JOHNSON COMPANY
Date:        July  1997
Format:      REPORT, STUDY                           No.  Pgs:  1
AR No.       03.07.96                                Document  No.  000275
Title:       Monthly  Progress  Report  for  the ARI  and  the AFS  - August  1997.
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:      GREGORY  JOHNSON -  JOHNSON  COMPANY

-------
Date:
Format:
AR No.
August 1997
REPORT, STUDY
03.07.97
No. Pgs: 1
Document No. 000274
Title:       Monthly  Progress  Report  for  the ARI  and  the AFS  -  September 1997.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL PROTECTION AGENCY
Authors:      GREGORY  JOHNSON - JOHNSON  COMPANY
Date:        September  1997
Format:      REPORT,  STUDY                              No.  Pgs:  1
AR No.       03.07.98                                   Document  No.  000193

Title:       Monthly  Progress  Report  for  the ARI  and  the AFS  -  October 1997.
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:      GREGORY  JOHNSON - JOHNSON  COMPANY
Date:        October  1997
Format:      REPORT,  STUDY                              No.  Pgs:  2
AR No.       03.07.99                                   Document  No.  000228

Title:       Monthly  Progress  Report  for  the ARI  and  the AFS  -  November 1997.
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:      GREGORY  JOHNSON - JOHNSON  COMPANY
Date:        November 1997
Format:      REPORT,  STUDY                      No.  Pgs: 1
AR No.       03.07.100                          Document No.  000227

Title:       Monthly  Progress  Report  for  the ARI  and  the AFS  -  December 1997.
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:      GREGORY  JOHNSON - JOHNSON  COMPANY
Date:        December 1997
Format:      REPORT,  STUDY                      No.  Pgs: 1
AR No.       03.07.101                          Document No.000269

Title:       Monthly  Progress  Report  for  the ARI  and  the AFS  -  January 1998.
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:      GREGORY  JOHNSON - JOHNSON  COMPANY
Date:        January  1998
Format:      REPORT,  STUDY                      No.  Pgs: 1
AR No.       03.07.102                          Document No.000270

Title:       Monthly  Progress  Report  for  the Pine Street Phase
              I LA and the AFS  for February 1998, with  Transmittal Letter.
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:      GREGORY  JOHNSON - JOHNSON  COMPANY
Date:        March 13,  1998
Format:      LETTER                            No. Pgs: 3
AR No.       0:3.07.103                         Document No.  000592

Title:       Monthly  Progress  Report  for  the Pine Street Phase
              IIA ARI and the AFS for the Month of March 1998.
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:      GREGORY  JOHNSON - JOHNSON  COMPANY
Date:        April  15,  1998
Format:      LETTER                            No. Pgs: 2
AR No.       03.07.104                          Document No.  000593

Title:       Monthly  Progress  Report  for  the Phase  IIA ARI  and
               the AFS for April  1998, with Transmittal Letter.
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:      GREGORY  JOHNSON - JOHNSON  COMPANY
Date:        May 15,  1998
Format:      LETTER                            No. Pgs: 2
AR No.       03.07.105                          Document No.  000594
03.09
             REMEDIAL  INVESTIGATION  -  HEALTH ASSESSMENTS
Title:       Health  Consultation.
Addressee:   SUZANNE SIMON  - AGENCY  FOR  TOXIC  SUBSTANCES AND  DISEASE
Authors:      TAMMY MCCRAE US DEPT  OF HEALTH  HUMAN SERVICES
Date:        October 29, 1992
Format:      MEMORANDUM                              No. Pgs:  6
AR No.       03.09.1                            Document No.  000114
Title:       ATSDR's Health  Consultations  on  the  Pine  Street  Canal.
Authors:     AGENCY FOR  TOXIC  SUBSTANCES AND  DISEASE
Date:        February  1993
Format:      FACT  SHEET,  PRESS  RELEASE            No. Pgs:  2
AR No.       03.09.2                              Document  No.  000525

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03.10
REMEDIAL INVESTIGATION - ENDANGERMENT/BASELINE RISK ASSESSMENTS
Title:        Framework  for  Ecological  Risk Assessment.
Authors:      ENVIRONMENTAL  PROTECTION  AGENCY
Date:         February 1992
Format:       REPORT, STUDY                         No.  Pgs:  94
AR No.        03.10.1                               Document  No.
                                                                000222
Title:        Statement  of Work  for  Further  Study-Draft.
Authors:      ENVIRONMENTAL  PROTECTION AGENCY
Date:         July  30, 1993
Format:       WORK  PLAN                              No.  Pgs:  9
AR No.        03.10.2                                Document  No.  000115

Title:        Rationale  for  Selection of  Compounds  of  Concern in  Fish Tissue.
Addressee:    SHEILA ECKMAN  -  EPA REGION  I
Authors:      ANNE-MARIE BURKE - EPA REGION  I
Date:         October  4,  1993
Format:       MEMORANDUM                                  No. Pgs:  1
AR No.        03.10.3                                      Document  No.  000116

Title:        Meeting  Notes  of Inhalation Risks  from Industrial Use of Groundwater.
Addressee:    SHEILA ECKMAN  -  EPA REGION  I
Authors:      BARBARA  WEIR,  JOHN YOUNG -  METCALF &  EDDY
Date:         May 12,  1994
Format:       MEMORANDUM                                   No. Pgs: 17
AR No.        03.10.4                                       Document No.  000117

Title:        Screening  Calculations for  Whole Fish Consumption.
Addressee:    PINE  STREET HUMAN  HEALTH WORK  GROUP
Authors:      SHEILA ECKMAN, ANNE-MARIE BURKE -  EPA REGION I
Date:         February 3, 1995
Format:       MEMORANDUM                                   No. Pgs:  7
AR No.        03.10.5                                       Document  No.  000118

Title:        Bounding Calculations  for Consumption of Fish - Draft.
Addressee:    HUMAN HEALTH RISK  ASSESSMENT TECHNICAL W
Authors:      DEE HULL,  DAVID  BURMASTER - ALCEON CORPORATION
Date:         February 6, 1995
Format:       MEMORANDUM                                     No.  Pgs:  9
AR No.        03.10.6                                         Document No.  000119
Title:       Comments  on  Draft  Supplemental  Baseline
Addressee:   PINE  STREET  COORDINATING COUNCIL
Authors:     PHILIP HARTER, ALAN  STRASSER
Date:        January 6, 1996
Format:       MEMORANDUM
AR No.       03. 10.7
                                         Ecological Risk Assessment.
                                               No. Pgs: 14
                                               Document No. 000184
Title:       Comments  on  the Work  Plan  for  the  SBERA.
Addressee:   SHEILA ECKMAN  - ENVIRONMENTAL  PROTECTION AGENCY
Authors:     ALAN  QUACKENBUSH,  STANLEY  CORNEILLE  - VT DEPT.  OF  ENVIRONMENTAL CONSERVATION
Date:        January 30,  1996
Format:      LETTER                                      No.  Pgs:  1
AR No.       03.10.8                                     Document  No.  000192

Title:       PRP Comments on the Draft  Analysis Phase Version
              I, Supplemental Baseline  Ecological Risk Assessment.
Addressee:   SHEILA ECKMAN  - EPA REGION I
Authors:     SONJA SCHUYLER - JOHNSON COMPANY
Date:        October 10,  1996
Format:       LETTER                                      No.  Pgs:  7
AR No.       03.10.9                                      Document No.  000342

Title:       Memorandum Concerning Comments on  Analysis  Phase of  SBERA;  Work Plan for Retrieval
              and Disposal  of Submerged Drums;  and December Retreat.
Addressee:   PINE  STREET  COORDINATING COUNCIL
Authors:     PHILIP HARTER, ALAN STRASSER
Date:        October 17,  1996
Format:      MEMORANDUM                                     No. Pgs: 2
AR No.       03.10.10                                        Document No.  000180
Title:       Comments  on  the  Draft  Pine  Street  Barge  Canal
                   Supplemental Baseline Ecological Risk Assessment.
Addressee:   SHEILA  ECKMAN  -  EPA  REGION  I
Authors:     AL MCINTOSH, MARY WATZIN  -  UNIVERSITY  OF VERMONT
Date:        January 6, 1997

-------
Format:
AR No.
MEMORANDUM
03.10.11
No. Pgs: 2
Document No. 000340
Title:       Comments  on  the  Draft  Supplemental  Ecological  Risk Assessment.
Addressee:   SHEILA  ECKMAN  -  EPA  REGION  I
Authors:     STANLEY CORNEILLE  -  VT DEPT.  OF  ENVIRONMENTAL  CONSERVATION
Date:        January 22,  1997
Format:      LETTER                                            No.  Pgs: 1
AR No.       03.10.12                                          Document No.  000341
Title:       Memoranda Concerning  Fish Memos  from the  State  of
               Vermont and Conference Call of March 11, 1997.
Addressee:   PINE  STREET  COORDINATING COUNCIL
Authors:     PHILIP HARTER, ALAN STRASSER
Date:        March 3, 1997
Format:      MEMORANDUM                              No.  Pgs:  6
AR No.       03.10.13                                Document No.
                                                                   000120
Title:       Comments  on  the  Final  Supplemental  Baseline  Ecological  Risk Assessment  -  Draft.
Addressee:   SHEILA  ECKMAN  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     SONJA SCHUYLER,  CHRIS  CRANDELL -  JOHNSON COMPANY
Date:        May  30, 1997
Format:      LETTER                                   No.  Pgs:  4
AR No.       03.10.14                                 Document  No. 000121

Title:       Supplemental Baseline  Ecological  Risk Assessment - Volume  II  - Appendices and Plates.
Addressee:   ENVIRONMENTAL  PROTECTION AGENCY
Authors:     ROY  WESTON INC.
Date:        July 1997
Format:      REPORT, STUDY                            No.  Pgs:  280
AR No.       03.10.15                                 Document  No. 000259

Title:       Memorandum:  Analysis of the  Day Care Scenario for  Selected Areas
              of  the Pine Street Site.
Addressee:   ROSS GILLELAND - EPA REGION  I
Authors:     ANNE-MARIE BURKE -  EPA REGION  I
Date:        July 10,  1997
Format:      MEMORANDUM                               No.  Pgs:  2
AR No.       03.10.16                                 Document  No. 000595
Title:        Supplemental  Baseline  Ecological  Risk Assessment  - Volume  I  -
Addressee:    ENVIRONMENTAL PROTECTION AGENCY
Authors:      ROY WESTON  INC.
Date:         July  15,  1997
Format:       REPORT,  STUDY                            No.  Pgs: 243
AR No.        03.10.17                                  Document No.  000258
                                                              Text.
Title:        "Hot  Spot"  Evaluation  for  Ecological  Risk.
Addressee:    PINE  STREET COORDINATING COUNCIL
Authors:       SONJA SCHUYLER  -  JOHNSON COMPANY
Date:         August 7, 1997
Format:       MEMORANDUM                    No.  Pgs:  4
AR No.        03.10.18                      Document  No.  000631
04.01
              FEASIBILITY  STUDY  -  CORRESPONDENCE
Title:       Reguest  for  Extension  to  Due  Date Additional
               Feasibility Study, Initial Screening of Alternatives Report.
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:      JEFFREY  KLAIBER GEI  CONSULTANTS
Date:        August 7,  1995
Format:      LETTER                          No.  Pgs:  2
AR No.       04.01.1                         Document  No. 000124

Title:       Post  Screening  Field Investigation.
Addressee:   DR. MARTIN JOHNSON  - JOHNSON  COMPANY
Authors:      SHEILA ECKMAN - EPA REGION  I
Date:        September  5, 1995
Format:      LETTER                          No. Pgs: 2
AR No.       04.01.2                         Document No.  000300
Title:       Update  on EPA's  Involvement  on  the  Feasibility  Study  and  Southern  Connector.
Addressee:   PINE  STREET  COORDINATING  COUNCIL
Authors:     ROSS  GILLELAND -  EPA REGION  I
Date:        April 4, 1996
Format:      MEMORANDUM                        No.  Pgs:  4
AR No.       04.01.3                           Document  No. 000284

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Title:        Identification  of Hot  Spots.
Addressee:    ROSS  GILLELAND  - EPA REGION  I
Authors:      AL MCINTOSH, MARY WATZIN  - UNIVERSITY  OF VERMONT
Date:         June  20,  1997
Format:       MEMORANDUM                        No. Pgs:  1
AR No.        04.01.4                           Document  No.  000281

Title:        Additional  Feasibility Study Regarding EPA's  Oct.  21st  Letter.
Addressee:    MARY  JANE 0'DONNELL  -  EPA REGION  I
Authors:      CHRIS CRANDELL  - JOHNSON  COMPANY
Date:         October  28, 1997
Format:       LETTER                          No.  Pgs:   2
AR No.        04.01.5                         Document No.  000336
04.03
              FEASIBILITY  STUDY  -  SCOPES  OF WORK
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Post Screening Field Investigation Scope of Work - Additional Feasibility Study.
DR. MARTIN JOHNSON - JOHNSON COMPANY
ROSS GILLELAND - EPA REGION I
September 27,  1995
LETTER                          No. Pgs:  3
              04.03.1
                                              Document  No.  000271
04.04
              FEASIBILITY  STUDY  -  INTERIM  DELIVERABLES
Title:       Natural Biodegradation  Evaluation—Summary  of  Results.
Authors:      RETEC
Format:      PUBLIC MEETING  RECORDS          No.  Pgs:  13
AR No.       04.04.1                         Document  No. 000122

Title:       In-Situ Capping of  Contaminated Sediments,  A Primer  for  Environmental  Professionals.
Authors:      HAZARDOUS  SUBS.  RESEARCH  CTR/SO &  SO WES
Format:      REPORT, STUDY                   No.  Pgs:  18
AR No.       04.04.2                         Document  No. 000596

Title:       Response to EPA Comments  on  the Draft Additional  Feasibility  Study  -
              Post-Screening Field Investigation: Intrinsic & Enhanced Bioremediation Assessm
Authors:      GREGORY JOHNSON
Format:      CORRESPONDENCE                  No.  Pgs:  13
AR No.       04.04.3                         Document  No. 000601
  *Attached to Document No.   000599 In 04.04

Title:       Response to EPA Comments  on  the Additional
               Feasibility Study Post-Screening Field  Investigation.
Authors:      JOHNSON COMPANY
Format:      CORRESPONDENCE                  No.  Pgs:  4
AR No.       04.04.4                         Document  No. 000602
  *Attached  to  Document No.  000599  In  04.04

Title:       Results of Preliminary  Microbial Screening.
Addressee:   PINE ST REMEDIAL ALTERNATIVES WORK GROUP
Authors:      BENJAMIN GENES  - RETEC
Date:        November 28, 1994
Format:      MEMORANDUM                     No.  Pgs:  4
AR No.       04.04.5                         Document  No. 000123

Title:       Comments on Remedial Alternatives.
Addressee:   ROSS GILLELAND  - EPA REGION  I
Authors:      AL  MCINTOSH - UNIVERSITY  OF  VERMONT
Date:        September  26, 1995
Format:      MEMORANDUM                     No.  Pgs:  1
AR No.       04.04.6                         Document  No. 000299

Title:       Comments Regarding  the  Post-Screening Field
               Investigation Work Plan and Initial Screening Report.
Addressee:   PINE STREET COORDINATING  COUNCIL
Authors:      PHILIP HARTER,  ALAN STRASSER
Date:        November 8, 1995
Format:      MEMORANDUM                     No.  Pgs:  6
AR No.       04.04.7                         Document  No. 000297
Title:       Conditional Approval  of  FS  Post-Screening  Field  Investigation Work  Plan.
Addressee:     DR. MARTIN JOHNSON - JOHNSON COMPANY
Authors:     MARY JANE 0'DONNELL -  EPA REGION  I
Date:        November 14, 1995
Format:      LETTER                          No.  Pgs:   10

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AR No.
              04.04.8
                                              Document  No.  000296
Title:       Disapproval with Modifications  Required  of  the
               Additional Feasibility Study—Initial Screening of Alternatives Report - 9/8/95.
Addressee:   DR. MARTIN JOHNSON  -  JOHNSON  COMPANY
Authors:     MARY  JANE 0'DONNELL -  ENVIRONMENTAL PROTECTION AGENCY
Date:        December 4, 1995
Format:      LETTER                           No. Pgs:  10
AR No.       04.04.9                          Document  No.  000125

Title:       Objections and  Response  of  Performing  Respondents to December  4
               Disapproval with Modifications Required of the Remedial Alternatives Report.
Addressee:   ROSS  GILLELAND  - EPA  REGION I
Authors:     DAVID LEDBETTER - HUNTON AND  WILLIAMS
Date:        December 8, 1995
Format:      LETTER                           No. Pgs:  5
AR No.       04.04.10                         Document No. 000293

Title:       Request for Extension  -  Revised AFS Initial
              Screening of Remedial Alternatives Report and Response to Comment Letter.
Addressee:   ROSS  GILLELAND  - EPA  REGION I
Authors:     JEFFREY KLAIBER - GEI  CONSULTANTS
Date:        December 21,  1995
Format:      LETTER                           No. Pgs:  1
AR No.       04.04.11                         Document  No.  000295

Title:       Response to Comments  Letter and Post Screening
              Field Investigation Work Plan  - Revision 2.
Addressee:   ROSS  GILLELAND  - EPA  REGION I
Authors:     JEFFREY KLAIBER - GEI  CONSULTANTS
Date:        December 22,  1995
Format:      LETTER                           No. Pgs:  13
AR No.       04.04.12                         Document  No.  000294

Title:       Extension of  Time in  Due Date for  the  AFS Initial
              Screening of Alternatives  Report,  Revision 1.
Addressee:   DR. MARTIN JOHNSON  -  JOHNSON  COMPANY
Authors:     MARY  JANE 0'DONNELL -  EPA REGION I
Date:        January 2, 1996
Format:      LETTER                           No. Pgs:  2
AR No.       04.04.13                         Document  No.  000292

Title:       Informal Submittal  -  Draft  Additional  Feasibility
               Study - Initial Screening of  Remedial Alternatives Report.
Addressee:   ROSS  GILLELAND  - EPA  REGION I
Authors:     JEFFREY KLAIBER - GEI  CONSULTANTS
Date:        January 10, 1996
Format:      LETTER                           No. Pgs:  20
AR No.       04.04.14                         Document  No.  000291

Title:       Summary of Remedial Alternatives Subjected  to Initial  Screening.
Addressee:   ENVIRONMENTAL PROTECTION AGENCY
Authors:     GEI CONSULTANTS
Date:        January 22, 1996
Format:      REPORT, STUDY                    No. Pgs:  74
AR No.       04.04.15                         Document  No.  000126

Title:       Comments on Revision  I of the Initial  Screening
               of Remedial Alternatives  Report  (January 10, 1996).
Addressee:   JEFFREY KLAIBER - GEI  CONSULTANTS.
Authors:     ROSS  GILLELAND  - EPA  REGION I
Date:        January 29, 1996
Format:      MEMORANDUM                       No. Pgs:  6
AR No.       04.04.16                         Document  No.  000290

Title:       Additional Evaluation  of Remediation Technologies for  Manufactured Gas  Plant  Sites.
Addressee:   ROSS  GILLELAND  - EPA  REGION I
Authors:     DR. MARTIN JOHNSON  -  JOHNSON  COMPANY
Date:        February 2, 1996
Format:      MEMORANDUM                       No. Pgs:  1
AR No.       04.04.17                         Document  No.  000289
Title:       Response  to  Comments  Letter  and  Initial  Screening
               of Remedial Alternatives - Revision 2 Additional Feasibility Study.
Addressee:   ROSS GILLELAND  -  EPA  REGION  I
Authors:      RIDGELY MAUCK - GEI CONSULTANTS
Date:        February  8,  1996
Format:      LETTER                           No.  Pgs:   8

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AR No.
              04.04.18
                                              Document  No.  000288
Title:       Additional  Bioremediation  Sampling.
Addressee:   PINE  STREET COORDINATING COUNCIL
Authors:     PHILIP HARTER, ALAN  STRASSER
Date:        February  14,  1996
Format:      MEMORANDUM                      No.  Pgs:   2
AR No.       04.04.19                        Document  No.  000287

Title:       Supplemental Submittal  to  the  Initial  Screening  of Remedial Alternatives  Report."
Addressee:   ROSS  GILLELAND - EPA REGION I
Authors:     CHRIS CRANDELL - JOHNSON COMPANY
Date:        March 1,  1996
Format:      LETTER                          No.  Pgs:   2
AR No.       04.04.20                        Document  No.  000286

Title:       Response  to EPA Comments on the Draft  Review  of
               Additional  Remedial Technoogies, March  27,  1996.
Authors:     JOHNSON COMPANY
Date:        March 27, 1996
Format:      CORRESPONDENCE                  No.  Pgs:   4
AR No.       04.04.21                        Document  No.  000600
  *Attached to Document No. 000599 In 04.04

Title:       Comments  on the Post Screening Field Investigation:  Intrinsic  and Enhanced
              Bioremediation Assessments - Additional  Feasibility Study.
Addressee:   CHRIS CRANDELL - JOHNSON COMPANY
Authors:     ROSS  GILLELAND - ENVIRONMENTAL PROTECTION AGENCY
Date:        January 3,  1997
Format:      LETTER                          No.  Pgs:   13
AR No.       04.04.22                        Document  No.  000278

Title:       Letter with Comments on Draft  Review of Additional Remedial Technologies,  March 27,  1996.
Addressee:   CHRIS CRANDELL - JOHNSON COMPANY
Authors:     ROSS  GILLELAND - EPA REGION I
Date:        January 3,  1997
Format:      LETTER                          No.  Pgs:   4
AR No.       04.04.23                        Document  No.  000597

Title:       Letter with EPA Comments on Investigations to Support  Detailed Evaluation
              of a Subagueous Capping Remedial Alternative, GEI, August 8,   1996. 1996.
Addressee:   CHRIS CRANDELL - JOHNSON COMPANY
Authors:     ROSS  GILLELAND - EPA REGION I
Date:        January 3,  1997
Format:      LETTER                          No.  Pgs:   3
AR No.       04.04.24                        Document  No.  000598

Title:       Transmittal Letter for  Attached Response  to EPA  Comments.
Addressee:   ROSS  GILLELAND EPA REGION  I
Authors:     GREGORY JOHNSON - JOHNSON  COMPANY
Date:        May 15, 1997
Format:      LETTER                          No.  Pgs:   1
AR No.       04.04.25                        Document  No.  000599
04.06
              FEASIBILITY  STUDY  -  FEASIBILITY  STUDY  REPORTS
Title:        Submission  of  PRP  Technical  Committee  Supplemental  Information -  Rough Draft  I.
Addressee:    MICHAEL  JASINSKI - ENVIRONMENTAL  PROTECTION AGENCY
Authors:       NORM  TERRERI - GREEN MOUNTAIN
Date:         August 5, 1992
Format:       LETTER                          No.  Pgs:   26
AR No.        04.06.1                         Document  No.  000128

Title:        Submission  of  PRP  Technical  Committee  Supplemental  Information -  Rough Draft  II.
Addressee:    ROSS  GILLELAND - EPA REGION  I
Authors:       NORM  TERRERI - GREEN MOUNTAIN
Date:         August 26,  1992
Format:       LETTER                          No.  Pgs:   69
AR No.        04.06.2                         Document  No.  000267
Title:       Review  of  "Feasibility-Like Analysis  -  Proposed  Remedial  Action Plan."
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     ROBERT  RAMEY  -  BURLINGTON  PLANNING COMMISSION
Date:        September  1,  1992
Format:      LETTER                           No. Pgs:  16
AR No.       04.06.3                          Document No. 000129

-------
Title:       Announcement  that  the  State will  be  Submitting
               Comments on the Draft Detailed Screening Phase - Additional Feasibility Study.
Addressee:   PHILIP HARTER
Authors:     STANLEY CORNEILLE  - VT DEPT.  OF ENVIRONMENTAL CONSERVATION
Date:        May  15, 1997
Format:      LETTER                          No.  Pgs:   1
AR No.       04.016.4                        Document  No. 000279

Title:       Comments  on Additional Feasibility Study  for
               Consideration at the May 19 Coordinating Council Meeting.
Addressee:   PHILIP HARTER
Authors:     E. MICHAEL THOMAS  - MC DERMOTT, WILL AND  EMERY
Date:        May  15, 1997
Format:      LETTER                          No.  Pgs:   2
AR No.       04.06.5                         Document  No. 000280

Title:       Comments  on Feasibility Study.
Addressee:   PHILIP HARTER - ENVIRONMENTAL PROTECTION  AGENCY
Authors:     LAPSE TEAM
Date:        May  16, 1997
Format:      MEMORANDUM                      No.  Pgs:   3
AR No.       04.06.6                         Document  No. 000242

Title:       Responses to  USEPA General Comments  on Draft
               Revision No. 2 of the Additional Feasibility Study, Pine Street Canal.
Authors:     RETEC
Date:        June 16,  1997
Format:      CORRESPONDENCE                  No.  Pgs:   6
AR No.       04.06.7                         Document  No. 000603
Title:       EPA General  Comments  - Additional  Feasibility  Study  - April  14  and July  7,
Addressee:   CHRIS CRANDELL  -  JOHNSON  COMPANY
Authors:     MARY JANE 0'DONNELL - EPA REGION I
Date:        July 31, 1997
Format:      LETTER                          No.  Pgs:   31
AR No.       04.06.8                         Document  No. 000276
1997.
Title:       Response  to  Comments  on  the  Draft Additional  Feasibility  Study (Rev.  1).
Addressee:   ROSS  GILLELAND  -  EPA  REGION  I
Authors:      BENJAMIN  GENES  -  RETEC
Date:        August  29, 1997
Format:      CORRESPONDENCE                  No.  Pgs:   47
AR No.       04.06.9                        Document  No.  000604

Title:       Memo  Concerning Additional Feasibility  Study  Comments  - Revised  Draft.
Addressee:   ROSS  GILLELAND  -  EPA  REGION  I
Authors:      SHEILA  ECKMAN - EPA REGION I
Date:        September 15, 1997
Format:      MEMORANDUM                     No.  Pgs:   9
AR No.       04.06.10                        Document  No.  000230

Title:       Text  from AFS Draft Revision I  Concerning Wetland  Impacts from Remedial Actions.
Authors:      ENVIRONMENTAL PROTECTION AGENCY
Date:        September 22, 1997
Format:      MISCELLANEOUS                   No.  Pgs:   7
AR No.       04.06.11                        Document  No.  000229

Title:       Comments  on  Revised Draft -  Additional  Feasibility Study.
Authors:      ENVIRONMENTAL PROTECTION AGENCY
Date:        October 1997
Format:      MISCELLANEOUS                   No.  Pgs:   25
AR No.       04.06.12                        Document  No.  000638


Title:       EPA Comments on the Revised  Draft -  Additional  Feasibility Study.
Addressee:   CHRIS CRANDELL  -  JOHNSON COMPANY
Authors:      MARY  JANE 0'DONNELL - EPA REGION I
Date:        October 20,  1997
Format:      LETTER                          No.  Pgs:   65
AR No.       04.06.13                        Document  No.  000272
Title:       Letter  Disapproving  the Additional  Feasibility
               Study Dated August 1997, with modifications Reguired.
Addressee:   CHRIS CRANDELL  -  JOHNSON  COMPANY
Authors:     MARY JANE 0'DONNELL  -  EPA REGION  I
Date:        October 20, 1997
Format:      LETTER                          No.  Pgs:   1
AR No.       04.06.14                        Document  No.  000605

-------
Title:       Objections  and  Response  of  Performing  Respondents  to  October  20
               Disapproval with Modifications Required of the Additional Feasibility Study.
Addressee:   SHEILA  ECKMAN -  EPA  REGION  I
Authors:     DAVID LEDBETTER  - HUNTON AND WILLIAMS
Date:        October 28,  1997
Format:      LETTER                          No.  Pgs:  4
AR No.       04.06.15                        Document No.  000273

Title:       Letter  Concerning EPA's  Review  of  the  Additional Feasibility  Study,  Dated August  1997.
Addressee:   MARY JANE 0'DONNELL  -  EPA REGION I
Authors:     CHRIS CRANDELL  - JOHNSON COMPANY
Date:        October 28,  1997
Format:      LETTER                          No.  Pgs:  2
AR No.       04.06.16                        Document No.  000606

Title:       Response to Comments on  the August  1997 Revision of the Additional  Feasibility Study.
Addressee:   ROSS GILLELAND  - EPA REGION I
Authors:     BENJAMIN GENES  - RETEC
Date:        November 7,  1997
Format:      CORRESPONDENCE                  No.  Pgs:  60
AR No.       04.06.17                        Document No.  000607

Title:       Letter  Providing Additional Modifications to  the Additional Feasibility Study.
Addressee:   CHRIS CRANDELL  - JOHNSON COMPANY
Authors:     MARY JANE 0'DONNELL  -  EPA REGION I
Date:        January 21,  1998
Format:      LETTER                          No.  Pgs:  3
AR No.       04.06.18                        Document No.  000608

Title:       Response to USEPA January 1998  Comments on the
               Draft Additional Feasibility Study (Revision 3).
Addressee:   ROSS GILLELAND  - EPA REGION I
Authors:     BENJAMIN GENES  - RETEC
Date:        February 12, 1998
Format:      CORRESPONDENCE                  No.  Pgs:  24
AR No.       04.06.19                        Document No.  000609

Title:       Letter  Containing Additional Modifications Required to the Additional  Feasibility Study.
Addressee:   CHRIS CRANDELL  - JOHNSON COMPANY
Authors:     MARY JANE 0'DONNELL  -  EPA REGION I
Date:        April 20, 1998
Format:      LETTER                          No.  Pgs:  3
AR No.       04.06.20                        Document No.  000610

Title:       Draft Final Additional Feasibility  Study, Volume 1 (of 2), Report.
Authors:     RETEC
Date:        May 1998
Format:      REPORT,  STUDY                   No.  Pgs:  286
AR No.       04.06.21                        Document No.  000613

Title:       Draft Final Additional Feasibility  Study, Volume 2 of 2, Appendices  A  - E.
Authors:     RETEC
Date:        May 1998
Format:      REPORT,  STUDY
AR No.       04.06.22                        Document No.  000614

Title:       Letter  Concerning Required  Modifications to the ARARs.
Addressee:   CHRIS CRANDELL  - JOHNSON COMPANY
Authors:     MARY JANE 0'DONNELL  -  EPA REGION I
Date:        May 1,  1998
Format:      LETTER                          No.  Pgs:  1
AR No.       04.06.23                        Document No.  000611

Title:       Response to EPA Comments on the Draft  Final Additional Feasibility  Study.
Addressee:   ROSS GILLELAND  - EPA REGION I
Authors:     BENJAMIN GENES  - RETEC
Date:        May 18,  1998
Format:      CORRESPONDENCE                  No.  Pgs:  44
AR No.       04.06.24                        Document No.  000612
04.07         FEASIBILITY  STUDY  - WORK PLANS AND  PROGRESS  REPORTS

Title:        Work  Plan  for Natural  Biodegradation  Evaluation
              at the Pine Street Canal Site, Burlington, Vermont.
Addressee:    ENVIRONMENTAL PROTECTION AGENCY
Authors:       RETEC
Date:         September  19, 1994

-------
Format:
AR No.
MEMORANDUM
04.07.1
No. Pgs:  69
Document No. 000152
Title:       Comments  on Work  Plan  for  Natural  Biodegradation Evaluation.
Addressee:   RETEC
Authors:     ENVIRONMENTAL  PROTECTION AGENCY
Date:        September 20,  1994
Format:      CORRESPONDENCE                  No.  Pgs:   7
AR No.       04.07.2                          Document  No.  000153
  *Attached to Document No. 000639  In 04.07

Title:       Work Plan for  Natural  Biodegradation EvaluationVermont.
Addressee:   ENVIRONMENTAL  PROTECTION AGENCY
Authors:     RETEC
Date:        October 1994
Format:      WORK PLAN                       No.  Pgs:   88
AR No.       04.07.3                          Document  No.  000633

Title:       Transmitting EPA  Comments  on  the Draft  Biodegradation Work  Plan.
Addressee:   BENJAMIN  GENES -  RETEC
Authors:     ROSS GILLELAND -  ENVIRONMENTAL PROTECTION AGENCY
Date:        October 3, 1994
Format:      LETTER                           No.  Pgs:   1
AR No.       04.07.4                          Document  No.  000639

Title:       EPA's Comments on the  Draft Biodegradation Work  Plan.
Addressee:   BENJAMIN  GENES -  RETEC
Authors:     ROSS GILLELAND -  ENVIRONMENTAL PROTECTION, AGENCY
Date:        October 3, 1994
Format:      LETTER                           No.  Pgs:   19
AR No.       04.07.5                          Document  No.  000658

Title:       Screening Samples for  Natural Biodegradation  Evaluation.
Addressee:   PINE ST REMEDIAL  ALTERNATIVES WORK GROUP
Authors:     BENJAMIN  GENES -  RETEC
Date:        October 18, 1994
Format:      MEMORANDUM                      No.  Pgs:   2
AR No.         04.07.6                         Document No.  000655

Title:       EPA's Comments on the  Memorandum "Screening
              Samples  for Natural Biodegradation  Evaluation."
Addressee:   BENJAMIN  GENES -  RETEC
Authors:     ROSS GILLELAND -  ENVIRONMENTAL PROTECTION AGENCY
Date:        October 21, 1994
Format:      LETTER                           No.  Pgs:   2
AR No.       04.07.7                          Document  No.  000154
Title:       EPA's  Comments  on  RECTEC's Memo  entitled
              "Screening Samples for Natural Biodegradation Evaluation" dated October 18,
Addressee:   BENJAMIN  GENES  - RETEC
Authors:     ROSS GILLELAND  - ENVIRONMENTAL PROTECTION AGENCY
Date:        October 21, 1994
Format:      LETTER                          No.  Pgs:  2
AR No.       04.07.8                       Document  No.  000657
                                                                             1994.
Title:       Response  to  Comments  on  the  "Draft  Treatability
               Work Plan for Natural Biodegradation Evaluation."
Addressee:   ENVIRONMENTAL  PROTECTION AGENCY
Authors:      RETEC
Date:        November  17, 1994
Format:      CORRESPONDENCE                  No.  Pgs:   11
AR No.       04.07.9                          Document  No.  000155

Title:       Response  to  Comments  on  the  "Draft  Treatability Work  Plan for
               Natural Biodegradation Evaluation for the Pine Street Barge Canal Site.
Addressee:   ROSS GILLELAND - ENVIRONMENTAL PROTECTION AGENCY
Authors:      BENJAMIN  GENES - RETEC
Date:        November  17, 1994
Format:      LETTER                           No.  Pgs:   12
AR No.       04.07.10                         Document  No.  000656
Title:       Approval  of Natural  Biodegradation Work  Plan.
Addressee:   DR. MARTIN JOHNSON - JOHNSON  COMPANY
Authors:     MARY  JANE 0'DONNELL  -  EPA REGION  I
Date:        December  14,  1994
Format:      LETTER                          No. Pgs:   3
AR No.       04.07.11                        Document No.  000307

-------
Title:        Progress  of Natural  Biodegradation  Evaluation.
Addressee:    PINE  ST REMEDIAL ALTERNATIVES WORK  GROUP
Authors:       BENJAMIN  GENES  - RETEC
Date:         January 17, 1995
Format:       MEMORANDUM                      No.  Pgs:   6
AR No.        04.07.12                        Document  No.  000156

Title:        Draft—Additional  Feasibility Study Work  Plan—Comments.
Addressee:    DR. MARTIN JOHNSON - JOHNSON COMPANY
Authors:       ROSS  GILLELAND  - ENVIRONMENTAL  PROTECTION AGENCY
Date:         June  1, 1995
Format:       LETTER                          No.  Pgs:  11
AR No.        04.07.13                        Document  No.  000157

Title:        Response  to EPA Comments  on Draft AFS Work Plan.
Addressee:    ENVIRONMENTAL PROTECTION  AGENCY
Authors:       JOHNSON COMPANY
Date:         June  26,  1995
Format:       CORRESPONDENCE                  No.  Pgs:  16
AR No.        04.07.14                        Document  No.  000158

Title:        Memo  Concerning the  Addendum to Draft APS Work Plan  Dated April  17,  1995.
Addressee:    ROSS  GILLELAND  - ENVIRONMENTAL  PROTECTION AGENCY
Authors:       GREGORY JOHNSON -  JOHNSON COMPANY
Date:         June  27,  1995
Format:       MEMORANDUM                      No.  Pgs:   2
AR No.        04.07.15                        Document  No.  000160

Title:        Additional Feasibility  Study Work Plan  -  Draft,
              Pine Street Canal Site, Burlington, Vermont, Revision 1.
Addressee:    ENVIRONMENTAL PROTECTION  AGENCY
Authors:       GEI CONSULTANTS
Date:         June  30,  1995
Format:       WORK  PLAN                      No.  Pgs:   38
AR No.        04.07.16                        Document  No.  000159

Title:        Approval  of Additional  Feasibility  Study  Work Plan.
Addressee:    DR. MARTIN JOHNSON - JOHNSON COMPANY
Authors:       MARY  JANE 0'DONNELL  - EPA REGION I
Date:         July  6, 1995
Format:       LETTER                          No.  Pgs:   2
AR No.        04.07.17                        Document  No.  000303

Title:        Extension of FS Initial screening of Alternatives
               Report  and Post-Screening Field Investigation Work Plan.
Addressee:    DR. MARTIN JOHNSON - JOHNSON COMPANY
Authors:       MARY  JANE 0'DONNELL  - EPA REGION I
Date:         August 14, 1995
Format:       LETTER                          No.  Pgs:   3
AR No.        04.07.18                        Document  No.  000302

Title:        Comments  on GEI Proposed  Post-Screening Field Investigation Workplan.
Addressee:    ROSS  GILLELAND  - ENVIRONMENTAL  PROTECTION AGENCY
Authors:       LAPSE TEAM
Date:         September 20, 1995
Format:       MEMORANDUM                      No.  Pgs:   1
AR No.        04.07.19                        Document  No.  000636

Title:        Comments  on the Draft Post-Screening Field
              Investigation Work  Plan and the ARI Phase IIB Work Plan.
Addressee:    CHRIS CRANDELL  - JOHNSON  COMPANY
Authors:       STANLEY CORNEILLE  -  VT  DEPT. OF ENVIRONMENTAL CONSERVATION
Date:         September 29, 1995
Format:       LETTER                          No.  Pgs:   2
AR No.        04.07.20                        Document  No.  000634

Title:        Draft Post - Screening  Field Investigation Work Plan.
Addressee:    ENVIRONMENTAL PROTECTION  AGENCY
Authors:       GEI CONSULTANTS
Date:         December  22, 1995
Format:       REPORT, STUDY                   No.  Pgs:   183
AR No.        04.07.21                        Document  No.  000637
Title:       Comments  - Additional  Feasibility  Study  -  Post  Screening  Field Investigation.
Authors:     ENVIRONMENTAL  PROTECTION AGENCY
Date:        August  8, 1996
Format:      MISCELLANEOUS                   No.  Pgs:   4
AR No.       04.07.22                        Document No.  000635

-------
04.09
              FEASIBILITY  STUDY  -  PROPOSED  PLANS  FOR SELECTED REMEDIAL ACTION
Title:       Cleanup  Plan  Proposed  for  Pine  Street  Barge  Canal  Superfund Site.
Authors:      EPA  REGION  I
Date:        May  1998
Format:      FACT SHEET, PRESS  RELEASE        No.  Pgs:   11
AR No.       04.09.1                          Document  No.  000615
05.01
             RECORDS  OF  DECISION  -  CORRESPONDENCE
Title:       Request  to  Continue  Classifying  the  Groundwater
              Underneath the Pine Street Site as Not a Suitable Source of Potable Water.
Addressee:   JAY  RUTHERFORD  - VT  DEPT.  OF  ENVIRONMENTAL  CONSERVATION
Authors:     MARY JANE 0'DONNELL  -  ENVIRONMENTAL  PROTECTION AGENCY
Date:        August 12,  1998
Format:      LETTER                           No.  Pgs:  3
AR No.       05.01.1                          Document  No.  000671

Title:       Groundwater Reclassification  - Pine  Street  Barge  Canal  Site.
Addressee:   MARY JANE 0'DONNELL  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     GEORGE DESCH  - VT  DEPT.  OF ENVIRONMENTAL  CONSERVATION
Date:        September 14, 1998
Format:      LETTER                           No.  Pgs:  2
AR No.       05.01.2                          Document  No.  000672


05.02        RECORDS  OF  DECISION  -  APPLICABLE OR  RELEVANT  & APPROPRIATE  REQUIREMEN

Title:       ARARs Specific  to  Remedial Alternative  3a:  Capping Subareas 1,  2,  3, 7 and
Format:      MISCELLANEOUS                    No.  Pgs:  5
AR No.       05.02.1                          Document  No.  000666

Title:       Section  18-79 of Burlington Code of  Ordinances: Plumbing Connections.
Addressee:   BETH TENSASELLO -  ENVIRONMENTAL  PROTECTION  AGENCY
Authors:     ROBERT RAMEY  -  BURLINGTON  PLANNING COMMISSION
Date:        August 20,  1992
Format:      MISCELLANEOUS               No.  Pgs:  1
AR No.       05.02.2                       Document No.   000640

Title:       Notification  of EPA  Disagreement with the State
               of  Vermont over State Standards Qualifying as ARARs.
Addressee:   WILLIAM  AHERN - VT DEPT. OF ENVIRONMENTAL CONSERVATION
Authors:     MARY JANE 0'DONNELL  -  ENVIRONMENTAL  PROTECTION AGENCY
Date:        November 9, 1992
Format:      LETTER                        No. Pgs:   2
AR No.       05.02.3                       Document No.   000151
05.03
             RECORDS  OF  DECISION  -  RESPONSIVENESS  SUMMARIES
Title:       Comments  on  the  Proposed  Plan  for  the  Pine  Street  Barge  Canal  Superfund Site.
Addressee:   KAREN  LUMINO - ENVIRONMENTAL PROTECTION AGENCY
Format:      FORM                           No.  Pgs:  1
AR No.       05.03.1                      Document  No. 000646

Title:       Comments  on  the  Proposed  Plan  for  the  Pine  Street  Barge  Canal  Superfund Site.
Addressee:   KAREN  LUMINO - ENVIRONMENTAL PROTECTION AGENCY
Authors:     FRED HILL
Date:        June 9, 1998
Format:      CORRESPONDENCE              No.  Pgs:  1
AR No.       05.03.2                      Document  No.   000648

Title:       Pine Street  Barge  Canal Public Hearing.
Authors:     CAROL  BOONE  - COURT  REPORTERS  ASSOCIATES
Date:        June 24,  1998
Format:      PUBLIC MEETING RECORDS            No.  Pgs:  17
AR No.       05.03.3                      Document  No.   000641

Title:       Resolution that  EPA  Accept  Settlement.
Addressee:   ENVIRONMENTAL PROTECTION  AGENCY
Authors:     BURLINGTON CITY  COUNCIL
Date:        June 26,  1998
Format:      MISCELLANEOUS               No.  Pgs:  3
AR No.       05.03.4                      Document  No.   000645
Title:
Comments on the Proposed Plan for the Pine Street Barge Canal Superfund Site.

-------
Addressee:   KAREN  LUMINO  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     LINDEN WITHERELL
Date:        July 8,  1998
Format:      LETTER                       No.  Pgs:  5
AR No.       05.03.5                       Document  No.   000644

Title:       Comments  on the Proposed  Plan for the  Pine  Street  Barge  Canal  Superfund Site.
Addressee:   KAREN  LUMINO  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     WAYNE  SENVILLE  -  BURLINGTON PLANNING COMMISSION
Date:        July 8,  1998
Format:      FORM                           No.  Pgs:  1
AR No.       05.03.6                       Document  No.   000647

Title:       Comments  on the Proposed  Plan for the  Pine  Street  Barge  Canal  Superfund Site.
Addressee:   KAREN  LUMINO  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     JOHN BRABANT  -  VT DEPT. OF ENVIRONMENTAL  CONSERVATION
Date:        July 10,  1998
Format:      CORRESPONDENCE              No.  Pgs: 2
AR No.       05.03.7                       Document  No.   000643

Title:       Comments  on the Proposed  Plan for the  Pine  Street  Barge  Canal  Superfund Site.
Addressee:   KAREN  LUMINO  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     HAROD  CARSLON
Date:        July 24,  1998
Format:      FORM                           No.  Pgs:  2
AR No.       05.03.8                       Document  No.   000642

Title:       Pine Street Canal Superfund Site Responsiveness Summary.
Authors:     ENVIRONMENTAL PROTECTION  AGENCY
Date:        September 1998
Format:      PUBLIC MEETING  RECORDS            No. Pgs:  50
AR No.       05.03.9                       Document  No.   000668
05.04
             RECORDS  OF  DECISION  -  RECORD  OF  DECISION
Title:       Record  of  Decision  for  the  Pine  Street  Canal  Superfund Site.
Authors:     ENVIRONMENTAL  PROTECTION AGENCY
Date:        September  29,  1998
Format:      REPORT,  STUDY                No.  Pgs:  312
AR No.       05.04.1                       Document No.   000669
9.01
              STATE  COORDINATION  -  CORRESPONDENCE
Title:        Joint  Resolution  Relating  to  the  Burlington Barge  Canal  Site.
Addressee:    CAROL  BROWNER  - ENVIRONMENTAL PROTECTION AGENCY
Authors:       DONALD HOOPER  - VERMONT  SECRETARY OF  STATE
Date:         April  28,  1993
Format:       LETTER                       No.  Pgs:   4
AR No.        09.01.1                       Document  No. 000344

Title:        Cancelation  of the  Proposed Plan.
Addressee:    DONALD HOOPER  - VERMONT  SECRETARY OF  STATE
Authors:       PAUL KEOUGH  -  EPA REGION I
Date:         June 22,  1993
Format:       LETTER                       No.  Pgs:   1
AR No.        09.01.2                       Document  No.   000343


10.01         ENFORCEMENT/NEGOTIATION  -  CORRESPONDENCE

Title:        Agreement  -- Pine Street Barge Canal  Coordinating  Council.
Authors:       PINE STREET  COORDINATING COUNCIL
Date:         May 27,  1998
Format:       MISCELLANEOUS               No. Pgs:   1
AR No.        10.01.1                       Document  No.   000621


10.07         ENFORCEMENT/NEGOTIATION  -  EPA ADMINISTRATIVE ORDERS

Title:        Administrative Order  by  Consent for Additional
              Remedial Investigation Study   (Phase I) - USEPA Docket No. 1-94-1065.
Authors:       ENVIRONMENTAL  PROTECTION AGENCY
Format:       LITIGATION                        No.  Pgs:  55
AR No.        10.07.1                       Document  No. 000171
Title:
Administrative Order by Consent for Additional

-------
              Remedial Investigation/Feasibility Study - USEPA Docket No. 1-95-1048.
Authors:      ENVIRONMENTAL  PROTECTION AGENCY
Date:         June  30,  199S
Format:       LITIGATION                         No.   Pgs:  222
AR No.        10.07.2                       Document  No.   00516
11.05
              POTENTIALLY  RESPONSIBLE  PARTIES  -  MULTIPLE PRP DOCUMENTS
Title:        Pine  Street  Barge  Canal  Superfund Site  Property Owners.
Date:         June  1991
Format:       LIST                           No.  Pgs:  2
AR No.        11.05.1                       Document No.   000359

Title:        Notification of Meeting  on February 11,  1994  for Potentially Responsible Parties.
Addressee:    JAMES  ROBEAR - BLODGETT  COMPANY
Authors:      MERRILL HOHMAN - ENVIRONMENTAL PROTECTION  AGENCY
Date:         January 12,  1994
Format:       LETTER                        No.  Pgs:  8
AR No.        11.05.2                        Document  No.  000354

Title:        PRP Meeting  Notes  -  February 11,  1994.
Authors:      ENVIRONMENTAL PROTECTION AGENCY
Date:         February  11,  1994
Format:       NOTES-MEETING                No.  Pgs: 10
AR No.        11.05.3                        Document  No.  000355

Title:        PRP Meeting  Summary  of February 11,  1994.
Addressee:    AL SMITH  - MURTHA, CULLINA,  RICHTER, AND PINNEY
Authors:      MARGERY ADAMS - ENVIRONMENTAL PROTECTION AGENCY
Date:         March  7,  1994
Format:       LETTER                        No.  Pgs:  8
AR No.        11.05.4                        Document  No.  000356

Title:        PRP's  Agreement Concerning Allocation of Responsibility.
Addressee:    MARGERY ADAMS - ENVIRONMENTAL PROTECTION AGENCY
Authors:      DAVID  LEDBETTER -  HUNTON AND WILLIAMS
Date:         March  16, 1994
Format:       LETTER                        No.  Pgs:  2
AR No.        11.05.5                        Document  No.  000358

Title:        PRP Internal Settlement.
Authors:      ROSS  GILLELAND - ENVIRONMENTAL PROTECTION  AGENCY
Date:         March  30, 1995
Format:       MEMORANDUM                        No. Pgs:   1
AR No.        11.05.6                      Document No.   000357
11.09
              POTENTIALLY  RESPONSIBLE  PARTIES  -  PRP-SPECIFIC DOCUMENTS
Title:        Responses  to  Comments  on the      Draft SEIS (VTAOT)
Authors:      ENVIRONMENTAL PROTECTION AGENCY
Format:       REPORT,  STUDY              No.  Pgs:   10
AR No.        11.09.1                     Document  No.   000399

Title:        Draft  #2 - Statement of  Work  -  Site  Investigation on the Burlington Department
              of Public Works Property for Contract 6  (City of  Burlington).
Format:       REPORT,  STUDY              No.  Pgs:   28
AR No.        11.09.2                     Document  No.   000402

Title:        Objectives Reguired by EPA/Superfund  - Draft SEIS Comments
              (Vermont Agency of Transportation).
Format:       NOTES-MEETING              No.  Pgs:  6
AR No.        11.09.3                     Document  No.  000422

Title:        Operating  Log of the Gas Plant,  January  10-16,  1926.
Format:       NOTES-GENERAL              No.  Pgs:  1
AR No.        11.09.4                     Document  No.  000650

Title:        Gas Plant  Photographs  Associated with Green Mountain Power Co.
Format:       PHOTO, MICROFORM, VIDEO          No.  Pgs:  28
AR No.        11.09.5                     Document  No.  000654
Title:        Proposed  Plan  (Leverage  Group).
Addressee:    RICHARD GRUNDLER  -  LEVERAGE  GROUP
Authors:      MERRILL HOHMAN  -  EPA REGION  I
Date:         November  6,  1992
Format:       LETTER                       No.  Pgs:  2

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AR No.
              11.09.6
                                          Document  No.  000581
Title:       Building  Permit  (Martin Marietta).
Authors:     GARY  KJELLEREN - MARTIN MARIETTA ARMAMENT  SYSTEMS
Date:        August  24,  1993
Format:      LETTER                       No.  Pgs:  1
AR No.       11.09.7                      Document  No.  000381

Title:       Alternative  Southern  Connector/Burlington  Street Department  Property.
Addressee:   ROSS  GILLELAND - ENVIRONMENTAL  PROTECTION  AGENCY
Authors:     PAUL  CRAVEN  - VERMONT RAILWAY
Date:        August  24,  1993
Format:      MEMORANDUM                       No.  Pgs:  4
AR No.       11.09.8                      Document  No.  000649
Title:

Addressee:
Authors:
Date:
Format:
AR No.
Removing a Property from Superfund Status When
 the  Property is  not Contaminated (Davis Development).
SHEILA ECKMAN - ENVIRONMENTAL PROTECTION AGENCY
DERRICK DAVIS - DAVIS COMPANY
              1993
                            No. Pgs: 3
                            Document No. 000379
September 24,
LETTER
11.09.9
Title:       Draft  Statement  of Work  for  City  of  Burlington;  Champlain Parkway
               (Vermont Agency of Transportation).
Addressee:   ROSS GILLELAND - ENVIRONMENTAL  PROTECTION AGENCY
Authors:     STANLEY  CORNEILLE - VT DEPT.  OF ENVIRONMENTAL  CONSERVATION
Date:        November 9,  1994
Format:      WORK PLAN                   No. Pgs:   20
AR No.       11.09.10                    Document No.  000194

Title:       Comments on  Statement of Work - Draft (Vermont Agency of Transportation).
Addressee:   ROSS GILLELAND - EPA REGION  I
Authors:     SHEILA ECKMAN -  EPA REGION I
Date:        December 13, 1994
Format:      MEMORANDUM                        No.  Pgs:   2
AR No.       11.09.11                    Document No.  000196

Title:       Comments on  the  Statement of Work -  Draft  (Vermont  Agency of Transportation).
Addressee:   STANLEY  CORNEILLE - VT DEPT.  OF ENVIRONMENTAL  CONSERVATION
Authors:     ROSS GILLELAND - EPA REGION  I
Date:        January  4, 1995
Format:      LETTER                      No. Pgs:   4
AR No.       11.09.12                    Document No.  000195
Title:       Burlington  Southern  Connector  (Vermont Agency  of  Transportation).
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:      BETH  ALAFAT
Date:        April 25, 1995
Format:      CORRESPONDENCE
AR No.       11.09.13
                           No. Pgs: 1
                            Document No.  000448
Title:       C2  and  C6 Alignment  Project  -  Early  Coordination (Vermont  Agency of Transportation)
Addressee:   BETH ALAFAT  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     JOHN NAROWSKI  - VERMONT AGENCY OF  TRANSPORTATION
Date:        April 25, 1995
Format:      MEMORANDUM                       No.  Pgs:  1
AR No.       11.09.14                     Document No.  000449

Title:       Burlington Southern  Connector/Champlain  Park Way;
               Notification of Agency Review Meeting (Vermont Agency of Transportation).
Addressee:   ROSS GILLELAND -  ENVIRONMENTAL PROTECTION AGENCY
Authors:     ROBERT  KLIMM,  STERLING WALL  -  HMM  ASSOCIATES INC.
Date:        May 10, 1995
Format:      MEMORANDUM                       No.  Pgs:  4
AR No.       11.09.15                     Document No.  000451

Title:       Southern Connector and Pine  Street Canal
              Superfund  Site Meeting -  May 16,  1995 (Vermont Agency of Transportation).
Addressee:   BARBARA BUCKLEY  -         EARTHTECH
Authors:     ROSS GILLELAND -  ENVIRONMENTAL PROTECTION AGENCY
Date:        May 11, 1995
Format:      LETTER                     No.  Pgs:  4
AR No.       11.09.16                   Document  No.  000450
Title:       Burlington  Southern/Champlain  Park Way Agency
               Meeting Notes - May 16,  1995  (Vermont  Agency of Transportation)
Authors:     HMM ASSOCIATES  INC.

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Date:
Format:
AR No.
May 16, 1995
NOTES-MEETING
11.09.17
No. Pgs:     4
 Document No.000444
Title:       Response  to  Request  as  to Whether  Pine  Street  is
               Considered Part of the Pine Street Canal Superfund Site (City of Burlington).
Addressee:   SUSAN  COMPTON  -  MCNEIL  LEDDY, AND  SHEAHAN
Authors:     MARY JANE 0'DONNELL  - ENVIRONMENTAL PROTECTION AGENCY
Date:        May 18, 1995
Format:      LETTER                      No.  Pgs:  3
AR No.       11.09.18                     Document No.   000369

Title:       Progress  Updates -  Pine Street  Coordinating  Council  (Vermont Agency of Transportation)
Addressee:   STERLING  WALL  -  EARTHTECH
Authors:     ROSS GILLELAND - EPA REGION  I
Date:        June 6, 1995
Format:      MEMORANDUM                             No. Pgs: 1
AR No.       11.09.19                         Document  No.000447

Title:       Minutes of the May  18,  1995  Monthly Meeting
              Regarding the  C2 and C6 Alignment Project (Vermont Agency of Transportation).
Addressee:   ROSS GILLELAND - EPA REGION  I
Authors:     TINA BOHL - VERMONT  AGENCY OF TRANSPORTATION
Date:        June 9, 1995
Format:      MEMORANDUM                      No.  Pgs:  8
AR No.       11.09.20                     Document No.  000446

Title:       Stormwater Sampling  Equipment at the Pine Street  Canal  Site  (Vermont Railway).
Addressee:   DAVID  WULFSON  -  VERMONT RAILWAY
Authors:     GREGORY JOHNSON  - JOHNSON COMPANY
Date:        June 26,  1995
Format:      LETTER                      No.  Pgs:  1
AR No.       11.09.21                          Document No.   000361

Title:       Discussion with  Stephen John, EPA  Regarding  SEIS  Document for VAOT Burlington
              Connector/Champlain Park Way Project (Vermont Agency of  Transportation).
Addressee:   JOHN NAROWSKI  -  VERMONT AGENCY  OF  TRANSPORTATION
Authors:     ROBERT KLIMM - HMM ASSOCIATES INC.
Date:        July 3, 1995
Format:      MEMORANDUM                      No.  Pgs:  1
AR No.       11.09.22                     Document No.   000445

Title:       Construction of  the  New Railway Bridge  (Vermont Railway).
Addressee:   JOHN PENNINGTON  -         VERMONT  RAILWAY
Authors:     GREGORY JOHNSON  -         JOHNSON  COMPANY
Date:        July 7, 1995
Format:      LETTER                    No.  Pgs:  2
AR No.       11.09.23                   Document No.   000362

Title:       Rail Work Around the Pine Street Canal  Superfund  Site (Vermont Railway).
Addressee:   JOHN PENNINGTON  -         VERMONT  RAILWAY
Authors:     ROSS GILLELAND - ENVIRONMENTAL  PROTECTION AGENCY
Date:        July 7, 1995
Format:      LETTER                      No.  Pgs:  2
AR No.       11.09.24                     Document No.  000363

Title:       Minutes of the June  21,  1995 Monthly Meeting
              Regarding the  C2 and C6 Alignment Project (Vermont Agency of Transportation).
Addressee:   ROSS GILLELAND - EPA REGION  I
Authors:     TINA BOHL - VERMONT  AGENCY OF TRANSPORTATION
Date:        July 12,  1995
Format:      MEMORANDUM                      No.  Pgs:  8
AR No.       11.09.25                     Document No.  000440

Title:       Description  of Railwork Performed  at the  Pine
               Street  Canal  Superfund Site (Vermont Railway).
Addressee:   ROSS GILLELAND - ENVIRONMENTAL  PROTECTION AGENCY
Authors:     JOHN PENNINGTON  -         VERMONT  RAILWAY
Date:        July 20,  1995
Format:      LETTER                      No.  Pgs:  2
AR No.       11.09.26                     Document No.  000364
Title:       Burlington  Southern  Connector/Champlain Park  Way
               Project (Vermont Agency of Transportation).
Addressee:   ROSS  GILLELAND  -  EPA REGION I
Authors:     ROBERT  KLIMM  -  HMM ASSOCIATES  INC.
Date:        July  21,  1995
Format:      LETTER                       No.  Pgs:  15

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AR No.
              11.09.27
                                          Document  No.   000439
Title:       Minutes  of  the  July  19,  1995 Monthly  Meeting
                   Regarding the C2 and C6 Alignment Project (Vermont Agency of Transportation)
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:     TINA  BOHL - VERMONT  AGENCY OF  TRANSPORTATION
Date:        August 9, 1995
Format:      MEMORANDUM                        No.  Pgs:  8
AR No.       11.09.28                     Document  No.   000438

Title:       Draft Administrative Order By  Consent for  Highway
              Study -  EPA Docket No.  1-95  (City of Burlington)
Addressee:   SUSAN COMPTON - MCNEIL AND MURRAY
Authors:     MARGERY ADAMS - ENVIRONMENTAL  PROTECTION AGENCY
Date:        August 15,  1995
Format:      LETTER                       No.  Pgs:  59
AR No.       11.09.29                     Document  No. 000404

Title:       Minutes  of  the August 23, 1995 Monthly Meeting
              Regarding the  Burlington C2  and C6 Projects (Vermont Agency of Transportation).
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL PROTECTION  AGENCY
Authors:     TINA  BOHL - VERMONT  AGENCY OF  TRANSPORTATION
Date:        August 23,  1995
Format:      MEMORANDUM                        No.  Pgs:  8
AR No.       11.09.30                     Document  No. 000406

Title:       Brownfields Action Agenda  (Maltex Partnership)
Addressee:   LINDA MURPHY -  ENVIRONMENTAL PROTECTION AGENCY
Authors:     DERRICK  DAVIS - DAVIS COMPANY
Date:        September 18, 1995
Format:      LETTER                       No.  Pgs:  2
AR No.       11.09.31                     Document  No. 000378

Title:       Minutes  of  the  September 13, 1995 Monthly  Meeting
              Regarding the Burlington C2 and  C6 Projects (Vermont Agency of Transportation).
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL PROTECTION  AGENCY
Authors:     ALEC  PORTALUPI  -  VERMONT AGENCY  OF TRANSPORTATION
Date:        September 19, 1995
Format:      MEMORANDUM                        No.  Pgs:  5
AR No.       11.09.32                     Document  No.   000407

Title:       Comments  on the Southern Connector/Champlain Park Way -  Draft  Supplemental
              Environmental Impact Statement  (Vermont Agency of Transportation).
Addressee:   DONALD WEST - FEDERAL HIGHWAY  ADMINISTRATION
Authors:     JOHN  DE VILLARS - EPA REGION I
Date:        September 25, 1995
Format:      LETTER                       No.  Pgs:  11
AR No.       11.09.33                     Document  No. 000441

Title:       Draft #3  -  Statement of  Work - Site Investigation on the Burlington
              Department of Public Works Property  for Contract 6  (City of Burlington).
Date:        October  12, 1995
Format:      REPORT,  STUDY              No. Pgs:  28
AR No.       11.09.34                     Document  No. 000403

Title:       Meeting  Summary of October 17, 1995 Regarding  Hazardous Waste Materials Testing
              at Champlain Park Way (Vermont Agency of  Transportation).
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL PROTECTION  AGENCY
Authors:     ALEC  PORTALUPI  -  VERMONT AGENCY  OF TRANSPORTATION
Date:        October  19, 1995
Format:      MEMORANDUM                        No.  Pgs:  2
AR No.       11.09.35                     Document  No. 000554

Title:       Minutes  of  the  October 18, 1995  Monthly Meeting
              Regarding the  Burlington C2  and C6 Projects (Vermont Agency of Transportation).
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL PROTECTION  AGENCY
Authors:     ALEC  PORTALUPI  -  VERMONT AGENCY  OF TRANSPORTATION
Date:        October  23, 1995
Format:      MEMORANDUM                        No.  Pgs:  5
AR No.       11.09.36                     Document  No. 000408
Title:       Draft  -  Field Activities Work  Plan  -  CG Alignment  Construction,  Southern
              Connecter/Champlain Parkway Project  (Vermont Agency of Transportation).
Addressee:   ROSS GILLELAND  -  ENVIRONMENTAL PROTECTION AGENCY
Authors:      BARBARA  BUCKLEY - EARTHTECH
Date:        November 1,  1995
Format:      REPORT,  STUDY              No.   Pgs:  21
AR No.       11.09.37                   Document  No.  000400

-------
Title:       Decision  Regarding Vermont Agency  of  Transportation  and  City of  Burlington's
              Proposal to Conduct Environmental Investigations  (VTAOT).
Addressee:   SUSAN COMPTON  - MCNEIL  LEDDY, AND  SHEAHAN
Authors:     MARY JANE 0'DONNELL  - ENVIRONMENTAL PROTECTIONAGENCY
Date:        November  7, 1995
Format:      LETTER                      No.  Pgs:  2
AR No.       11.09.38                    Document  No. 000370

Title:       Comments  on the October 19, 1995 and  October  23,  1995  Meeting Summaries  Regarding
              the C2 and C6 Alignment Project (Vermont Agency of  Transportation).
Addressee:   ALEC PORTALUPI - VERMONT AGENCY  OF TRANSPORTATION
Authors:     ROSS GILLELAND - EPA REGION I
Date:        November  8, 1995
Format:      LETTER                     No. Pgs: 5
AR No.       11.09.39                   Document No. 000443

Title:       Comments  on the Draft - Field Activities Work
              Plan -  C6 Alignment  Construction  (Vermont  Agency of Transportation) .
Addressee:   ALEC PORTALUPI - VERMONT AGENCY  OF TRANSPORTATION
Authors:     ROSS: GILLELAND - ENVIRONMENTAL  PROTECTION AGENCY
Date:        November  14, 1995
Format:      LETTER                     No. Pgs: 5
AR No.       11.09.40                   Document No. 000409

Title:       Minutes of the November 15, 1995 Monthly Meeting Regarding the Burlington
              C2 and C6 Projects  (Vermont Agency of Transportation).
Addressee:   ROSE GILLELAND - ENVIRONMENTAL PROTECTION  AGENCY
Authors:     ALEC PORTALUPI - VERMONT AGENCY  OF TRANSPORTATION
Date:        November  27, 1995
Format:      MEMORANDUM                         No.  Pgs: 5
AR No.       11.09.41                     Document No.000410

Title:       B.E.D.  Pine Street Facility Site Work Summary Report (City of Burlington).
Addressee:   ROSS GILLELAND - ENVIRONMENTAL PROTECTION  AGENCY
Authors:     ROGER DONEGAN  - BURLINGTON ELECTRIC DEPARTMENT
Date:        November  29, 1995
Format:      LETTER                       No. Pgs:  32
AR No.       11.09.42                     Document No.  000371

Title:       Comments  on Revision 1  of the Field Activities
               Work  Plan  -  C6 Alignment  Construction (Vermont Agency of Transportation).
Addressee:   ROSS GILLELAND - ENVIRONMENTAL PROTECTION  AGENCY
Authors:     BARBARA BUCKLEY -          EARTHTECH
Date:        December  1995
Format:      REPORT, STUDY               No.  Pgs:  23
AR No.       11.09.43                     Document No.  000401

Title:       Comments  on the Draft - Revision I -  Field
               Activities Work  Plan  - Champlain  Parkway  Contract 6.
Addressee:   ALEC PORTALUPI - VERMONT AGENCY  OF TRANSPORTATION
Authors:     ROSS GILLELAND - EPA REGION I
Date:        December  13, 1995
Format:      LETTER                       No. Pgs:  5
AR No.       11.09.44                     Document No.  000424

Title:       Southern  Connector - E-Mail Message  (Vermont  Agency  of Transportation).
Addressee:   ROSS GILLELAND - EPA REGION I
Authors:     KATE QUINN
Date:        January 18, 1996
Format:      CORRESPONDENCE              No.  Pgs:  1
AR No.       11.09.45                     Document No.  000411

Title:       Southern  Connector - Reply - E-Mail Message  (Vermont Agency of Transportation).
Addressee:   KATE QUINN
Authors:     ROSS GILLELAND - EPA REGION I
Date:        January 18, 1996
Format:      CORRESPONDENCE              No.  Pgs:  1
AR No.       11.09.46                     Document No.000412
Title:        Field Activities Workplan  Received  -  E-Mail Message  (Vermont Agency of  Transportation)
Addressee:    ROSS GILLELAND  - EPA REGION  I
Authors:       KATE QUINN
Date:         January  22,  1996
Format:       CORRESPONDENCE               No.  Pgs:   1
AR No.        11.09.47                     Document No.000413

Title:        Questions Regarding  the  C6 Interim  Alignment  Project
               (Vermont Agency of Transportation).

-------
Addressee:   KATE  QUINN
Authors:     ROSS  GILLELAND  -  EPA REGION  I
Date:        January  24,  1996
Format:      CORRESPONDENCE               No.  Pgs:   1
AR No.       11.09.48                     Document  No.000414

Title:       Review of the Field  Activities Workplan  (Vermont Agency  of  Transportation).
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:     KATE  QUINN
Date:        January  24,  1996
Format:      CORRESPONDENCE               No.  Pgs:   2
AR No.       11.09.49                     Document  No.000417

Title:       Field Activities  Workplan  -  Response - E-Mail Message
               (Vermont Agency  of  Transportation).
Addressee:   KATE  QUINN
Authors:     ROSS  GILLELAND  -  EPA REGION  I
Date:        January  25,  1996
Format:      CORRESPONDENCE               No.  Pgs:   2
AR No.       11.09.50                     Document  No.000416

Title:       Comments on  the Field Activities Workplan -
                   E-Mail  Message  (Vermont Agency of Transportation).
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:     KATE  QUINN
Date:        January  25,  1996
Format:      CORRESPONDENCE               No. Pgs:  2
AR No.       11.09.51                      Document No.000437

Title:       Comments on  Revision II- Draft Field Activities
             Work Plan  -  C6  Alignment  Construction  (Vermont  Agency of Transportation).
Addressee:   ALEC  PORTALUPI  -  VERMONT AGENCY  OF TRANSPORTATION
Authors:     ROSS  GILLELAND  -  EPA REGION  I
Date:        February 2,  1996
Format:      LETTER                        No.  Pgs: 8
AR No.       11.09.52                      Document No.  000421

Title:       Meeting Agenda  -  To  Discuss  the  Status of the
             Burlington MEGC - M5000 (1)  Project (Vermont Agency of Transportation).
Date:        February 26, 1996
Format:      NOTES-MEETING                No. Pgs:  1
AR No.       11.09.53                      Document No.  000423

Title:       Minutes  of the  January  17, 1996  Monthly Meeting
             Regarding  the  C2  and C6 Alignment  Project (Vermont Agency of Transportation).
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:     TINA  BOHL -  VERMONT  AGENCY OF TRANSPORTATION
Date:        February 27, 1996
Format:      MEMORANDUM                         No.  Pgs:  4
AR No.       11.09.54                     Document  No.  000428

Title:       Vermont AOT  Febrary  28  Meeting Notes - E-Mail  (Vermont Agency of  Transportation)
Addressee:   KATE  QUINN
Authors:     ROSS  GILLELAND  -  EPA REGION  I
Date:        February 28, 1996
Format:      CORRESPONDENCE               No. Pgs:   1
AR No.       11.09.55                      Document No.   000429

Title:       Monthly Meeting Regarding  the C2 and C6 Alignment  Project Canceled,
              Meeting Rescheduled  for April 1,  1996 (Vermont Agency of Transportation).
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:     TINA  BOHL -  VERMONT  AGENCY OF TRANSPORTATION
Date:        March 18, 1996
Format:      MEMORANDUM                    No.  Pgs: 1
AR No.       11.09.56                      Document No.   000431

Title:       Minutes  of the  February 28,  1996 Monthly  Meeting
              Regarding the  C2 and C6 Alignment Project  (Vermont Agency of Transportation)
Addressee:   ROSS  GILLELAND  -  EPA REGION  I
Authors:     TINA  BOHL -  VERMONT  AGENCY OF TRANSPORTATION
Date:        March 22, 1996
Format:      MEMORANDUM                   No. Pgs:  7
AR No.       11.09.57                     Document  No.   000432
Title:       Vermont AOT Meeting Notes  -  Reply  -  E-Mail
Addressee:   ROSS  GILLELAND  -  EPA  REGION  I
Authors:      KATE  QUINN
Date:        April  2,  1996
(Vermont Agency  of  Transportation)

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Format:
AR No.
CORRESPONDENCE
11.09.58
No. Pgs:  2
Document No.  000430
Title:       Minutes  of  the April  1,  1996  Monthly Meeting Regarding the C2  and C6 Alignment Project
               (Vermont Agency of Transportation).
Addressee:   ROSS  GILLELAND - EPA  REGION I
Authors:     TINA  BOHL - VERMONT AGENCY OF TRANSPORTATION
Date:        April  17, 1996
Format:      MEMORANDUM                    No.  Pgs:   8
AR No.       11.09.59                     Document No.   000433

Title:       Minutes  of  the May 1,  1996 Monthly Meeting
              Regarding the C2 and C6 Alignment  Project  (Vermont Agency  of  Transportation).
Addressee:   ROSS  GILLELAND - EPA  REGION I
Authors:     TINA  BOHL - VERMONT AGENCY OF TRANSPORTATION
Date:        May 21,  1996
Format:      MEMORANDUM                    No.  Pgs:   8
AR No.       11.09.60                     Document No.   000434

Title:       EPA's  Comments on the April Environmental  Report  -  E-Mail
               (Vermont Agency of Transportation).
Addressee:   ROSS  GILLELAND - EPA  REGION I
Authors:     KATE  QUINN
Date:        May 29,  1996
Format:      CORRESPONDENCE                No.  Pgs:   1
AR No.       11.09.61                     Document No.   000435

Title:       Reply  to EPA's Comments  on the April
              Environmental Report - E-Mail (Vermont Agency of Transportation).
Addressee:   ROSS  GILLELAND - EPA  REGION I
Authors:     KATE  QUINN
Date:        May 30,  1996
Format:      CORRESPONDENCE                No.  Pgs:   1
AR No.       11.09.62                     Document No.   000436

Title:       Final  Supplemental Environmental  Impact Statement  (Vermont Agency of Transportation).
Authors:     FEDERAL  HIGHWAY ADMINISTRATION
Date:        February 1997
Format:      REPORT,  STUDY                 No.  Pgs:   575
AR No.       11.09.63                     Document No.   000456

Title:       Environmental Data on  Pine Street Canal  (Vermont  Transit).
Addressee:   JOHN  SHARROW - VERMONT TRANSIT COMPANY
Authors:     ROSS  GILLELAND - ENVIRONMENTAL PROTECTION  AGENCY
Date:        May 1, 1997
Format:      LETTER                       No.  Pgs:   16
AR No.       11.09.64                     Document No.   000372

Title:       Approval of Zoning Permit  (Vermont Transit).
Addressee:   ROSS  GILLELAND - ENVIRONMENTAL PROTECTION  AGENCY
Authors:     JOHN  SHARROW - VERMONT TRANSIT COMPANY
Date:        May 6, 1997
Format:      MISCELLANEOUS                 No.  Pgs:   1
AR No.       11.09.65                     Document No.   000373

Title:       Land  Use -  Pine Street Canal  Superfund Site (Vermont  Transit).
Addressee:   JOHN  SHARROW - VERMONT TRANSIT COMPANY
Authors:     ROSS  GILLELAND - ENVIRONMENTAL PROTECTION  AGENCY
Date:        May 9, 1997
Format:      LETTER                       No.  Pgs:   5
AR No.       11.09.66                     Document No.   000365

Title:       Comments on the Southern Connector/Champlain Park Way - Final  Supplemental
              Environmental Impact Statement  (Vermont Agency of Transportation).
Addressee:   FREDERICK DOWNS - FEDERAL  HIGHWAY ADMINISTRATION
Authors:     ELIZABETH HIGGINS - OFFICE OF ENVIRONMENTAL REVIEW
Date:        May 20,  1997
Format:      LETTER                       No.  Pgs:   13
AR No.       11.09.67                     Document No.   000442

Title:       Redevelopment of the  Pine  Street  Barge Canal Site  (City of Burlington).
Addressee:   PINE  STREET COORDINATING COUNCIL
Authors:     PETER  CLAVELLE - BURLINGTON OFFICE OF THE  MAYOR
Date:        June  16, 1997
Format:      LETTER                       No.  Pgs:   2
AR No.       11.09.68                     Document No.   000367
Title:
Redevelopment at the Pine Street Canal Superfund Site  (City of Burlington)

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Addressee:    JOHN  DE VILLARS  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:       PETER CLAVELLE - BURLINGTON  OFFICE  OF  THE  MAYOR
Date:         July  1, 1997
Format:       LETTER                       No.  Pgs:   2
AR No.        11.09.69                      Document  No.   000368

Title:        Redefinition  of  the  Boundary Lines  for the Pine
              Street Canal Superfund Site  (City  of  Burlington).
Addressee:    PETER CLAVELLE BURLINGTON  OFFICE OF THE MAYOR
Authors:       JOHN  DE VILLARS  ENVIRONMENTAL PROTECTION AGENCY
Date:         August 6,  1997
Format:       LETTER                       No.  Pgs:   9
AR No.        11.09.70                      Document  No.   000366

Title:        Building  Permit  to the  City  of Burlington  (City of Burlington).
Addressee:    ROSS  GILLELAND ENVIRONMENTAL PROTECTION AGENCY
Authors:       JOHN  SHARROW  - VERMONT  TRANSIT COMPANY
Date:         August 21,  1997
Format:       LETTER                       No.  Pgs:   11
AR No.        11.09.71                      Document  No.   000374
Title:       Response  to  Civil  Engineering Associates,  Inc.  Letter Dated August 28,
              Regarding the Central Fueling Depot  (City of Burlington).
Authors:     ROSS  GILLELAND  - EPA REGION  I
Date:        September 11, 1997
Format:      MEMORANDUM                   No.  Pgs:   9
AR No.       11.09.72                      Document  No.  000199
                                                                       1997
Title:       City  of  Burlington  Central  Fueling Depot  (City of Burlington).
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     JEFF  PADGETT  -  CIVIL  ENGINEERING ASSOCIATES  INC.
Date:        September  24, 1997
Format:      LETTER                        No.  Pgs:  4
AR No.       11.09.73                     Document  No.  000375

Title:       EPA's Concerns  with Respect to  Development  and
              Land Use at the Pine Street Canal  Superfund Site  (City of Burlington).
Addressee:   JEFF  PADGETT  -  CIVIL  ENGINEERING ASSOCIATES  INC.
Authors:     ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTTON AGENCY
Date:        October  20, 1997
Format:      LETTER                        No.  Pgs:  2
AR No.       11.09.74                     Document  No.  000376

Title:       Record of  Decision  for  Champlain Parkway  (Vermont Agency  of  Transportation)
Addressee:   ELIZABETH  HIGGINS - ENVIRONMENTAL  PROTECTION AGENCY
Authors:     TINA  BOHL  - VERMONT AGENCY  OF TRANSPORTATION
Date:        October  20, 1997
Format:      REPORT,  STUDY                 No.  Pgs:  62
AR No.       11.09.75                     Document  No.  000457

Title:       October  20, 1997  Letter Regarding  the City  of
              Burlington's Proposed  Central Fueling Depot (City  of Burlington).
Addressee:   ROSS  GILLELAND  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     CHRIS CRANDELL  -  JOHNSON COMPANY
Date:        November 7, 1997
Format:      LETTER                        No.  Pgs:  1
AR No.       11.09.76                     Document  No.  000377


13.01        COMMUNITY  RELATIONS - CORRESPONDENCE

Title:       Reguest  that  the  Burlington Board  of Health  Be
              Made a  Full Member of  the  Pine  Street Canal Coordinating Committee.
Addressee:   PINE  STREET COORDINATING COUNCIL
Authors:     ZARA  ZSIDO -  BURLINGTON BOARD OF HEALTH
Format:      LETTER                        No.  Pgs:  2
AR No.       13.01.1                       Document  No.  000651

Title:       Nomination of Pine  Street Canal  Superfund Site
              for Non-Binding Alternative Dispute Resolution.
Addressee:   WILLIAM  WHITE ENVIRONMENTAL PROTECTION  AGENCY
Authors:     HARLEY LAING  ENVIRONMENTAL  PROTECTION AGENCY
Date:        June  17, 1993
Format:      MEMORANDUM                   No.  Pgs:  2
AR No.       13.01.2                       Document  No.  000001
Title:
Addressee:
Memorandum Concerning a Revised Copy of the Press Release on Superfund Process.
LEO KAY - EPA REGION I

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Authors:      LORI  FISHER  -  LAKE  CHAMPLAIN COMMITTEE
Date:         November  18,  1993
Format:       MEMORANDUM                     No.  Pgs:   1
AR No.        13-01.3                        Document  No.   000576

Title:        Pine  Street  Canal - No  Fishing Posting.
Authors:      STEVEN GOODKIND  - BURLINGTON DEPARTMENT OF  PUBLIC HEALTH
Date:         July  18,  1994
Format:       MEMORANDUM                     No.  Pgs:   1
AR No.        13.01.4                        Document  No.   000474
13.03

Title:
Authors:
Format:
AR No.
COMMUNITY RELATIONS - NEWS CLIPPINGS/PRESS RELEASES
Plan in Progress.
BETSEY KRUMHOLTZ
NEWS CLIPPING
13.03.1
No. Pgs:  1
Document No.  000496
Title:
Authors:
Format:
AR No.
Residents Discuss Southern Connector.
MEGHAN MC MENIMEN - BURLINGTON FREE PRESS
NEWS CLIPPING                 No. Pgs:  1
13.03.2                       Document No.  000497
Title:
Authors:
Format:
AR No.
Southern Connector Debate.
BURLINGTON FREE PRESS
NEWS CLIPPING
13.03.3
No. Pgs:  1
Document No.  000498
Title:
Authors:
Format:
AR No.
Pine Street Detour.
RAY UNSWORTH - BURLINGTON FREE PRESS
NEWS CLIPPING                 No. Pgs:  1
13.03.4                       Document No.  000500
Title:
Authors:
Format:
AR No.
Connector Takes Curves.
SONA IYENGAR - BURLINGTON FREE PRESS
NEWS CLIPPING                 No. Pgs:  2
13.03.5                       Document No.  000501
Title:
Authors:
Date:
Format:
AR No.
NEES Zapped by Cost of Toxic Cleanups.
DAN ROSENFELD
NEWS CLIPPING
13.03.6
No. Pgs:  1
Document No.  000523
Title:        Southern  Connector  Still  Snagged.
Authors:      ANN  DONIAN  -  BURLINGTON FREE  PRESS
Date:         March  18, 1990
Format:       NEWS CLIPPING                 No. Pgs:   4
AR No.        13.03.7                        Document  No.   000521

Title:        EPA  Tells Pine  St.  Residents  Don't  Worry,  Be Happy.
Authors:      GEORGE LAYING - VERMONT TIMES
Date:         December  13,  1990
Format:       NEWS CLIPPING                 No. Pgs:   1
AR No.        13.03.8                        Document  No.   000589

Title:        Lake Champlain  Committee  to Apply for EPA  Grant
              to  Oversee Pine St. Barge Canal Superfund Project.
Authors:      ENVIRONMENTAL PROTECTION  AGENCY
Date:         August 20,  1992
Format:       FACT SHEET, PRESS RELEASE     No. Pgs:   2
AR No.        13.03.9                        Document  No.   000139

Title:        EPA  Proposes  Contaminant  and  Limited Excavation
              of  Coal Tar  - Contaminated Wastes  at Pine Street Barge Canal Superfund Site.
Authors:      ENVIRONMENTAL PROTECTION  AGENCY
Date:         November  6, 1992
Format:       FACT SHEET, PRESS RELEASE     No. Pgs:   3
AR No.        13.03.10                       Document  No.   000132

Title:        Clavelle  Seeks  More Time  for  Comment on Cleanup.
Authors:      PAUL TEETOR - BURLINGTON  FREE PRESS
Date:         November  24,  1992
Format:       NEWS CLIPPING                 No. Pgs:   1
AR No.        13.03.11                       Document  No.   000587
Title:
EPA Postpones Hearing, Opts for Availability

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              Session on Pine Street Barge Canal Cleanup Proposal.
Authors:      EPA  REGION  I
Date:        December  4, 1992
Format:      FACT SHEET, PRESS  RELEASE     No.  Pgs:   2
AR No.       13.03.12                      Document  No.   000588

Title:       EPA  Extends Comment  Period  Until May  15,  1993  on
              Cleanup Proposal for Pine  St. Barge Canal.
Authors:      ENVIRONMENTAL  PROTECTION AGENCY
Date:        December  7, 1992
Format:      FACT SHEET, PRESS  RELEASE     No.  Pgs:   2
AR No.       13.03.13                      Document  No.   000133

Title:       EPA  Awards  $50,000 Grant to Lake Champlain
              Committee to Oversee Pine  St. Barge Canal Superfund Project.
Authors:      ENVIRONMENTAL  PROTECTION AGENCY
Date:        December  8, 1992
Format:      FACT SHEET, PRESS  RELEASE     No.  Pgs:   2
AR No.       13.03.14                      Document  No.   000134

Title:       Barge Canal to  be  Discussed at January  Meeting.
Authors:      WARD FIVE NEIGHBORHOOD ASSEMBLY NEWS
Date:        January 1993
Format:      FACT SHEET, PRESS  RELEASE     No.  Pgs:   4
AR No.       13.03.15                      Document  No.   000145

Title:       Mother Nature Will Clean Up the Barge Canal.
Authors:      RICHARD BARTLETT - BURLINGTON FREE PRESS
Date:        January 3,  1993
Format:      NEWS CLIPPING                 No.  Pgs:   1
AR No.       13-03.16                      Document  No.   000524
Title:        Superfund  Proposes  Super-foolish  Solution.
Authors:       BURLINGTON FREE  PRESS
Date:         February 11,  1993
Format:       NEWS  CLIPPING                 No.  Pgs:   2
AR No.        13.03.17                       Document  No.
                                                          000526
Title:       A Dump  as  Big  as  the Mall.
Authors:      BURLINGTON FREE PRESS
Date:        February 12, 1993
Format:      NEWS  CLIPPING
AR No.       13.03.18
No. Pgs:  1
Document No.  000527
Title:       Dean,  EPA  Official  to  Discuss  Barge  Canal.
Authors:      BURLINGTON FREE  PRESS
Date:        February 18,  1993
Format:      NEWS  CLIPPING                 No.  Pgs:   1
AR No.       13.03.19                       Document  No.   000528

Title:       Agency Tells  Lawmakers Not  to  Interfere with Superfund Plan.
Authors:      NANCY BAZILCHUK  - BURLINGTON FREE  PRESS
Date:        February 20,  1993
Format:      NEWS  CLIPPING                 No.  Pgs:   1
AR No.       13.03.20                       Document  No.   000529

Title:       Lawmakers  Asked  to  Stay Neutral  on Barge Canal
Authors:      RUTLAND HERALD
Date:        February 21,  1993
Format:      NEWS  CLIPPING                 No.  Pgs:   1
AR No.       13.03.21                       Document  No.   000530

Title:       Mother Nature 10, EPA  0 (Various Authors).
Authors:      THOMAS BATES, MIKE  BARSOTTI, ERNST CARLSON,  JOHN POOLE -  BURLINGTON FREE PRESS
Date:        February 21,  1993
Format:      NEWS  CLIPPING                 No.  Pgs:   2
AR No.       13.03.22                       Document  No.   000531

Title:       Silence Won't Stop  Barge Canal Plan.
Authors:      BURLINGTON FREE  PRESS
Date:        February 23,  1993
Format:      NEWS  CLIPPING                 No.  Pgs:   1
AR No.       13.03.23                       Document  No.   000532
Title:       EPA  Flexible  on  Barge  Canal.
Authors:     NANCY  BAZILCHUK  -  BURLINGTON  FREE  PRESS
Date:        February  26,  1993
Format:      NEWS CLIPPING                 No.  Pgs:   1

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AR No.
              13.03.24
                                            Document  No.   000533
Title:       EPA  Open  to  Canal Alternatives.
Authors:     BARRE  TIMES-ARGUS
Date:        February  26,  1993
Format:      NEWS CLIPPING                 No.  Pgs:   1
AR No.       13.03.25                       Document  No.   000534

Title:       Today's Public  Forum Focuses  on  Barge Canal.
Authors:     BURLINGTON FREE PRESS
Date:        March  6,  1993
Format:      NEWS CLIPPING                 No.  Pgs:   1
AR No.       13.03.26                       Document No.   000535

Title:       Residents Blast Barge  Canal Plan.
Authors:     TOM  HACKER - BURLINGTON  FREE  PRESS
Date:        March  7,  1993
Format:      NEWS CLIPPING                 No.  Pgs:   1
AR No.       13.03.27                       Document No.   000536

Title:       EPA  Concerned about  Barge  Canal  Cleanup.
Authors:     WILLIAM KEOUGH  - BURLINGTON FREE PRESS
Date:        March  15, 1993
Format:      NEWS CLIPPING                 No.  Pgs:   1
AR No.       13.03.28                       Document No.   000537

Title:       Barge  Canal  Risks Reported.
Authors:     NANCY  BAZILCHUK - BURLINGTON  FREE  PRESS
Date:        March  16, 1993
Format:      NEWS CLIPPING                 No.  Pgs:   2
AR No.       13.03.29                       Document No.   000538

Title:       Vermont Must Learn to  Live with  Superfund Law.
Authors:     JEFFREY KIMMEL  - BARRE TIMES-ARGUS
Date:        March  25, 1993
Format:      NEWS CLIPPING                 No.  Pgs:   1
AR No.       13.03.30                       Document No.   000539

Title:       Barge  Canal  Tests Challenged.
Authors:     NANCY  BAZILCHUK - BURLINGTON  FREE  PRESS
Date:        April  7,  1993
Format:      NEWS CLIPPING                 No.  Pgs:   1
AR No.       13.03.31                       Document No.   000542

Title:       Panel  Blasts Barge Canal Site.
Authors:     NANCY  BAZILCHUK - BURLINGTON  FREE  PRESS
Date:        April  10, 1993
Format:      NEWS CLIPPING                 No.  Pgs:   1
AR No.       13.03.32                       Document No.   000541
Title:       Delay Asked  in Vt.  Cleanup.
Authors:      BOSTON  GLOBE
Date:        April 11,  1993
Format:      NEWS CLIPPING
AR No.       13.03.33
No. Pgs:  1
Document No.  000543
Title:       Hitting  Solid  Ground  in  the  Barge  Canal.
Authors:      BURLINGTON  FREE  PRESS
Date:        April  11, 1993
Format:      NEWS CLIPPING                    No.  Pgs:   1
AR No.       13.03.34                         Document  No.   000544
Title:       Learning  an  EPA Lesson.
Authors:     NANCY  BAZILCHUK -  BURLINGTON  FREE  PRESS
Date:        April  12,  1993
Format:      NEWS CLIPPING                    No.  Pgs:   2
AR No.       13.03.35                         Document  No.
                                                            000545
Title:       Barge  Canal  Resolution  Backed  -  In Brief  .
Authors:      BURLINGTON FREE  PRESS
Date:        April  15, 1993
Format:      NEWS CLIPPING                    No.  Pgs:   1
AR No.       13.03.36                         Document  No.   000546
Title:       EPA  and  the  $50 Million Worm.
Authors:     GAYLE HANSON - INSIGHT ON  THE  NEWS
Date:        April 18,  1993
Format:      NEWS CLIPPING                   No.  Pgs:

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AR No.
              13.03.37
                                              Document  No.   000547
Title:       EPA  Plan  Called Mall  Size  Error.
Authors:     NANCY  BAZILCHUK -  BURLINGTON  FREE  PRESS
Date:        April  28,  1993
Format:      NEWS CLIPPING                   No.  Pgs:   1
AR No.       13.03.38                        Document  No.   000548

Title:       State  Suggests Alternatives to  Barge Canal Plan.
Authors:     NANCY  BAZILCHUK -  BURLINGTON  FREE  PRESS
Date:        April  30,  1993
Format:      NEWS CLIPPING                   No.  Pgs:   1
AR No.       13.03.39                        Document  No.   000549

Title:       Vermont Official Disputes  Need  for EPA Mandated Landfill.
Authors:     MAINE  TELEGRAM
Date:        May  2, 1993
Format:      NEWS CLIPPING                   No.  Pgs:   1
AR No.       13.03.40                        Document  No.   000550
Title:        $50 Million Molasses  Cleanup.
Authors:       BURLINGTON FREE  PRESS
Date:         May 3,  1993
Format:       NEWS  CLIPPING
AR No.        13.03.41
No. Pgs:  1
Document No.  000551
Title:       Council,  Panel  Oppose  Barge  Canal  Cleanup  Plan.
Authors:     NANCY  BAZILCHUK -  BURLINGTON FREE  PRESS
Date:        May  4,  1993
Format:      NEWS CLIPPING                    No.  Pgs:   1
AR No.       13.03.42                         Document No.   000552

Title:       EPA  Scraps Barge Canal Cleanup  Plan.
Authors:     NANCY  BAZILCHUK -  BURLINGTON FREE  PRESS
Date:        May  5,  1993
Format:      NEWS CLIPPING                    No.  Pgs:   1
AR No.       13.03.43                         Document No.   000553

Title:       Agency to Propose  Barge Canal Plan.
Authors:     BETSY  LILEY  - BURLINGTON FREE PRESS
Date:        May  6,  1993
Format:      NEWS CLIPPING                    No.  Pgs:   1
AR No.       13.03.44                         Document No.   000555

Title:       UVM  Study Blasts EPA Research.
Authors:     NANCY  BAZILCHUK -  BURLINGTON FREE  PRESS
Date:        May  6,  1993
Format:      NEWS CLIPPING                    No.  Pgs:   1
AR No.       13.03.45                         Document No.   000590
Title:       Next  on  Pine  Street?
Authors:      BURLINGTON  FREE  PRESS
Date:        May 7, 1993
Format:      NEWS  CLIPPING
AR No.       13.03.46
 No. Pgs:  1
 Document No.  000556
Title:       Earth  to  EPA Regulators:  Drop  Dead.
Authors:      BURLINGTON  FREE  PRESS
Date:        May  12, 1993
Format:      NEWS CLIPPING                    No.  Pgs:   1
AR No.       13.03.47                          Document  No.   000557

Title:       Barge  Canal  Comments Filed.
Authors:      NANCY  BAZILCHUK  -  BURLINGTON FREE PRESS
Date:        May  17, 1993
Format:      NEWS CLIPPING                    No.  Pgs:   1
AR No.       13.03.48                          Document  No.   000558

Title:       Drums  Leak  on Canal Waste Site.
Authors:      NANCY  BAZILCHUK  -  BURLINGTON FREE PRESS
Date:        May  28, 1993
Format:      NEWS CLIPPING                    No.  Pgs:   1
AR No.       13.03.49                          Document  No.   000559
Title:       Media Advisory.
Authors:     ENVIRONMENTAL  PROTECTION AGENCY
Date:        June 3,  1993
Format:      FACT SHEET, PRESS  RELEASE         No.
     Pgs:

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AR No.
              13.03.50
                                               Document  No.   000560
Title:       EPA  Drops  Barge  Canal  Cleanup  Plan  in  Response  to  Community Concerns.
Authors:     ENVIRONMENTAL  PROTECTION AGENCY
Date:        June 4,  1993
Format:      FACT SHEET, PRESS  RELEASE         No. Pgs:   2
AR No.       13.03.51                          Document  No.   000561

Title:       $50  Million Barge  Canal Plan Killed.
Authors:     NANCY BAZILCHUK  -  BURLINGTON FREE PRESS
Date:        June 5,  1993
Format:      NEWS CLIPPING                     No.  Pgs:  2
AR No.       13.03.52                          Document No.   000562

Title:       Superfund  Cleanup  -  Editorial  Page.
Authors:     BURLINGTON FREE  PRESS
Date:        June 6,  1993
Format:      NEWS CLIPPING                     No.  Pgs:  1
AR No.       13.03.53                          Document No.   000563

Title:       Drums to be Removed  from Pine  Street Canal Site.
Authors:     ENVIRONMENTAL  PROTECTION AGENCY
Date:        August 12, 1993
Format:      FACT SHEET, PRESS  RELEASE         No.  Pgs:  1
AR No.       13.03.54                          Document No.   000147

Title:       Vt.  Taps Residents Opinions about State's  Waters Policy.
Authors:     NANCY BAZILCHUK  -  BURLINGTON FREE PRESS
Date:        August 12, 1993
Format:      NEWS CLIPPING                     No.  Pgs:  2
AR No.       13.03.55                          Document No.   000564

Title:       EPA  Alters Approach  to Canal.
Authors:     NANCY BAZILCHUK  -  BURLINGTON FREE PRESS
Date:        September  6, 1993
Format:      NEWS CLIPPING                     No.  Pgs:  1
AR No.       13.03.56                          Document No.   000665

Title:       Coordinating Council Forms to  Address  Pine Street  Barge  Canal  Superfund Site.
Authors:     ENVIRONMENTAL  PROTECTION AGENCY
Date:        September  17,  1993
Format:      FACT SHEET, PRESS  RELEASE         No.  Pgs:  2
AR No.       13.03.57                          Document No.   000566

Title:       In Vt. ,  EPA Chief  Urges Flexible  Review  Process.
Authors:     RUTLAND HERALD
Date:        September  19,  1993
Format:      NEWS CLIPPING                     No.  Pgs:  2
AR No.       13.03.58                          Document No.   000583

Title:       EPA  Chief  Gives  and  Takes.
Authors:     NANCY BAZILCHUK  -  BURLINGTON FREE PRESS
Date:        September  19,  1993
Format:      NEWS CLIPPING                     No.  Pgs:  2
AR No.       13.03.59                          Document No.   000584

Title:       EPA  Head Calls for More Environmental  Cooperation.
Authors:     WILSON RING -  CALEDONIAN RECORD
Date:        September  20,  1993
Format:      NEWS CLIPPING                     No.  Pgs:  1
AR No.       13.03.60                          Document No.   000585

Title:       EPA  Launches Pilot Project to  Increase Public Input  into Superfund.
Authors:     INSIDE EPA
Date:        September  24,  1993
Format:      FACT SHEET, PRESS  RELEASE         No.  Pgs:  1
AR No.       13.03.61                          Document No.   000567

Title:       Barge Canal Cleanup  Plan a Challenge.
Authors:     NANCY BAZILCHUK  -  BURLINGTON FREE PRESS
Date:        September  28,  1993
Format:      NEWS CLIPPING                     No.  Pgs:  1
AR No.       13.03.62                          Document No.   000568
Title:       EPA  Extends  Burlington  Citizen's  Group  Grant.
Authors:     ENVIRONMENTAL  PROTECTION AGENCY
Date:        October  12,  1993
Format:      FACT SHEET,  PRESS  RELEASE          No. Pgs:   2

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AR No.
              13.03.63
                                                Document  No.   000148
Title:       City has  Plan  to Make  Southern  Connector  a  Go.
Authors:     NANCY BAZILCHUK -  BURLINGTON  FREE  PRESS
Date:        October 15,  1993
Format:      NEWS CLIPPING                       No. Pgs:   1
AR No.       13.03.64                            Document No.   000570

Title:       Superfund Panel's  in Spotlight  and Cleanup  Committee  Receives Another  Grant.
Authors:     NANCY BAZILCHUK -  BURLINGTON  FREE  PRESS
Date:        October 15,  1993
Format:      NEWS CLIPPING                       No. Pgs:   1
AR No.       13.03.65                            Document No.   000571

Title:       EPA Agrees to  Work on  City's  Access Road.
Authors:     NANCY BAZILCHUK -  BURLINGTON  FREE  PRESS
Date:        October 27,  1993
Format:      NEWS CLIPPING                       No. Pgs:   1
AR No.       13.03.66                            Document No.   000572

Title:       Pine Street Coordinating  Council to Review  Risk
              Assessment Process - LAN Message  and Public Safety Announcement Attached.
Date:        November  1993
Format:      FACT SHEET,  PRESS  RELEASE           No. Pgs:   3
AR No.       13.03.67                            Document No.   000573

Title:       Ward Five Neighborhood Planning Assembly  News -
              November  10,  7:30 P.M. at South Meadows Community Room.
Authors:     WARD FIVE NEIGHBORHOOD ASSEMBLY NEWS
Date:        November  1993
Format:      FACT SHEET,  PRESS  RELEASE           No. Pgs:   2
AR No.       13.03.68                            Document No.   000574

Title:       Pine Street Coordinating  Council to Review  Superfund  Process -  Rough Draft.
Authors:     ENVIRONMENTAL  PROTECTION AGENCY
Date:        November  1993
Format:      FACT SHEET,  PRESS  RELEASE           No. Pgs:   1
AR No.       13.03.69                            Document No.   000577

Title:       Two Vermonters: Superfund Law Needs Cleaning Up.
Authors:     BURLINGTON FREE PRESS
Date:        November  9,  1993
Format:      NEWS CLIPPING                 No.  Pgs: 1
AR No.       13.03.70                      Document No.  000575

Title:       Vermont Develops "First in Nation" Superfund Coordinating  Council  -  Draft.
Date:        November  18, 1993
Format:      FACT SHEET,  PRESS  RELEASE     No.  Pgs: 2
AR No.       13.03.71                      Document No.  000578

Title:       Pine Street Coordinating  Council to Review  Superfund  Process.
Authors:     PINE STREET COORDINATING  COUNCIL
Date:        November  23, 1993
Format:      FACT SHEET,  PRESS  RELEASE     No.  Pgs: 1
AR No.       13.03.72                      Document No.  000579

Title:       Superfund Site Poses More Questions.
Authors:     NANCY BAZILCHUK -  BURLINGTON  FREE  PRESS
Date:        December  2,  1993
Format:      NEWS CLIPPING                 No.  Pgs: 1
AR No.       13.03.73                      Document No.  000580

Title:       Pine Street Barge  Canal Update.
Authors:     DOUG HOFFER -  BURLINGTON  BEAT
Date:        1994
Format:      NEWS CLIPPING                 No.  Pgs: 1
AR No.       13.03.74                      Document No.  000459

Title:       Panel Lists Questions  About Barge  Cleanup,  Urges  Study.
Authors:     NANCY BAZILCHUK -  BURLINGTON  FREE  PRESS
Date:        January 7,  1994
Format:      NEWS CLIPPING                 No.  Pgs: 1
AR No.       13.03.75                      Document No.  000460
Title:       Dean  Says  Editorials  Nice  But  Can't Vote.
Authors:     CANDACE  PAGE  -  BURLINGTON  FREE PRESS
Date:        January  9,  1994
Format:      NEWS  CLIPPING                 No.  Pgs:  1

-------
AR No.
              13.03.76
                                            Document  No.  000461
Title:       Administration  Pushes  for  Superfund  Fix.
Authors:     JOSEF HEBERT  -  BURLINGTON  FREE  PRESS
Date:        February  4, 1994
Format:      NEWS CLIPPING                No.  Pgs:  1
AR No.       13.03.77                      Document  No.  000464

Title:       Notice  of Schedule  of  Meetings  of  the Pine  Street
              Canal Coordinating Council  (Federal Register Announcement.
Authors:     FEDERAL REGISTER
Date:        March 2,  1994
Format:      MISCELLANEOUS                No.  Pgs:  1
AR No.       13.03.78                      Document  No.  000664

Title:       Road Still Pushed for  Waste  Site.
Authors:     NANCY BAZILCHUK - BURLINGTON FREE  PRESS
Date:        March 3,  1994
Format:      NEWS CLIPPING                No.  Pgs:  1
AR No.       13.03.79                      Document  No.  000466

Title:       EPA Launches  New Superfund Approach  at  Cleanup  Site.
Authors:     MATTHEW WITTEN  - NEW HAMPSHIRE  MONITOR
Date:        March 30,  1994
Format:      NEWS CLIPPING                No.  Pgs:  4
AR No.       13.03.80                      Document  No.  000463

Title:       Undisturbed Barge Site Believed Safe.
Authors:     NANCY BAZILCHUK - BURLINGTON FREE  PRESS
Date:        March 31,  1994
Format:      NEWS CLIPPING                No.  Pgs:  1
AR No.       13.03.81                      Document  No.  000468
Title:       Barge  Canal  Group  to Meet.
Authors:      BURLINGTON FREE  PRESS
Date:        April  17, 1994
Format:      NEWS CLIPPING
AR No.       13.03.82
 No. Pgs: 1
 Document No. 000469
Title:       GMP  Rates will  Rise  2.  9%.
Authors:     NANCY  BAZILCHUK -  BURLINGTON  FREE  PRESS
Date:        May  17,  1994
Format:      NEWS CLIPPING                 No. Pgs:  1
AR No.       13.03.83                      Document  No.  000470

Title:       EPA  to Probe Waste Site Again.
Authors:     NANCY  BAZILCHUK -  BURLINGTON  FREE  PRESS
Date:        May  :20, 1994
Format:      NEWS CLIPPING                 No. Pgs:  1
AR No.       13.03.84                      Document  No.  000471

Title:       Bugs Might  Help take a  Bite Out  of Waste.
Authors:     NANCY  BAZILCHUK -  BURLINGTON  FREE  PRESS
Date:        June 29, 1994
Format:      NEWS CLIPPING                 No. Pgs:  1
AR No.       13.03.85                      Document  No.  000472

Title:       Testing to  Resume  in August.
Authors:     NANCY  BAZILCHUK -  BURLINGTON  FREE  PRESS
Date:        July 16, 1994
Format:      NEWS CLIPPING                 No. Pgs:  1
AR No.       13.03.86                      Document  No.  000473

Title:       New  Round of Studies to Begin at Pine  Street  Barge  Canal.
Date:        July 22, 1994
Format:      FACT SHEET, PRESS  RELEASE     No. Pgs:  2
AR No.       13.03.87                      Document  No.  000475
Title:       The  Canal  Quandary.
Authors:      BURLINGTON FREE  PRESS
Date:        July 23, 1994
Format:      NEWS CLIPPING
AR No.       13.03.88
No. Pgs: 1
Document No. 000476
Title:       New  Round  of  Studies  to  Begin  at  Pine  Street  Barge  Canal.
Date:        August  15,  1994
Format:      FACT SHEET, PRESS  RELEASE    No.  Pgs:  1
AR No.       13.03.89                     Document  No.  000477

-------
Title:        Superfund  Studies  Begin  Next Week.
Authors:      NANCY  BAZILCHUK -  BURLINGTON FREE  PRESS
Date:         August 18,  1994
Format:       NEWS CLIPPING                No. Pgs:  1
AR No.        13.03.90                     Document  No.  000478

Title:        Studies on Barge Canal Start Late.
Authors:      NANCY  BAZILCHUK -  BURLINGTON FREE  PRESS
Date:         September  10,  1994
Format:       NEWS CLIPPING                No. Pgs:  1
AR No.        13.03.91                     Document  No.  000479

Title:        Residents  Speak  Out  on Barge Canal.
Authors:      SONA IYENGAR - BURLINGTON  FREE  PRESS
Date:         November 16, 1994
Format:       NEWS CLIPPING                No. Pgs:  1
AR No.        13.03.92                     Document  No.  000480
Title:
Authors:
Date:
Format:
AR No.
Pine Street Detour.
RAY UNSWORTH
1995
NEWS CLIPPING
13.03.93
No. Pgs: 1
Document No. 000481
Title:        Southern  Connector  Gets  in Gear.
Authors:       JEFFREY MACDONALD - BURLINGTON FREE  PRESS
Date:         February  3,  1995
Format:       NEWS  CLIPPING                 No.  Pgs:  1
AR No.        13.03.94                      Document  No.  000482
Title:        Still  a  Slow  Road.
Authors:       BURLINGTON  FREE  PRESS
Date:         February 8, 1995
Format:       NEWS CLIPPING
AR No.        13.03.95
                             No. Pgs: 2
                             Document No. 000483
Title:        EPA  - New  England Announces  Major  Superfund Reform Initiative.
Authors:      ENVIRONMENTAL  PROTECTION AGENCY
Date:         February 21, 1995
Format:       FACT SHEET,  PRESS RELEASE     No. Pgs:  1
AR No.        13.03.96                      Document  No.  000484

Title:        Barge Cleanup  Plan  Nears Final  Stage.
Authors:      NANCY BAZILCHUK - BURLINGTON FREE  PRESS
Date:         February 26, 1995
Format:       NEWS CLIPPING                 No. Pgs:  2
AR No.        13.03.97                      Document  No.  000485

Title:        Connector  to Veer from Barge Canal.
Authors:      NANCY BAZILCHUK - BURLINGTON FREE  PRESS
Date:         June 8, 1995
Format:       NEWS CLIPPING                 No. Pgs:  1
AR No.        13.03.98                      Document  No.  000487

Title:        Environmental  Investigations have  Resumed  at the  Pine  Street Canal Superfund Site.
Date:         July 6, 1995
Format:       FACTSHEET,  PRESS RELEASE      No.  Pgs:  1
AR No.        13.03.99                      Document No.  000488

Title:        City's  Junk Winds its  Way  into  the Lake.
Authors:      NANCY BAZILCHUK - BURLINGTON FREE  PRESS
Date:         July 13, 1995
Format:       NEWS CLIPPING                 No.  Pgs:  2
AR No.        13.03.100                     Document No.  000489

Title:        Experts Test Air Over  Barge  Canal.
Authors:      NANCY BAZILCHUK - BURLINGTON FREE  PRESS
Date:         July, 14,  1995
Format:       NEWS CLIPPING                   No.  Pgs: 2
AR No.        13.03.101                       Document No.  000490

Title:        Lake Cleanup:  Currents Shift.
Authors:      NANCY BAZILCHUK - BURLINGTON FREE  PRESS
Date:         July 25, 1995
Format:       NEWS CLIPPING                   No.  Pgs: 2
AR No.        13.03.102                       Document No.  000492
Title:
              Lake  Cleanup  Chronology.

-------
Authors:       BURLINGTON  FREE  PRESS
Date:         July  25,  1995
Format:       NEWS  CLIPPING
AR No.        13.03.103
                               No. Pgs: 2
                               Document No. 000493
Title:        Road, Waste  Site  Might  Intersect.
Authors:      NANCY BAZILCHUK - BURLINGTON FREE  PRESS
Date:         December  6,  1995
Format:       NEWS CLIPPING                   No.  Pgs:  1
AR No.        13.03.104                       Document  No.  000494

Title:        Southern  Connector Design  Concerns  Residents.
Authors:      SONA IYENGAR -  BURLINGTON  FREE  PRESS
Date:         December  8,  1995
Format:       NEWS CLIPPING                   No.  Pgs:  1
AR No.        13.03.105                       Document  No.  000495

Title:        Residents  Share Concerns About  4 -  Lane  Strip.
Authors:      SONA IYENGAR -  BURLINGTON  FREE  PRESS
Date:         January 5, 1996
Format:       NEWS CLIPPING                   No.  Pgs:  1
AR No.        13.03.106                       Document  No.  000502

Title:        Connector  Paves Way into the Future.
Authors:      CLARENCE MEUNIER  - BURLINGTON FREE  PRESS
Date:         January 16,  1996
Format:       NEWS CLIPPING                   No.  Pgs:  1
AR No.        13.03.107                       Document  No.  000503
Title:        "Earth  to  Planners"
Authors:       BURLINGTON FREE  PRESS
Date:         January 16,  1996
Format:       NEWS  CLIPPING
AR No.        13.03.108
                                No. Pgs: 1
                                Document No. 000504
Title:        Readers  Forum - Money  Blinds  and Road to Nowhere -  Seperate Editorials.
Authors:      FRED  HILL,  NANCY  DES RAULT  -  BURLINGTON FREE  PRESS
Date:         February 4,  1996
Format:       NEWS  CLIPPING                   No.  Pgs:  1
AR No.        13.03.109                       Document No.  000506
Title:        Drive  On  for  the  Connector.
Authors:      WILLIAM KEOUGH  -  BURLINGTON  FREE  PRESS
Date:         February  7, 1996
Format:       NEWS CLIPPING                  No.  Pgs:  1
AR No.        13.03.110                       Document  No.
                                                           000505
Title:        Readers  Forum -  Forget  Connector.
Authors:       TODD  LOCKWOOD -  BURLINGTON FREE  PRESS
Date:         February 24,  1996
Format:       NEWS  CLIPPING                   No.  Pgs:  1
AR No.        13.03.111                        Document  No.
                                                           000507
Title:        Readers  Forum -  Gutting Waste.
Authors:      TIM  LAVIGNE  - BURLINGTON  FREE  PRESS
Date:         February 24,  1996
Format:       NEWS CLIPPING                   No.  Pgs:  1
AR No.        13.03.112                        Document  No.
                                                           000508
Title:        Barge  Cleanup  Plan  Nears  Final  Stage.
Authors:      NANCY  BAZILCHUK - BURLINGTON FREE  PRESS
Date:         February  26, 1996
Format:       NEWS CLIPPING                    No.  Pgs:  2
AR No.        13.03.113                        Document  No.
                                                           000509
Title:        Residents  Discuss  Southern Connector Plan.
Authors:       MEGHAN MC  MENIMEN  -  BURLINGTON FREE  PRESS
Date:         February 27,  1996
Format:       NEWS  CLIPPING                   No.  Pgs:  1
AR No.        13.03.114                        Document  No.
                                                           000510
Title:        Connector  is  Critical.
Authors:      LISA VENTRISS -  BURLINGTON FREE  PRESS
Date:         February 28,  1996
Format:       NEWS CLIPPING                   No.  Pgs:  1
AR No.        13.03.115                        Document  No.
                                                           000511
Title:
3 Road Projects Face Delay.

-------
Authors:      MATT  SUTKOSKI  -  BURLINGTON  FREE  PRESS
Date:        March 13,  1996
Format:      NEWS  CLIPPING                    No.  Pgs:  1
AR No.       13.03.116                        Document  No.  000512

Title:       Burlington Plans Decision on  Coal  Tar  by  Fall.
Authors:      SONA  IYENGAR - BURLINGTON FREE PRESS
Date:        March 9, 1997
Format:      NEWS  CLIPPING                    No.  Pgs:  2
AR No.       13.03.117                        Document  No.  000513

Title:       Southern Connector  Design OK'd.
Authors:      SONA  IYENGAR - BURLINGTON FREE PRESS
Date:        April 1997
Format:      NEWS  CLIPPING                    No.  Pgs:  2
AR No.       13.03.118                        Document  No.  000514

Title:       EPA Congratulates Vermont Transit  on New  Terminal  -  Applauds  Reuse of Superfund Site.
Authors:      ENVIRONMENTAL  PROTECTION AGENCY
Date:        August 13,  1997
Format:      FACT  SHEET, PRESS RELEASE        No.  Pgs:      1
AR No.       13.03.119                        Document  No.  000143
Title:       Barge  Canal:  Fill  It.
Authors:     NANCY  BAZILCHUK -  BURLINGTON
Date:        September  23,  1997
Format:      NEWS CLIPPING
AR No.       13.03.120
 FREE PRESS

No. Pgs: 2
Document No. 000515
Title:       Coordinating  Council Mulls  Supplemental
              Environmental Projects, Prepares for Public Comment Period.
Authors:     ENVIRONMENTAL PROTECTION AGENCY
Date:        September  24,  1997
Format:      FACT  SHEET, PRESS RELEASE        No.  Pgs:  3
AR No.       13.03.121                        Document  No.  000142

Title:       Cleanup  Backed by EPA.
Authors:     NANCY BAZILCHUK  - BURLINGTON  FREE PRESS
Date:        September  24,  1997
Format:      NEWS  CLIPPING                   No.  Pgs:  2
AR No.       13.03.122                        Document  No.  000518

Title:       Barge Canal Cleanup Totals  $30 Million.
Authors:     NANCY BAZILCHUK  - BURLINGTON  FREE PRESS
Date:        December 20,  1997
Format:      NEWS  CLIPPING                   No.  Pgs:  2
AR No.       13.0-3.123                      Document  No.  000519

Title:       Progress Update  #3: Council Reaches  Concensus  on
              Cleanup at the Barge Canal Environmental Projects Proposed.
Authors:     PINE  STREET COORDINATING COUNCIL
Date:        May 1998
Format:      FACT  SHEET, PRESS RELEASE        No.  Pgs:  6
AR No.       13.03.124                        Document  No.  000619

Title:       Agreement  Reached on Burlington, VT  Superfund  Site.
Authors:     ASSOCIATED PRESS
Date:        May :28, 1998
Format:      NEWS  CLIPPING                   No.  Pgs:  1
AR No.       13.03.125                        Document  No.  000616
Title:       Canal  Cleanup  Finalized.
Authors:      BURLINGTON  FREE  PRESS
Date:        May  :28,  1998
Format:      NEWS CLIPPING
AR No.       13.  03.126
No. Pgs: 1
Document No. 000617
Title:       Canal:  EPA Announces  $7.3 Million  Cleanup.
Addressee:   BURLINGTON FREE  PRESS
Date:        May  28,  1998
Format:      NEWS CLIPPING                    No.  Pgs:  1
AR No.       13.03.127                        Document  No.  000618
Title:       Barge  Canal  Plan  Hailed.
Authors:     FREDERICK  BEVER - RUTLAND  HERALD
Date:        May  28,  1998
Format:      NEWS CLIPPING                   No.  Pgs:  1
AR No.       13.03.128                       Document  No.  000662

-------
Title:       Officials Reach Agreement  on  Canal Hazardous Waste  Cleanup.
Authors:      DAVID GRAM  -  BRATTLEBORO REFORMER
Date:        May  28,  1998
Format:      NEWS CLIPPING                  No.  Pgs:  1
AR No.       13.03.129                       Document  No. 000663

Title:       United  States Environmental Protection Agency
              Proposes Cleanup Plan at the Pine Street Canal Superfund, Site.
Authors:      BURLINGTON  FREE PRESS
Date:        May  29,  1998
Format:      NEWS CLIPPING                  No.  Pgs:  1
AR No.       13.03.130                       Document  No. 000652
Title:       A Good  Solution.
Authors:      RUTLAND HERALD
Date:         May  31,  1998
Format:      NEWS  CLIPPING
AR No.       13.03-131
                                No. Pgs: 1
                                Document No. 000661
Title:        Strengthen  Superfund.
Authors:       BURLINGTON  FREE  PRESS
Date:         June  25,  1998
Format:       NEWS  CLIPPING
AR No.        13.03.132
                                No. Pgs: 1
                                Document No. 000660
Title:       Canal Cleanup  Plan  Backed  at Hearing.
Authors:     NANCY BAZILCHUK  - BURLINGTON FREE  PRESS
Date:        June 28,  1998
Format:      NEWS CLIPPING                    No.  Pgs:  1
AR No.       13.03.133                        Document  No.  000659

Title:       Extention  of Time to  Comment on  the  Proposed
              Cleanup Plan for the Pine Street Superfund Site.
Authors:     BURLINGTON FREE  PRESS
Date:        July 20,  1998
Format:      NEWS CLIPPING                    No.  Pgs:  1
AR No.       13.03.134                        Document  No.  000653
13.04
COMMUNITY RELATIONS - PUBLIC MEETINGS/HEARINGS
Title:       Barge Canal Goals  Statement — Revised.
Authors:     BURLINGTON INTRA CITY WORK GROUP
Format:      PUBLIC MEETING  RECORDS           No.  Pgs:  3
AR No.       13.04.1                          Document  No.  000190

Title:       Summary  of September 27-28 Meeting; Meeting  of October  13-14,  1993.
Addressee:   PINE STREET COORDINATING  COUNCIL
Authors:     PHILIP HARTER
Date:        October  4, 1993
Format:      MEMORANDUM                       No.  Pgs:  7
AR No.       13.04.2                          Document  No.  000239
Title:       Meeting  Summary  of  October  13-14,
Addressee:   PINE  STREET COORDINATING  COUNCIL
Authors:     PHILIP HARTER
Date:        October  19, 1993
Format:       MEMORANDUM
AR No.       13.04.3
                                  1993.
                                  No. Pgs: 6
                                  Document No. 000231
Title:        Summary  of Meeting—October  26,  27,  1993; Agenda  for Next Meetings.
Addressee:    PINE  STREET COORDINATING  COUNCIL
Authors:      PHILIP HARTER
Date:         October  31, 1993
Format:       MEMORANDUM                        No.  Pgs:  4
AR No.        13.04.4                           Document  No.  000232

Title:        Summary  of Meeting—November 9;  Agenda for  Next Meeting.
Addressee:    PINE  STREET COORDINATING  COUNCIL
Authors:      PHILIP HARTER
Date:         November 15, 1993
Format:       MEMORANDUM                        No.  Pgs:  7
AR No.        13.04.5                           Document  No.  000233
Title:        Summary  of Meeting  December  1  and  2; Meeting  of  December  16;
              Cancellation of December 15 Meeting.
Addressee:    PINE  STREET COORDINATING COUNCIL
Authors:      PHILIP HARTER

-------
Date:        December  6,  1993
Format:       MEMORANDUM
AR No.       13.04.6
No. Pgs: 9
Document No. 000234
Title:        Issue  Spotting; Meetings  of  January  26-27;  Cancellation  of  January  27  Coordinating
              Council Meeting; Summary of January 6 Meeting.
Addressee:    PINE STREET COORDINATING  COUNCIL
Authors:      PHILIP HARTER
Date:         January 13, 1994
Format:       MEMORANDUM                        No.  Pgs;  26
AR No.        13.04.7                          Document  No.  000235

Title:        Council Meetings  of March 2-3;  Technical  Expert Meetings of March 1-4.
Addressee:    PINE STREET COORDINATING  COUNCIL
Authors:      PHILIP HARTER
Date:         February 22, 1994
Format:       MEMORANDUM                        No.  Pgs:  38
AR No.        13.04.8                          Document  No.  000236

Title:        Council Meeting of March  30, 31; Workgroup  Meetings March 29-31, April  14-15;
              Summaries of Previous Council and Workgroup Meetings.
Addressee:    PINE STREET COORDINATING  COUNCIL
Authors:      PHILIP HARTER, DANIEL  FINKELSTEIN
Date:         March  16, 1994
Format:       MEMORANDUM                        No.  Pgs:  25
AR No.        13.04.9                          Document  No.  000237
Title:       Organizational  Protocols.
Authors:     PINE  STREET COORDINATING  COUNCIL
Date:        March 22,  1994
Format:      NOTES-MEETING
AR No.       13.04.10
No. Pgs: 4
Document No. 000382
Title:       Council Meeting  of April  19  and  21; Workgroup Meetings April  14-15  and  19-21;
              Summaries of Previous Council and Workgroup Meetings.
Addressee:   PINE  STREET COORDINATING  COUNCIL
Authors:     PHILIP HARTER, DANIEL  FINKELSTEIN
Date:        April 8,  1994
Format:      MEMORANDUM                        No.  Pgs:  20
AR No.       13.04.11                          Document  No.  000238

Title:       Human Health Work Group—Meeting Summary, April  20-21, 1994.
Authors:     PINE: STREET COORDINATING COUNCIL
Date:        April 21, 1994
Format:      PUBLIC MEETING RECORDS            No.  Pgs:  3
AR No.       13.04.12                          Document  No.  000161

Title:       Schedule  Changes and Meeting Summaries.
Addressee:   PINE  STREET COORDINATING  COUNCIL
Authors:     PHILIP HARTER, DANIEL  FINKELSTEIN
Date:        May 1, 1994
Format:      MEMORANDUM                         No.  Pgs:13
AR No.       13.04.13                           Document No.  000181
Title:       Abbreviated Meeting  Summary.
Addressee:   PINE  STREET COORDINATING  COUNCIL
Authors:     PHILIP HARTER,  DANIEL  FINKELSTEIN
Date:        May 23,  1994
Format:       MEMORANDUM
AR No.       13-04 .14
 No. Pgs: 2
 Document No. 000211
Title:        Summer  Schedule  and Meeting  Summary  for  June  8,  1994.
Addressee:    PINE  STREET COORDINATING  COUNCIL
Authors:      PHILIP  HARTER, DANIEL  FINKELSTEIN
Date:         June  21,  1994
Format:       PUBLIC  MEETING RECORDS             No. Pgs: 4
AR No.        13.04.15                           Document No.  000169
Title:       Meeting  Summary—June  28-29,  1994.
Addressee:   PINE  STREET COORDINATING  COUNCIL
Authors:     PHILIP HARTER, DANIEL  FINKELSTEIN
Date:        July  7,  1994
Format:       MEMORANDUM
AR No.       13. 04 .16
 No. Pgs: 12
 Document No. 000188
Title:       Cancellation  of  September  19 Meeting;  Future Meetings, Meeting  Summaries  for
              September 7,  8 9, 1994.
Addressee:   PINE  STREET COORDINATING COUNCIL

-------
Authors:      PHILIP HARTER
Date:         September  14,  1994
Format:        MEMORANDUM
AR No.        13.04.17
                                   No. Pgs: 9
                                   Document No. 000189
Title:        Summary  of Meeting  October  6,  1994.
Addressee:    PINE  STREET COORDINATING  COUNCIL
Authors:      DANIEL FINKELSTEIN
Date:         October  20, 1994
Format:       MEMORANDUM                         No.  Pgs:  4
AR No.        13.04.18                           Document  No.  000187
Title:       Cancellation  of Council Meeting  December
Addressee:   PINE  STREET COORDINATING  COUNCIL
Authors:     PHILIP HARTER, DANIEL  FINKELSTEIN
Date:        November  22,  1994
Format:      PUBLIC MEETING RECORDS             No.  Pgs:  7
AR No.       13.04.19                           Document  No.
                                            Summaries of November 3 Meetings.
                                                              000168
Title:        Summary  of  January.S Meeting;  Future Meetings.
Addressee:    PINE  STREET COORDINATING  COUNCIL
Authors:      PHILIP HARTER
Date:         January  17, 1995
Format:        MEMORANDUM
AR No.        13.04.20
                                   No. Pgs: 6
                                   Document No. 000243
Title:       Meeting  Summary  and  Schedule.
Addressee:   PINE  STREET COORDINATING  COUNCIL
Authors:     PHILIP HARTER
Date:        February 22, 1995
Format:       MEMORANDUM
AR No.       13.04.21
                                   No. Pgs: 11
                                   Document No. 000244
Title:        Summary  of  ECO Workgroup Meeting March  3,  1995.
Addressee:    PINE  STREET COORDINATING COUNCIL
Authors:      PHILIP HARTER
Date:         March 3,  1995
Format:       MEMORANDUM                         No.  Pgs:  7
AR No.        13.04.22                           Document  No.  000245

Title:        Schedule  and Summary  of Meetings—March 9  and  17.
Addressee:    PINE  STREET COORDINATING COUNCIL
Authors:      PHILIP HARTER, ALAN STRASSER
Date:         March 23, 1995
Format:       MEMORANDUM                         No.  Pgs:  9
AR No.        13.04.23                           Document  No.  000246

Title:        Summary  of  June  8, 1995, Remedial Alternatives Workgroup,  and  Coordinating  Council
              Meetings and the Ecological Workgroup Meeting of June 14, 1995.
Addressee:    PINE  STREET COORDINATING COUNCIL
Authors:      PHILIP HARTER, ALAN STRASSER
Date:         June  22,  1995
Format:       MEMORANDUM                         No.  Pgs:  8
AR No.        13.04.24                           Document  No.  000215
Title:       Meetings  of  July  27  and  28,  1995.
Addressee:   PINE  STREET  COORDINATING COUNCIL
Authors:     PHILIP HARTER, ALAN  STRASSER
Date:        July  19,  1995
Format:       MEMORANDUM
AR No.       13.04.25
                                    No. Pgs: 5
                                    Document No. 000248
Title:       Meetings  of  July  27  and  28,  1995:  Summary  and Next Meetings.
Addressee:   PINE  STREET  COORDINATING COUNCIL
Authors:     PHILIP HARTER, ALAN  STRASSER
Date:        August 3,  1995
Format:      MEMORANDUM                         No.  Pgs: 10
AR No.       13.04.26                            Document No.  000249

Title:       Ecological Conference Call  on  Preliminary  Remedial Goal  #1  Clarifications.
Addressee:   SHEILA ECKMAN - EPA  REGION  I
Authors:     PHILIP HARTER, ALAN  STRASSER
Date:        August 10, 1995
Format:      MEMORANDUM                         No.  Pgs: 8
AR No.       13.04.27                            Document No.  000204
Title:
Addressee:
September 19 Meeting.
PINE STREET COORDINATING COUNCIL

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Authors:
Date:
Format:
AR No.
MEG HIMMEL
August 29, 1995
MEMORANDUM
13.04.28
No. Pgs: 5
Document No. 000220
Title:        Summary  of October  17,  1995 Meetings.
Authors:      PINE  STREET COORDINATING COUNCIL
Date:         October  17, 1995
Format:       MEMORANDUM                          No.  Pgs:  6
AR No.        13.04.29                           Document  No.  000174

Title:        Meeting  Summary of  October 17,  1995;  Scheduling Next Meeting.
Addressee:    PINE  STREET COORDINATING COUNCIL
Authors:      PHILIP HARTER, ALAN STRASSER
Date:         November 3, 1995
Format:       MEMORANDUM                          No.  Pgs:  7
AR No.        13.04.30                           Document  No.  000250

Title:        Summary  of the Conference Call  Regarding Comments  to the  Post-Screening  Field
              Investigation Work Plan and Initial Screening Report.
Addressee:    PINE  STREET COORDINATING COUNCIL
Authors:      PHILIP HARTER, ALAN STRASSER
Date:         November 13,  1995
Format:       MEMORANDUM                   No.  Pgs:  3
AR No.        13.04.31                    Document  No.  000175

Title:        Ecological Workgroup Meeting Proposed  for  December 5,  1995  to Discuss Ecological  Risk
              Assessment Work Plan; Correction to Meeting Summary of 10/17/95.
Addressee:    PINE  STREET COORDINATING COUNCIL
Authors:      PHILIP HARTER, ALAN STRASSER
Date:         November 14,  1995
Format:       MEMORANDUM                   No.  Pgs:  1
AR No.        13.04.32                    Document  No.  000251

Title:        Summary  of December 4,  1995 Council Meeting.
Authors:      PINE  STREET COORDINATING COUNCIL
Date:         December 4, 1995
Format:       PUBLIC MEETING RECORDS       No.  Pgs:  3
AR No.        13.04.33                    Document  No.  000162

Title:        Meeting  Summary of  December 4,  1995;  January  Council Meeting.
Addressee:    PINE  STREET COORDINATING COUNCIL
Authors:      PHILIP HARTER, ALAN STRASSER
Date:         December 8, 1995
Format:       MEMORANDUM                   No.  Pgs:  3
AR No.        13.04.34                    Document  No.  000252

Title:        Meeting  Summaries—January 22-23, 1996.
Authors:      PINE  STREET COORDINATING COUNCIL
Date:         January  23, 1996
Format:       PUBLIC MEETING RECORDS       No.  Pgs:  14
AR No.        13.04.35                    Document  No.  000163

Title:        Meeting  Summaries of January 22-23, 1996;  Scheduling of Meetings.
Addressee:    PINE  STREET COORDINATING COUNCIL
Authors:      PHILIP HARTER, ALAN STRASSER
Date:         February 7, 1996
Format:       MEMORANDUM                   No.  Pgs:  15
AR No.        13.04.36                    Document  No.  000253

Title:        Ecological Workgroup Summary of March  19,  1996.
Addressee:    SHEILA ECKMAN - EPA REGION I
Authors:      PHILIP HARTER, ALAN STRASSER
Date:         March 19, 1996
Format:       MEMORANDUM                   No.  Pgs:  7
AR No.        13.04.37                    Document  No.  000203

Title:        Technical Work Group Meeting Summary  of  March 28,  1996.
Addressee:    PINE  STREET COORDINATING COUNCIL
Authors:      PHILIP HARTER, ALAN STRASSER
Date:         March 28, 1996
Format:       MEMORANDUM                   No.  Pgs:  10
AR No.        13.04.38                    Document  No.  000176
Title:        Summary  of April  9,  1996 Council Meeting.
Addressee:    PINE  STREET COORDINATING COUNCIL
Authors:      PHILIP HARTER, ALAN  STRASSER
Date:         May 3, 1996

-------
Format:
AR No.
MEMORANDUM
13.04.39
No. Pgs: 7
Document No. 000177
Title:       Meeting  Summary  of May  22,  1996.
Addressee:   PINE  STREET COORDINATING COUNCIL
Authors:     PHILIP HARTER, ALAN  STRASSER
Date:        May 22,  1996
Format:      MEMORANDUM                   No.  Pgs:  3
AR No.       13.04.40                     Document  No.  000178

Title:        Meeting  Summary of  September  16,  1996.
Authors:     PINE  STREET COORDINATING COUNCIL
Date:        September 16,  1996
Format:      NOTES-MEETING                No.  Pgs:  6
AR No.       13.04.41                     Document  No.  000383

Title:       Summary  of September 16, 1996  Eco Workgroup Meeting  and  Schedule  of Upcoming  Events.
Addressee:   ECOLOGICAL WORK  GROUP
Authors:     PHILIP HARTER, ALAN  STRASSER
Date:        September 23,  1996
Format:      MEMORANDUM                   No.  Pgs:  8
AR No.       13.04.42                     Document  No.  000179

Title:       Summary  of November  6,  1996 Council  and Workgroup
              Meetings; Eco Workgroup,  Meeting  of December 11, 1996.
Addressee:   PINE  STREET COORDINATING COUNCIL
Authors:     PHILIP HARTER, ALAN  STRASSER
Date:        November  21, 1996
Format:      MEMORANDUM                   No.  Pgs:  13
AR No.       13.04.43                     Document  No.  000186

Title:       Ecological Work  Group Summary  of  December  10, 1996 Meeting.
Addressee:   PINE  STREET COORDINATING COUNCIL
Authors:     PHILIP HARTER, ALAN  STRASSER
Date:        December  31, 1996
Format:      MEMORANDUM                   No.  Pgs:  7
AR No.       13.04.44                     Document  No.  000185

Title:       Summary  of February  25th Meeting,  Agenda for March 18  Meeting.
Addressee:   PINE  STREET COORDINATING COUNCIL
Authors:     PHILIP HARTER, ALAN  STRASSER
Date:        March 11, 1997
Format:      MEMORANDUM                   No.  Pgs:  15
AR No.       13.04.45                     Document  No.  000164

Title:       Meeting  Summary  of March 18, 1997.
Authors:     PINE  STREET COORDINATING COUNCIL
Date:        April 1997
Format:      NOTES-MEETING                No.  Pgs:  8
AR No.       13.04.46                     Document  No.  000384

Title:       Agenda for Council and  Work Group Meeting  of April 15,
              and Meeting Summary of March  18,   1997.
Addressee:   PINE  STREET COORDINATING COUNCIL
Authors:     PHILIP HARTER, ALAN  STRASSER
Date:        April 3,  1997
Format:      MEMORANDUM                   No.  Pgs:  12
AR No.       13.04.47                     Document  No.  000165
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Tentative Agenda for Meeting on May 19
PINE STREET COORDINATING COUNCIL
PHILIP HARTER, ALAN STRASSER
May 6, 1997
PUBLIC MEETING RECORDS       No. Pgs: 13
           and Meeting Summary of April 15, 1997.
              13.04.48
                                           Document No.  000166
Title:       Meeting  Summary  of April  15,  1997.
Authors:     PINE  STREET COORDINATING  COUNCIL
Date:        May 6, 1997
Format:      NOTES-MEETING                 No.  Pgs:  8
AR No.       13.04.49                     Document  No.  000385
Title:       Meeting  Summary  of May  19; Agenda  for  June  16 Meeting.
Addressee:   SHEILA ECKMAN  -  ENVIRONMENTAL  PROTECTION AGENCY
Authors:     PHILIP HARTER, ALAN  STRASSER
Date:        June  13,  1997
Format:      MEMORANDUM                   No. Pgs:  5
AR No.       13.04.50                     Document  No. 000167

-------
Title:        Summary  of  Technical Work  Group  Meeting of  July 15,  1997.
Authors:      PINE  STREET COORDINATING COUNCIL
Date:         July  15,  1997
Format:       PUBLIC MEETING  RECORDS        No.  Pgs:  6
AR No.        13.04.51                      Document  No. 000182

Title:        Summary  of  Meeting  - July  15,  1997  - Technical  Workshop Meeting.
Addressee:    PINE  STREET COORDINATING COUNCIL
Authors:      PHILIP HARTER,  ALAN STRASSER
Date:         July  15,  1997
Format:       MEMORANDUM                    No.  Pgs:  6
AR No.        13.04.52                      Document  No. 000255

Title:        List  of Meeting Summaries  for EPA Docket.
Addressee:    SHEILA ECKMAN - EPA REGION I
Authors:      PHILIP HARTER,  ALAN STRASSER  - MEDIATION CONSORTIUM
Date:         January  7,  1998
Format:       LETTER                        No.  Pgs:  4
AR No.        13.04.53                      Document  No. 000240
13.05
COMMUNITY RELATIONS - FACT SHEETS/INFORMATION UPDATES
Title:       The  Barge  Canal: At  a  Crossroads.
Authors:      LAKE CHAMPLAIN  COMMITTEE
Format:      FACT SHEET,  PRESS  RELEASE     No.  Pgs:  4
AR No.       13.05.1                       Document  No.
                                                        000520
Title:        Fresh  Start  at  Pine  Street  Canal.
Date:         1993
Format:       FACT SHEET,  PRESS  RELEASE      No.  Pgs:  1
AR No.        13.05.2                        Document  No.  000522

Title:        Ecological Risk at the  Pine Street Superfund Site.
Authors:      ENVIRONMENTAL PROTECTION AGENCY
Date:         April  1993
Format:       FACT SHEET,  PRESS  RELEASE      No.  Pgs:  8
AR No.        13.05.3                        Document  No.  000146

Title:        Council Moving  Ahead on Further  Studies for Pine Street  -  Progress  Update #1.
Authors:      ENVIRONMENTAL PROTECTION AGENCY
Date:         March  1994
Format:       FACT SHEET,  PRESS  RELEASE      No.  Pgs:  4
AR No.        13.05.4                        Document  No.  000149

Title:        New Studies  Underway at Pine Street Barge  Canal Site  - Progress  Update #2.
Authors:      PINE STREET  COORDINATING COUNCIL
Date:         October 1994
Format:       FACT SHEET,  PRESS  RELEASE      No.  Pgs:  6
AR No.        13.05.5                        Document  No.  000150

Title:        Superfund Update - EPA  Region I  Promises Reforms will Prompt Faster Cleanups.
Authors:      ENVIRONMENTAL PROTECTION AGENCY
Date:         March  6, 1995
Format:       FACT SHEET,  PRESS  RELEASE      No.  Pgs:  1
AR No.        13.05.6                        Document  No.  000486

Title:        Council Proposes Cleanup Plan, Additional  Projects  for Pine  Street  Barge Canal Site.
Authors:      LEO KAY, LORI FISHER, PHILIP HARTER - EPA  REGION I
Date:         May 28, 1998
Format:       FACT SHEET,  PRESS  RELEASE      No.  Pgs:  3
AR No.        13.05.7                        Document  No.  000620
13.07
             COMMUNITY  RELATIONS  -  TECHNICAL ASSISTANCE  GRANTS
Title:       Lake  Champlain  Committee  Public  Survey on the  Barge  Canal  Clean -  Up.
Format:      LIST                           No.  Pgs:  2
AR No.       13.07.1                        Document No.  000395

Title:       Lake  Champlain  Committee  Proposal  for  Public and Scientific Review Committees.
Date:        May 1993
Format:      NOTES-GENERAL                  No.  Pgs:  2
AR No.       13.07.2                        Document No.  000455
Title:        Protocol  for  Taking Water  Samples  at  the  PSCB.
Addressee:    LORI  FISHER - LAKE CHAMPLAIN  COMMITTEE
Authors:      AL MCINTOSH - UNIVERSITY OF VERMONT

-------
Date:
Format:
AR No.
May 10, 1993
MEMORANDUM
13.07.3
No. Pgs: 1
Document No. 000386
Title:       TAG  Quarterly  Progress  Report.
Addressee:   LORI  FISHER  -  LAKE  CHAMPLAIN  COMMITTEE
Date:        May  15,  1993
Format:      REPORT,  STUDY                 No.  Pgs:  3
AR No.       13.07.4                       Document  No.  000198

Title:       Surface  Water  Sampling.
Addressee:   LORI  FISHER  -  LAKE  CHAMPLAIN  COMMITTEE
Authors:     ROSS  GILLELAND -  ENVIRONMENTAL  PROTECTION AGENCY
Date:        June  16,  1993
Format:      LETTER                        No.  Pgs:  3
AR No.       13.07.5                       Document  No.  000387

Title:       TAG  Quarterly  Progress  Report.
Addressee:   LORI  FISHER  -  LAKE  CHAMPLAIN  COMMITTEE
Date:        August 31, 1993
Format:      REPORT,  STUDY                 No.  Pgs:  2
AR No.       13.07.6                       Document  No.  000197

Title:       Community Involvement Focus Groups.
Authors:     DIANE HAMMER - ENVIRONMENTAL  PROTECTION AGENCY
Date:        June  2,  1994
Format:      MEMORANDUM                   No.  Pgs:  2
AR No.       13.07.7                       Document  No.  000388

Title:       Local Advisory Panel for  Scientific  Evaluation
              Component of  the Pine Street Coordinating Council to Receive Environmental Merit Award.
Addressee:   MARTY FELDMAN  - LIGHTWORKS  INC.
Authors:     JOHN  DE  VILLARS - ENVIRONMENTAL PROTECTION AGENCY
Date:        April 7,  1997
Format:      LETTER                        No.  Pgs:  1
AR No.       13.07.8                       Document  No.  000389

Title:       Local Advisory Panel for  Scientific  Evaluation
              Component of  the Pine Street Coordinating Council to Receive Environmental Merit Award.
Addressee:   MARY  WATZIN  -  UNIVERSITY  OF VERMONT
Authors:     JOHN  DE  VILLARS - ENVIRONMENTAL PROTECTION AGENCY
Date:        April 7,  1997
Format:      LETTER                        No.  Pgs:  1
AR No.       13.07.9                       Document  No.  000390

Title:       Local Advisory Panel for  Scientific  Evaluation
              Component of  the Pine Street Coordinating Council to Receive Environmental Merit Award.
Addressee:   AL MCINTOSH  -  UNIVERSITY  OF VERMONT
Authors:     JOHN  DE  VILLARS ENVIRONMENTAL PROTECTION AGENCY
Date:        April 7,  1997
Format:      LETTER                        No.  Pgs:  1
AR No.       13.07.10                     Document  No.  000391

Title:       Local Advisory Panel for  Scientific  Evaluation
              Component of  the Pine Street Coordinating Council to Recieve Environmental Merit Award.
Addressee:   WILLIAM  HOWLAND - GREEN MOUNTAIN AUDOBON SOCIETY
Authors:     JOHN  DE  VILLARS - ENVIRONMENTAL PROTECTION AGENCY
Date:        April 7,  1997
Format:      LETTER                        No.  Pgs:  1
AR No.       13.07.11                     Document  No.  000392

Title:       Local Advisory Panel for  Scientific  Evaluation
              Component of  the Pine Street Coordinating Council to Receive Environmental Merit Award.
Addressee:   JOHN  AKEY
Authors:     JOHN  DE  VILLARS - ENVIRONMENTAL PROTECTION AGENCY
Date:        April 7,  1997
Format:      LETTER                        No.  Pgs:  1
AR No.       13.07.12                     Document  No.  000393
Title:       Local Advisory  Panel  for  Scientific  Evaluation
              Component of the Pine Street Coordinating Council to Recieve Environmental Merit Award.
Addressee:   LORI FISHER  - LAKE  CHAMPLAIN  COMMITTEE
Authors:     JOHN DE VILLARS  - ENVIRONMENTAL  PROTECTION AGENCY
Date:        April 7,  1997
Format:      LETTER                        No.  Pgs:  1
AR No.       13.07.13                      Document  No. 000394

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14.01
              CONGRESSIONAL  RELATIONS  -  CORRESPONDENCE
Title:        Status  of  Leverage  Partners  as  PRP's.
Addressee:    AMES  JEFFORDS  -  UNITED  STATES SENATE
Authors:      MERRILL HOHMAN - EPA REGION  I
Date:         March 1, 1993
Format:       LETTER                        No. Pgs:  3
AR No.        14.01.1                      Document  No.  000582
16.01
             NATURAL  RESOURCE  TRUSTEE  -  CORRESPONDENCE
Title:        Invitation  to  Join  in  PRP  Negotiations  to  Fund
              and Work on Phase  II of the ARI/AFS Statement of Work.
Addressee:    JACK  LONG - VT DEPT. OF  ENVIRONMENTAL CONSERVATION
Authors:      MARY  JANE 0'DONNELL -  ENVIRONMENTAL  PROTECTION AGENCY
Date:         November 23, 1994
Format:       LETTER                         No.  Pgs:  4
AR No.        16.01.1                        Document  No.  000396

Title:        Invitation  to  Join  in  PRP  Negotiations  to  Fund
              and Work on Phase  II of the ARI/AFS Statement of Work.
Addressee:    WILLIAM PATTERSON - US DEPARTMENT  OF INTERIOR
Authors:      MARY  JANE 0'DONNELL -  ENVIRONMENTAL  PROTECTION AGENCY
Date:         November 23, 1994
Format:       LETTER                         No.  Pgs:  4
AR No.        16.01.2                        Document  No.  000397

Title:        Invitation  to  Join  in  PRP  Negotiations  to  Fund
              and Work on Phase  II of the ARI/AFS Statement of Work.
Addressee:    KENNETH FINKELSTEIN
Authors:      MARY  JANE 0'DONNELL -  ENVIRONMENTAL  PROTECTION AGENCY
Date:         November 23, 1994
Format:       LETTER                         No.  Pgs:  4
AR No.        16.01.3                        Document  No.  000398
17.02
              SITE MANAGEMENT  RECORDS  - ACCESS  RECORDS
Title:       Access  to  Property  on  or Adjoining the  Pine  Street Canal  Site.
Addressee:   DAVID DUBRUL  -  JACKSON TERRACE  APARTMENTS
Authors:     SETH PITKIN - JOHNSON  COMPANY
Date:        August  12, 1994
Format:      LETTER                        No.  Pgs:  2
AR No.       17.02.1                       Document  No.  000623

Title:       Access  to  Property  on  or Adjoining the  Pine  Street Canal  Site.
Addressee:   WILLIAM DUNCAN  -  BURLINGTON  PUBLIC SCHOOLS
Authors:     SETH PITKIN - JOHNSON  COMPANY
Date:        August  12, 1994
Format:      LETTER                        No.  Pgs:  1
AR No.       17.02.2                       Document  No.  000624

Title:       Access  to  Property  on  or Adjoining the  Pine  Street Canal  Site.
Addressee:   SKIP FARRELL  -  L.E.  FARELL COMPANY
Authors:     SETH PITKIN - JOHNSON  COMPANY
Date:        August  12, 1994
Format:      LETTER                        No.  Pgs:  1
AR No.       17.02.3                       Document  No.  000670
17.07
              SITE MANAGEMENT  RECORDS  -  REFERENCE  DOCUMENTS
Title:        Bibliography  for  the  Pine  Street  Canal  Site.
Addressee:    SHEILA ECKMAN - EPA REGION I
Authors:       GREGORY JOHNSON -  JOHNSON  COMPANY
Date:         March  21,  1996
Format:       MISCELLANEOUS                 No.  Pgs:  114
AR No.        17.07.1                       Document  No.  000226

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PREFACE
                                         APPENDIX E
                                   RESPONSIVENESS  SUMMARY
                              PINE STREET CANAL  SUPERFUND SITE

                                   RESPONSIVENESS  SUMMARY

                                       SEPTEMBER 1998
                                      TABLE OF CONTENTS
I.    OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE AFS AND
      PROPOSED PLAN  	2

II.   SITE HISTORY AND  BACKGROUND ON COMMUNITY INVOLVEMENT AND
      CONCERNS 	4

III.   SUMMARY OF PUBLIC COMMENTS  AND AGENCY RESPONSES 	6

ATTACHMENT A Transcript of public hearing (June 24,  1998)

ATTACHMENT B Written  comments  received during public comment period

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                                PINE STREET CANAL RESPONSIVENESS SUMMARY

                                                PREFACE


The U.S. Environmental Protection Agency  (EPA) held a 60-day public comment period from June 5 to
August 7, 1998, to provide an opportunity for public input on the Additional Remedial Investigation
(ARI), Additional Feasibility Study  (AFS) and Proposed Plan to address contamination at the Pine Street
Canal Superfund Site in Burlington, Vermont. The EPA prepared the Proposed Plan based on the results of
the ARI, AFS, Supplemental RI (SRI), Baseline Risk Assessment, Supplemental Baseline Ecological Risk
Assessment  (SBERA),  other documents. The ARI was conducted to supplement the SRI in identifying the
nature and extent of site contamination and in supporting the Baseline Risk Assessment and the SBERA
which identify potential risks to human health and the environment. The AFS examined and evaluated
various options, or alternatives, for addressing the contamination. The Proposed Plan, issued on May
29, 1998, presented the EPA's preferred alternative for the site. All documents that were used in the
EPA's selection of the preferred alternative were placed in the Administrative Record which is
available for public review in Burlington at the Fletcher Free Public Library and Bailey Howe Library
at the University of Vermont, and at the EPA Records Center in Boston, Massachusetts

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 AFS and Proposed Plan.  This section briefly
       outlines the  remedial alternatives evaluated in the AFS and the Proposed Plan,  including the
       selected remedy.

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 public comment period.

A copy of the transcript from the public hearing held on Wednesday, June 24, 1998, in Burlington,
Vermont, is included as Attachment A. The written comments received during the comment period are
included in Attachment B.


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

Using information gathered during the Supplemental RI, Additional RI, Baseline Risk Assessment, and
Supplemental Baseline Ecological Risk Assessment, the EPA identified several cleanup objectives for the
Pine Street Canal Site.

The primary cleanup objectives are to reduce risks to public health and the environment by 1)
preventing direct exposure to contaminated materials on site; 2) minimizing the movement of
contamination away from the site; and 3)  preventing the use of groundwater that might pose a risk to
human health.

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

The EPA's selected remedy (Alternative 3a), includes the following features:

       •     Capping  contaminated sediments in Canal and Wetlands Subareas  1,  2,  3,  7  and 8;
       •     Institutional controls for groundwater below the site;
       •     Institutional controls for land-use development;
       •     Site boundary definition;
       •     Long-term performance monitoring;  and,
       •     Five-year reviews.

The estimated net present worth of the remedy is $4,3379,000. This alternative was selected because it
achieved the best balance among the nine criteria that the EPA is reguired by law to use to evaluate
the cleanup options. The selected remedy provides an effective reduction in human health and ecological
risk through a combination of source control  (capping), institutional controls to prevent future risks,
and long-term performance monitoring to ensure the remedy continues to be protective of human health
and the environment in the future. The remedy attains Federal and State reguirements that are
applicable, or, relevant and appropriate for this remedial action, reduces the mobility of hazardous
substances through containment,  and utilizes permanent solutions to the maximum extent possible.

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The following other alternatives were considered to address the contamination at the site:

• Alternative 1: No Action Groundwater, Subareas 1-8, and Uplands/Wetlands; Long- term
Monitoring. Under this alternative, no treatment or containment of contaminated sediments
in Subareas 1, 2 and 8 (canal and turning basin) or Subareas 3, 4, 5, 6, and 7 (surrounding
uplands and wetlands) would occur, no effort would be made to control the migration of
contamination, and no institutional controls regulating groundwater use or future land use
would be put in place.

• Alternative 2a: Institutional Controls for Groundwater and Uplands/Wetlands; No Action in
Subareas 1, 2, 3, 7, and 8; Long-term Monitoring. Under this alternative, a variety of
institutional and administrative controls for groundwater and uplands/wetlands areas. No
treatment or containment of contaminated sediments at the site would occur, and no effort
would be made to control the migration of contamination.

• Alternative 2b: Institutional Controls for Groundwater and Uplands/Wetlands; No Action in
Subareas 1, 2, 7, and 8; Capping in Subarea 3; Long-term Monitoring. Alternative 2b is
identical to 2a with the addition of a sand and silt cap over the emergent wetlands in
Subarea 3.

• Alternative 2c: Institutional Controls for Groundwater and Uplands/Wetlands; No Action in
Subareas 3 and 7; Capping in Subareas 1, 2, and 8; Long-term Monitoring. Alternative 2c is
identical to 2a, however, this one provides for capping the contaminated sediments in
Subareas 1, 2 and 8 (the canal and turning basin) with sand and silt.

• Alternative 2d: Institutional Controls for Groundwater and Uplands/Wetlands; No Action in
Subareas 3 and 7; Excavation and Off-site Treatment and Disposal for Subareas 1, 2, and 8;
Long-term Monitoring; Dewatering. This alternative includes all the components of
Alternative 2, except instead of capping Subareas 1, 2, and 8, the contaminated sediments
would be excavated and taken off site for treatment and disposal.

• Alternative 3a: Institutional Controls for Groundwater and Uplands/Wetlands; Capping in
Subareas 1, 2, 3, 7, and 8; Long-term Monitoring. The remedy in the Proposed Plan and
selected by the EPA in the Record of Decision.

• Alternative 3b: Institutional Controls for Groundwater and Uplands/Wetlands; Capping in
Subareas 3 and 7; Excavation and Off-site Treatment/Disposal for Subareas 1, 2, and 8;
Long-term Monitoring; Dewatering. This alternative includes all the components of
Alternative 2d, with the addition of a sand/silt cap in Subareas 3 and 7.

• Alternative 3c: Institutional Controls for Groundwater and Uplands/Wetlands; Capping in
Subareas 1, 2, 3, and 8; No Action in Subarea 7; Long-term Monitoring. This is similar to
the selected remedy, 3a, however Subarea 7 would not be capped.

II. SITE HISTORY AND BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

Site History

The site has been used for various industrial and commercial purposes since the mid-1800s, when the
railroad on the western edge of the canal was built. The barge canal and turning basin were first
dredged in 1868 to provide access to Lake Champlain for several lumber companies, a coal company and a
boat builder. Around 1895, Burlington gas works, a manufactured gas plant (MGP), was constructed near
Pine Street, just north of what is now the Burlington Electric Department. The plant used a coal
gasification process to manufacture gas for the community. The Burlington gas works reportedly disposed
of large guantities of coal gasification wastes, such as coal tar, fuel oil, cyanide, contaminated wood
chips, iron oxide, cinders and metals at its former location along Pine Street and in the wetland areas
behind the plant. The gas plant ceased operations in 1966 and was dismantled in 1967. These waste
materials are the primary source of contamination at the site.

The first observation of visible contamination on surface water was documented in 1926, when a daily
log book for the MGP noted that light tar from the plant's tar well was running into the lake. A series
of oily releases to the canal occurred in the late 1960's and early 1970's. In 1977 and 1978, the State
of Vermont took exploratory borings for the Southern Connector highway that was proposed for the site.
The borings revealed extensive sub-surface contamination. In 1981, the State of Vermont nominated the
Pine Street Canal Site for the newly-created Superfund program. The site was proposed for the CERCLA
National Priorities List on October 23, 1981, and listed on September 8, 1983. The Vermont Agency of
Transportation investigated the site,primarily along the proposed Southern Connector right-of-way,
until 1988, when the EPA took the lead for site investigations and broadened its scope.

In 1987, 1988 and 1992, the EPA notified parties who owned portions of the site, were former owners or
operators of the gas plant, or had succeeded to the liability of former operators of the gas plant, of
their potential liability and responsibility for cost of environmental response actions under CERCLA.
The EPA entered into negotiations with PRPs for the performance of the Remedial Investigation and
Feasibility Study (RI/FS) and reimbursement of the EPA's response costs in 1988, but no agreement was
reached. On June 27, 1988, the EPA began the RI/FS, financed by the Superfund program. In December,
1988, the EPA filed suit against three PRPs who had owned and/or operated the gas plant from 1930-1968,
seeking reimbursement of past costs incurred by the EPA. In 1990, the EPA reached a settlement for

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$945,000 in past response costs and reserved the right to seek the cost of future response actions from
the parties. The settlement was approved by the United States District Court for the District of
Vermont on December 26, 1990.

In November of 1992, the EPA proposed a cleanup plan for the site. The plan called for (1) the
construction of a containment/disposal facility (CDF) over the most heavily contaminated portion of the
site (wetlands west of the former MGP); (2) dredging, contaminated sediments from the canal and
turning, basin and placing the sediments in the CDF, (3) collecting mobile coal tar and coal oil; (4)
on-site restoration or replication of wetlands; and, (5) institutional controls to protect the
integrity of the CDF and prevent ingestion of groundwater. Public comment on the 1992 Proposed Plan was
overwhelmingly negative. Commenters raised several concerns about the studies, including guestions
about the nature and extent of ecological risk at the site, the migration of contaminated groundwater,
and air guality. Commenters were also concerned about the short-term health effects of excavation, and
the construction of a landfill on the shores of Lake Champlain. After a six-month comment period, the
EPA withdrew the proposed cleanup plan due to community opposition.

Following the withdrawal of the EPA's 1992 Proposed Plan, the EPA and the State of Vermont issued an
Administrative Order on Consent in 1994 (U.S. EPA Docket No. 1-94-1065), and a second Administrative
Order on Consent in 1995 (U.S. EPA Docket No. 1-95-1048), under which certain PRPs agreed to undertake
an Additional Remedial Investigation (ARI) and Additional Feasibility Study (AFS), and to compensate
the EPA and the State of Vermont for the costs of oversight on the ARI and AFS.

Community Involvement and Concern

Community concern and involvement with the site has varied over time. The EPA's Community Relations
Plan, released in December 1990, outlined a program to keep citizens informed about and involved in
activities during the remedial process. Between the time of the site's listing on the NPL in 1983, and
the 1992 Proposed Plan, the EPA held meetings, and issued fact sheets and press releases to keep the
community and other interested parties apprized of activities at the site. The public's interest
peaked in 1992 when the EPA proposed a cleanup plan. In response to reguests from the community, the
EPA extended the formal comment period on the proposed cleanup plan from 30 days to six months. The EPA
held numerous public informational meetings and a public hearing during those six months to discuss and
receive comments on the proposed remedy. The EPA received hundreds of comments, generally opposing the
1992 Proposed Plan. The EPA withdrew the Proposed Plan in June 1993.

After the EPA's withdrawal of the proposed cleanup plan in 19933, environmental regulators, the PRPs,
and citizens and groups who had been active in commenting on the 1992 Proposed Plan, formed the Pine
Street Barele Canal Coordinating Council (PSBCCC). The purpose of the council was to provide for more
meaningful public involvement in the selection of a remedy. Specifically, the PSBCCC's mission was to
design and oversee the implementation of additional studies to fill in data gaps from prior studies,
and to recommend a proposed remedy for the site to EPA management. The PSBCCC consists of
representatives of the EPA, Vermont DEC, City of Burlington, US Fish & Wildlife Service, Lake Champlain
Committee, Pine Street Arts and Business Council, Ward 5 Planning Association, and PRPs. The Lake
Champlain Committee received a Technical Assistance Grant under Section 117 (e) of CERCLA, and used the
funds to hire technical experts to advise the community representatives on the Council. The EPA
retained its statutory responsibility for final remedy selection.

The PSBCCC retained a neutral facilitator and agreed on Organizational Protocols to guide the
decision-making process. Decisions were made with consensus from each party on the Coordinating
Council. The Council formed technical work groups to direct each phase of the ARI/AFS which was being
conducted by the PRPs contractor. The Council and the work groups had an opportunity to comment on all
interim and draft technical documents. The Coordinating Council formed a Public Participation
Committee, issued published progress updates, and held community informational meetings. PSBCCC
meetings were announced in the Federal Register and to local news media, and open to the public. The
informal summaries of the PSBCCC meetings are available as part of the Administrative Record for this
Record of Decision.

On May 27, 1998, the PSBCCC formally recommended to the EPA New England Regional Administrator a
cleanup plan for remediation of the Pine Street Canal Site. The Agency, in the 1998 Proposed Plan,
adopted the PSBCCC's recommendation as the proposed preferred alternative. This proposed preferred
alternative is the selected remedy in the September 1998 Record of Decision.

III. SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES

The 1992 Proposed Plan

As discussed above, the EPA proposed a remedy in 1992, which was withdrawn after a six month public
comment period due to community opposition. The comments received on the 1992 Proposed Plan are
included in the Administrative Record for the Pine Street Canal Site. Commenters raised several
objections. In general, commenters believed that the proposed cleanup plan, which called for dredging
contaminated sediments and disposal on site in a landfill, was too intrusive, that there would be
unacceptable short-term human-health risks associated with excavation, and that the proposal was too
costly. In addition, commenters guestioned the adeguacy of the ecological risk assessment, and raised
guestions about gaps in the data.

This responsiveness summary does not include detailed responses to comments on the 1992 Proposed Plan,
as the plan has been withdrawn. However, the ARI and AFS reports, as well as other material in

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Administrative Record Addendum IV, are responsive to the concerns raised during that six-month public
comment period.

The 1998 Proposed Plan

This Responsiveness Summary addresses comments pertaining to the Proposed Plan that were received by
the EPA during the extended public comment period (June 5 to August 7, 1998). Seven individuals,
including representatives of Vermont DEC, the City of Burlington, and area residents, submitted written
comments. Five individuals, including representatives of city and state government, the Lake Champlain
Committee and the PRPs, submitted oral comments at the
public hearing (June 24, 1998). A copy of the public hearing transcript is included as Attachment A.
Copies of the written comments are included as Attachment B.

Comment 1: We endorse the selected cleanup plan, and the work of the Pine Street Barge Canal
Coordinating Council.

EPA Response: Of the 12 sets of comments received during the public comment period, six were
endorsements of the selected remedy and/or the Coordinating Council process. These commenters were
State Representative Mary Sullivan, George Desch of the State of Vermont, Martin Johnson on behalf of
the PRPs, Wayne Senville on behalf of the Burlington Planning Commission, and Fred G. Hill. The City
Council of the City of Burlington passed a resolution endorsing the plan, and urging work to begin as
guickly as possible.

Comment 2: Who controls the site? Who maintains the controls and facilities?

EPA Response: Under the Superfund law, the remedy selected in the Record of Decision may be performed
either by the EPA, or by the potentially responsible parties (PRPs), under the oversight of the EPA and
Vermont DEC. In this case, the EPA plans to negotiate with the PRPs and enter into a consent decree
(which must be approved by the federal court) that will reguire the PRPs to perform the remedy.

During the construction of the remedy, the PRPs would control the areas of the site where work will be
undertaken, sectiring access and maintaining safety. In areas of the site where work is not conducted,
as well as after completion of the construction, the owners of the various parcels will control their
properties, subject to certain restrictions that will be imposed by the EPA. As part of the remedy, the
EPA. is reguiring certain land- and water-use restrictions (known as institutional controls) to be in
place to prevent or limit exposures to contaminants that could be a significant risk to human health,
such as excavations below five feet, or use of the groundwater for drinking. The PRPs will be reguired
to work with the EPA to obtain the deed restrictions, conservation easements, zoning ordinances or
legislation needed to impose these controls. The institutional controls will include a provision
allowing the EPA, State of Vermont, or other responsible entity(ies) to enforce the restrictions needed
to protect human health. The EPA or the State will be able to take action to prevent unsafe uses of the
site.

The selected remedy does not call for construction of facilities, other than the subagueous cap. If the
PRPs perform the remedy, they will be responsible for ensuring that the cap remains intact and is not
disturbed after construction is complete. If the EPA performs the remedy, EPA and Vermont DEC would
assume that responsibility.

Finally, the EPA and Vermont DEC will oversee the PRPs' performance to ensure that the remedy remains
protective iin the long term. The EPA will reguire regular monitoring of the site after construction is
complete to ensure that the remedy remains effective. This monitoring will take place guarterly or
semi-annually in the first several years after construction, and will continue on a regular basis
thereafter as long as necessary. 1 Because the remedy calls for a large volume of wastes to be left in
place under the surface at the site, long-term monitoring will be needed for the indefinite future to
insure that site conditions do not change over time and cause a risk to health or the environment.
Long-term monitoring will also confirm among other things, that contaminated groundwater does not
migrate to Lake Champlain and that the subagueous cap provides an effective barrier against exposure of
wildlife to contaminants. Under Section 121 (c) of CERCLA, the EPA must conduct a formal review of the
remedy every five years to ensure that the remedial action continues to protect human health and the
environment.

Comment 3: The plan does not provide adeguate safeguards to reguire the PRPs to take corrective action
if the proposedplan does not work.

EPA Response: The EPA will not allow the PRPs to perform the site remedy unless adeguate legal
safeguards are included. The EPA will negotiate with the PRPs to enter into a consent decree,
enforceable in court, that will reguire the PRPs to perform the remedy, attain the performance
standards set out in the ROD, and continue long-term monitoring for as long as the EPA and the State of
Vermont deem necessary. If the PRPs do not agree to the EPA's conditions for the consent decree, the
EPA will either unilaterally order the PRPs to perform the remedy as the EPA reguires, or the federal
government will perform the remedy, and the EPA will sue the PRPs for costs.

EPA consent decrees reguire the PRPs to provide financial assurances (such as establishing a trust
fund, or posting a bond) showing that they can perform the remedy that is described in the Record of
Decision (ROD). In addition, under the consent decree, the PRPs must agree to perform additional work
consistent with the scope of the remedy selected in the ROD to make sure that the performance standards
are attained and to maintain the effectiveness of the remedy. Thus, for example, if the subagueous cap
becomes recontaminated through the upward flow of contaminants, the PRPs will be reguired under the

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consent decree to repair or redesign it.

EPA consent decrees, however, do not require the PRPs to agree at this time to perform an entirely new
remedy (or to post a bond to fund an entirely new remedy) if the remedy in the ROD is ultimately
ineffective. Rather, the United States reserves the right to reopen the lawsuit against the PRPs for
performance of a new remedy at any time if, based on new information, the EPA determines that the
remedy selected in the ROD does not protect human health and the environment. Under the law, the public
would be involved in selection of any remedy that is a fundamental change from the remedy set out in
the ROD. As a matter of national Superfund policy, the EPA uses this "reopener" approach to deal with
the possibility -- which we consider unlikely at Pine Street -- that an entirely new remedy is
required. In this case, given the number of large entities that are, PRPs at Pine Street and the
strength of the EPA's case against them, this approach should provide that funds will be available if a
fundamentally new remedy is needed.

1 It is important to note that the monitoring period is not limited to thirty years. A 30-year
monitoring period was assumed in the AFS for the sole purpose of deriving a present worth of the cost
of monitoring, to be used in comparing various alternative remedial approaches.
Comment 4: The plan does not result in a cleanup of the site, but rather merely, covers up the
hazardous waste on site resulting in continuing serious ecological and puhlic health hazards.

EPA Response: While the National Contingency Plan (NCP) does identify a preference for treatment
(cleanup) that would reduce the toxicity, mobility and volume of contaminants, other forms of response
actions are acceptable, so long as they reduce the risks posed by the contamination. The selected
remedy contains the contaminants and reduces the contact or exposures between the contaminants and
environmental and human receptors, thus reducing the risks to acceptable levels.

The Additional Feasibility Study evaluated a range of alternatives including, no action, treatment, and
containment alternatives. The EPA is required by law to evaluate these alternatives against nine
criteria. These criteria fall in three categories: threshold, primary balancing and modifying. There
are two threshold criteria which must be met in order for an alternative to be considered for
selection. These are overall protection of human health and the environment, and, compliance with
applicable or relevant and appropriate federal and state requirements. The five primary balancing
criteria (long-term effectiveness and permanence; reduction of toxicity, mobility, or volume through
treatment; short-term effectiveness; implementability; and cost) are used to evaluate and compare the
elements of alternatives that meet the two threshold criteria. Finally, state acceptance and community
acceptance are used on the final evaluation of remedial alternatives.

The selected remedy meets the threshold criteria, provides the best balance of long-term and short-term
effectiveness and permanence, implementability, cost, and reduction of toxicity, mobility or volume
through treatment, has concurrence from the State of Vermont, and, as exhibited during the comment
period, has wide community acceptance. It is the remedy endorsed by the Pine Street Barge Canal
Coordinating Council, a group whose membership is representative of different "wedges" of the community
such as the Pine Street Arts and Business Council, Ward 5 Planning Association, The Lake Champlain
Committee, the City of Burlington, and the PRPs. As such, the selected remedy is an acceptable response
action as envisioned by the Superfund statute and the NCP.

Comment 5: Hazardous wastes are not presently in contact with the environment and present no human
health or ecological hazard and will continue to remain isolated from the environment and
microorganisms will, given time, break down the wastes into harmless materials.

EPA Response: The EPA disagrees with this statement. The underlying basis of the remedy is that
contamination is, in fact, in contact with the environment and does present unacceptable risks to human
health and the environment. The selected remedy will provide the means to protect people and other
wildlife from the unacceptable risks associated with contaminated environmental media. Biodegradation
is not a component of the selected remedy.

Comment 6: The site is located upstream of the water supply for the City of Burlington.

EPA Response: The EPA and the PSBCCC are extremely concerned with protecting the natural resources
provided by Lake Champlain, EPA's 1992 Proposed Plan included active measures to ensure that no
contamination would migrate to Lake Champlain. The PSBCCC reevaluated the potential for contaminate
migration to the lake and determined that there is no negative effect. The selected remedy includes
monitoring requirements to ensure that the site does not have a negative impact on the lake in the
future.

Comment 7: It is not known how much time will he required to break this material down into harmless
material. More information is needed before reliance is placed on the theory that a silt/sand cap will
contain the wastes and microorganisms will allow the site to "heal " itself.

EPA Response: Remedial investigations and feasibility studies done at the site looked into the
question of bioremediation/biodegradation and the extent to which the site is "healing" itself. It was
determined that although limited biodegradation may be occurring along the fringe areas of the site,
and may assist in preventing further migration, it was not considered to be a viable alternative for

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remediation. Site-related contamination does not appear to be leaving the site at concentrations of
concern. The primary risks are on site, and are from ecological and human exposure to contaminated
sediments and soils, and human consumption of contaminated groundwater. The remedy, which calls for
capping contaminated sediments and institutional controls to prevent human exposure to contaminated
environmental media, does not rely on biodegradation.

Comment 8: There was limited opportunity for true public input and review before the completion of the
proposed plan. The work of the Council was flawed because the City of Burlington and the State of
Vermont Agency of Transportation were PRPs.

EPA Response: The EPA disagrees with this comment. As detailed in Section III of the Record of
Decision, the EPA agreed to an intensive community participation process, known as the Pine Street
Barge Canal Coordinating Council. The Council's involvement over a five year period (1993-1998) in the
development of the Additional Remedial Investigation, the Additional Feasibility Study, and opportunity
for comment on the proposed plan goes far beyond the legal reguirements of the National Contingency
Plan, 40 C.F.R. 300 et seg.

The EPA took extraordinary steps to ensure that the entire Coordinating Council process was fair and
open to the public. The Council evolved out of a core group of parties who had been active in
commenting on the EPA's original 1992 Proposed Plan (which was later withdrawn). The representatives of
the Lake Champlain Committee on the Council had submitted comments on behalf of many environmental
organizations in Vermont in 1992 and 1993. Likewise, the PRPs' representatives had been very involved
in the 1992 proposal. When the EPA decided to expand upon this core group to initiate a
consensus-building council, the EPA hired a neutral facilitator to convene a group representing all
parties interested in the site. Based on the suggestions made by the local community, the facilitator
solicited additional citizen representatives for the Council, including a representative of the City of
Burlington, the Ward 5 Neighborhood Planning Association, and the Pine Street Arts and Business
Council. The intent of the Council was to have a broad spectrum of members -- from environmental groups
to responsible parties to local residents to federal and state environmental regulators -- that could
be representative of the major interests in the community at large.

The Coordinating Council adopted a set of protocols governing its conduct, which expressly included the
idea that each member on the council represented a larger "wedge" of people with similar interests in
the community. Each council member was responsible for checking back with his or her constituencies
periodically. The Ward 5 Planning Association member freguently conferred with local residents about
issues that had arisen during the Council, and reported back their responses to the Council. Similarly,
the representative of the Pine Street Arts and Business Association freguently briefed local businesses
and others about the environmental and land use issues raised in the Council.

Although the EPA did not issue a formal open solicitation for members on the Council, public attendance
and participation at Coordinating Council meetings was encouraged. The Council had scores of public
sessions which were announced to the press and published in the Federal Register. Many of the meetings
were broadcast on local cable television, and there were numerous press stories about the workings of
the Council between 1993 and 1998. As the meeting minutes show, several Council meetings included the
active participation of non-Council members. The Coordinating Council maintained two mailing lists. The
larger mailing list of over 900 names received periodic updates including three Progress Updates and a
copy of the Proposed Plan. A smaller mailing list received copies of summaries of Council meetings
prepared by the facilitator. The Progress Updates included instruction for being added to the smaller
mailing list of those desiring summaries of each meeting.

The non-PRP members of the Council had significant technical resources available to them. The EPA gave
the Lake Champlain Committee a $150,000 grant for technical assistance. The Lake Champlain Committee
hired the LAPSE team, a group of scientists from UVM and elsewhere to help develop, critigue and
oversee the ARI and AFS studies. These technical advisers were key players in evaluating several
issues, including the likelihood that PAH contamination would ever reach Lake Champlain at levels of
concern, and the significance of the ecological risk at the site, The LAPSE team members worked closely
with all the citizen members of the Council.

The EPA disagrees that the work of the Council was flawed because the City of Burlington and the State
of Vermont Agency of Transportation were PRPs. The fact that a city or state may be both a regulator
and a potentially responsible party is not uncommon. (In fact, the State of Vermont would have a
regulatory role to play in selection of a remedy under the National Contingency Plan even if the
Coordinating Council did not exist.) Furthermore, the State had separate representatives on the Council
representing the Department of Environmental Conservation and the Vermont Agency of Transportation
(represented by the landowner PRPs.) The City has a larger perspective than simply environmental
outcomes; to that end, it is appropriate that the City considered not only environmental issues, but
also transportation, land use and economic development issues in its work on the Council.

In sum, the EPA believes that the Pine Street Coordinating Council and the presentation of the Proposed
Plan to the public for comment has been extraordinarily open, and that the 1998 Proposed Plan is the
result of good science, policy and public participation.

Comment 9: Please consider creating a small outlet to Lake Champlain to enhance water circulation to
overcome the problem of stagnant, scummy water in the barge canal in the winter.

EPA Response: The surface water of the Pine Street Barge Canal receives nutrients from the stormwater
inflow from three storm sewers. These nutrients stimulate and support growth of vegetation in the canal
and turning basin. Large mats of vegetation sometimes form on the water's surface, giving the

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appearance of scum.

We expect the cap placed on the canal's contaminated sediments to isolate many nutrients presently in
the sediments, reducing nutrient availability for plant growth. In addition, the selected remedy will
enhance nutrient retention in a stormwater basin near the south end of the canal, thereby reducing the
level of nutrients entering the canal. However,  not all sources of nutrients entering the canal can be
controlled, and the rich plant growth typical of summer conditions will eventually reoccur.

Creation of an additional hydrologic connection with Lake Champlain would be counter to the goals of
the selected remedy which is to isolate and contain contaminants in place, thereby protecting Lake
Champlain. Based on extensive study, there is currently no adverse migration of contamination from the
site to the lake. Another outlet to Lake Champlain could jeopardize that desirable situation. Further,
Lake Champlain benefits from better stormwater treatment that results from the stormwater passing
through the entire length of the canal before it enters the lake. Since there does not appear to be any
adverse impact from these mats, aside from aesthetics,  and given the benefits of having thriving
vegetative growth  (including fish habitat),  the remedy will not change to address this concern.

Comment 10:  Please extend the public comment period

EPA Response:  In response to this reguest,  the EPA extended the public comment period from 30 to 60
days (June 5, 1998 to August 7, 1998).

Comment 11:  Was bioturbation considered during the development of the cleanup plan? If so, on what
basis it was decided that bioturbation over the longer term it will not be a concern?

EPA Response:  Yes, bioturbation was a key factor that had to be considered. Based on the depositional
environment, fine sediments and benthic organisms found in the canal, the zone of bioturbation in the
fine sediment layer is approximately 0-10 cm below the sediment surface. Therefore,  a clean sediment
layer greater than this thickness is reguired to prevent the exposure of benthic organisms to
contaminants through bioturbation.

Two factors provide assurance that bioturbation will not become a concern in the future. First, the cap
itself will be constructed to provide approximately one foot of clean cap material and the final layer
will contain silt to recreate a benthic environment similar to the natural condition. Second, the canal
will continue to be a depositional environment over time, thus further isolating the benthic community
from the buried contaminated sediments. Bioturbation may mix the newly-deposited material with the cap
material, but the cap will be designed to provide considerably more than 10 cm of clean material over
the present sediment surface, so the bioturbation will not mix the old contaminated material into the
new material.

Comment 12:  Does the proposed remediation plan take into account the preferred permanent route of the
Southern Connector through the Barge Canal?

EPA Response:  Between 1993 and 1998,  the Coordinating Council worked closely with the City of
Burlington and the State of Vermont to coordinate planning for the Southern Connector and the Superfund
remedy. The name of the Coordinating Council reflects the original intent of the participants to
coordinate the many interests affecting the site, including the potential building of the proposed
Southern Connector along a route that might pass through a portion of the Pine Street Canal Superfund
Site. Several members of the Coordinating Council continually advocated that the AFS evaluate an
alternative(s) that would integrate the remediation of the site with the building of a highway.
However, such an alternative could not be developed and evaluated without specific highway design
details, including the preferred route. The City of Burlington and Vermont AOT could not provide such
details, indicating that the preferred permanent route of the highway may not, in fact, be the original
C-8 alignment. The original alignment proposed in the late 1970s, which would cut through the wetland
areas,  would likely not be consistent with current regulations and policies aimed at protecting such
environments. The City of Burlington preferred to focus its resources on the proposed detour. The EPA
and other members of the Coordinating Council assisted the City of Burlington and Vermont AOT with work
plans to study the detour alignment, including providing detailed comments on the draft Environmental
Impact Statement.

Comment 13:  Does the proposed remediation plan preclude construction of the preferred permanent route
of the Southern Connecior through the Barge Canal?

EPA Response:  Recognizing that the Southern Connector project is a priority for the City of
Burlington, the Coordinating Council developed a Remedial Action Objective which states that the remedy
should: "Ensure to the extent practical that the remedy itself does not reduce the suitability of the
site for current and future uses, including a highway." The Council did not want to recommend an
alternative, if others are available,  that would itself prevent the construction of a highway. In order
to protect the integrity of the remedy, the selected remedy contains certain institutional controls
which will reguire developers to assess the impacts any proposed development, including a highway, may
have on the selected remedy.

Comment 14:  Will the institutional controls preclude any construction activities involving pilings or
any sort of work greater than five feet deep where the C8 segment is proposed?

EPA Response:  Excavations to depths greater than five feet (including those below the water table)  on
the some properties will be prohibited unless one or more of the following exceptions apply:  (a) the
excavation is performed to install, repair,  maintain, service or remove underground utility components,

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conduits, installations or channels, which may presently be in place deeper than five feet and which
may be below the water table;  (b) drilling, driving or boring to install pilings for otherwise
allowable construction is permitted; or,  (c) the excavation is performed in a location on the property
in which current contaminant concentrations at depths greater than five feet are below 140 mg/kg total
PAH. In the case of exceptions  (a) and  (b), workers conducting the excavations and working in the area
must use appropriate personal protective eguipment as reguired by the Occupational Health and Safety
Administration or its successor agencies, unless a site-specific risk assessment is performed and its
results have been approved by EPA prior to the excavation.

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                                              ATTACHMENT A

                                      Transcript of Public Hearing
                                              June 24,  1998
 1                             STATE OF VERMONT
                           CHITTENDEN COUNTY,  S.S.
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                          PINE STREET BARGE CANAL
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                              PUBLIC HEARING
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                         WEDNESDAY, JUNE  24,  1998
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10                              7:15 P.M.

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                      CONTOIS AUDITORIUM, CITY HALL
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15                        BURLINGTON, VERMONT

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                             Carol A. Boone
23                     COURT REPORTERS ASSOCIATES
                            117 Bank Street
24                         Burlington, Vermont

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 1                           INDEX




 2                                                      PAGE




 3          Welcoming Remarks,  Mary Jane O'Donnell      3




 4          Explanation of Project, Karen Lumino        5




 5          PUBLIC COMMENT




 6          George Desch, State of Vermont             10




 7          Mary Sullivan, State Representative               10




 8          Wayne Senville                             11




 9          Martin Johnson                             13




10          Lori Fisher                                13




11          Closing Remarks, Mary Jane O'Donnell              16




12




13




14




15




16




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                  COURT REPORTERS ASSOCIATES

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 1                   WEDNESDAY,  June 24,  1998; 7:15 P.M.




 2




 3               MS.  O'DONNELL:  Good evening,




 4          everyone. I'd like to welcome you to the public




 5          hearing of the Pine  Street Superfund Canal Project.




 6          My name is Mary Jane O'Donnell.  I'm from the




 7          Environmental Protection Agency in Boston and I




 8          will act as the moderator for tonight's meeting.




 9               I'd like to start off by introducing a couple of




10          people that are with me tonight.  Karen Lumino is




11          EPA's Project Manager; John Desch works for the




12          State of Vermont and he has his waste program plan.




13          In the back of the room most of you have met Sara




14          White who is EPA's project coordinator. Carol Boone




15          is a court stenographer who,  as you see, is




16          transcribing tonight's meeting.









17               I want to accomplish a couple of things tonight.




18          First of all, the major purpose of tonight's meeting




19          is to fully receive  your comments of EPA's proposed




20          cleanup plan. For those of us who were at the June




21          4th meeting, tonight's meeting is a bit more




22          structured than that meeting. In terms of format,




23          I'm going to start off by outlining a few ground




24          rules. Upon conclusion of that,  Karen is going to




25          give a short presentation of what our proposed









                      COURT REPORTERS ASSOCIATES

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 1          cleanup plan is.  Once we do that,  I will open the




 2          floor to any comments or Statements for the record




 3          that you might have,  and I understand that three




 4          people have stepped forward and said that they would




 5          like to make a statement.




 6               In terms of what we'll do with these comments,




 7          there are two ways people can make comments on the




 8          proposed cleanup plan: One is to make a statement




 9          at tonight's meeting; the second way is to submit




10          written comments to EPA by the end of our comment




11          period which ends on July 8th. We'll use those




12          comments to make revisions and hopefully potentially




13          any improvements to our cleanup plan, and then we




14          are reguired by law to respond in writing to those




15          comments, and we'll develop a written summary at




16          that time we make our final decision on the cleanup.




17               In terms of another logistical type item during




18          the formal part of this hearing because it is a




19          hearing we won't be in a position to answer any




20          guestions or comment on any statement you might




21          make, but we'll be here for the remainder of the




22          evening and can answer any guestions you might have




23          after the close of our public hearing.




24               Again, as I said before, the entire conference




25          will be transcribed for the record.












               COURT REPORTERS ASSOCIATES









 1               With that as background, I will turn things over




 2          to Karen.




 3                         MS. LUMINO: Thanks, Mary Jane. Good




 4          evening. As Mary Jane said, my name is  Karen Lumino




 5          and I'm the Project Manager at EPA in charge of the




 6          cleanup here at Pine Street.




 7               I'm actually encouraged by the low turnout




 8          tonight. That might seem odd to you, but although I




 9          wasn't here the last time we proposed a plan, I




10          understand there were people up in the  rafters who

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11          were hanging by their paperwork;  people were




12          obviously very upset with the plan that we proposed,




13          so over the five years after that we worked very




14          hard,  we had a consensus approach to come to a new




15          remedy that the public would like better. We have




16          had lots of opportunity for public input along the




17          way, so the fact that there are so few people here




18          tonight means we have done a really good job.




19               Why don't I,  because most of you I think are




20          guite familiar with the site, so I'm going to cut




21          right to the chase and get into what the proposed




22          plan actually is.




23               There are four components to the proposed plan.




24          First is, what we call the physical component and




25          this addresses the ecological risks that we found at









               COURT REPORTERS ASSOCIATES









 1          the site. This will involve placing a combination




 2          of silt and sand cap over five of the eight areas




 3          where we determined there were ecological risks.




 4          These are areas one, two, three,  seven and eight.




 5          We have a nice schematic over here which shows just




 6          how that cap would be put in place. We have got




 7          kind of a loader picking things up, we mix the




 8          slurry and then it will be piped out to a barge and




 9          then applied over these areas so this would address




10          the ecological risks that we found at the site.




11               The second component is the institutional




12          controls and these are the two which address the




13          human health risk. When we did our studies we found




14          the risks to human health included risk from




15          consumption of ground water, risk of exposure to




16          soils greater than below five feet. We determined




17          that this probably would not be a good place for a




18          children's daycare, so we are going to address that




19          in our remedy. And that is it.




20               The way we are addressing these is through




21          institutional controls. We are going to have deed

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22          restrictions,  we are going to have language actually




23          in deeds so that people will not be allowed to dig




24          below five feet to,  say,  put in a base foundation




25          for a building.









               COURT REPORTERS ASSOCIATES









      1          We didn't need to address the ground water,




      2     consumption of ground water because the state had




      3     already taken care of that by reclassifying the




      4     aguifer to Class 4 which is non-potable so no one




      5     will be able to place a drinking water well there.




      6          The third component is what we are calling a




      7     long-term monitoring component. We are leaving




      8     contamination in place. We need to be assured that




      9     any contamination doesn't get into Lake Champlain or




     10     get into the surface water of the Barge Canal. We




     11     need to insure that the sand and silt cap that we




     12     are placing over the areas of high risk are




     13     maintained in good condition, so that is what we are




     14     calling the long-term monitoring component.




     15          Then the fourth component is what we are calling




     16     the site boundary where you can see the original




     17     area of focus for the study included this whole




     18     general area with Lake Champlain on the west, we had




     19     Pine Street on the east,  Lakeside Avenue to the




     20     south,  and up in here are the Burlington Street




     21     Department buildings.




     22          With this remedy we are redefining the site




     23     boundary to include just this area inside the red




     24     dashed and dotted lines that were affected by gas




     25     plant wastes.  Anything outside of that we are












                     COURT REPORTERS ASSOCIATES

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 1          placing with institutional controls and we are doing




 2          this to monitor redevelopment at the site.




 3               So that is a guick rundown of the four




 4          components of the remedy that we are proposing here




 5          tonight.




 6               I'm doing overheads without an overhead machine




 7          so it's a little tricky.




 8               Mary Jane already went into what some of the




 9          next steps are during the public comment period.  We




10          did hold a public information meeting which was well




11          attended on June 4th. Tonight's meeting is formal




12          and the purpose is to take oral comments. If




13          anybody is either too bashful to make comments




14          tonight or on the way home you think of something




15          else you want to say, we are accepting written




16          comments. Written comments must be postmarked by




17          July 8th. We have handouts in the back with the




18          address where you should send those written comments




19          as well as we will accept things through E-mail.




20               I wanted to guickly run down a couple of the




21          things you might expect to see happen at the site




22          over the next few years. As I said, our public




23          comment period will close on July 8th. After that




24          we will reevaluate our proposed remedy based on the




25          comments that we received during the public comment







                      COURT REPORTERS ASSOCIATES

-------
 1          period and we will make our final selection.  That




 2          selection will be announced and this is called a




 3          record decision on the ROD. Along with the ROD we




 4          will issue what is called a responsiveness summary




 5          which is a written response to all the comments




 6          received during the public comment period. We




 7          expect that to happen in the fall of this year,




 8          that is the fall of 1998.




 9               After that we will work with the responsible




10          parties to implement the remedy.  We'll reach an




11          agreement with them after a period of negotiations




12          that will run through the winter of 1998. After




13          that we have a year of design. We'll design -- we




14          know generally what our remedy will look like but




15          this is a chance to get into the details, the




16          nitty-gritty of what this thing will actually look




17          like. After that in the spring of 2000 we hope to




18          begin construction.




19              Thank you.




20                           MS. O'DONNELL: Thank you, Karen. I




21          guess what I'd like to do now is open it up for




22          public comment. In terms of order, what I'd like to




23          do is first have the state and the elected officials




24          and those people who have signed up for comment, so




25          I will turn it over to George.









                       COURT REPORTERS ASSOCIATES

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 1                         MR.  DESCH:  Thank you.  I'm George




 2          Desch.  George Desch,  State of Vermont.  I have been




 3          involved in Pine Street for about five  years now




 4          since the time when the proposed plan was originally




 5          withdrawn and we adopted the coordinating council.  I




 6          would like to simply state for the record that the




 7          State supports the  remedy and the proposed plan as




 8          it's being presented over the last couple of weeks,




 9          and that is it.




10                         MS.  O'DONNELL: Thank you, George.




11          Mary Sullivan. If you could just state  your




12          name and your association with the State.




13                         MS.  SULLIVAN: I'm Mary Sullivan and




14          I'm a state representative and I represent the




15          district where the  Barge Canal is located. I want




16          to say how thrilled I was to really review the plan




17          and to see the molding of it is such a  different




18          reaction from what  I had five years ago. That is a




19          plan that really works for Burlington.  I believe it




20          protects the beauty of our area and so  forth down




21          there and I realize it's guite a beautiful area.




22          It's a plan I think that really developed from




23          citizens here who lived here and really they




24          participate in the  area and it really shows in the




25          plan, so I was really happy with it.  And I was also







                          COURT REPORTERS ASSOCIATES

-------
 1     happy with the fact that -- my husband and I live on




 2     Flynn Avenue and I happened to see a real component




 3     in the things that we are doing and I have spoken




 4     with a number of my neighbors and they were guite




 5     thrilled about it, too.  So I'd like to be a




 6     representative from that area.




 7                    MS. O'DONNELL: Thank you,  Mary.




 8               Wayne Senville?




 9                    MR. SENVILLE: Wayne Senville. I'm




10     here as a resident of Burlington.




11               First of all,  I want to commend everybody




12     involved in this project over the last couple of




13     years. It looks like you did a really good job.




14     The areas that I wanted to raise guestions about and




15     hopefully I will refer to responses on your formal




16     record involve the relationship between the




17     mediation plan and the Southern Connector Highway.




18               Just by way of brief background, the original




19     plan for the Southern Connector as identified I




20     believe way back in 1979 by the Environmental Impact




21     Statement had the Connector going through the Barge




22     Canal site. Obviously that got sidetracked pending




23     all the studies that EPA has done, and in the




24     meantime the City and State developed an interim




25     solution to route traffic on Pine Street, a









                COURT REPORTERS ASSOCIATES

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 1          temporary solution.




 2               In the record of this prcceeding there are many




 3          documents referencing the relationship between the




 4          Southern Connector and the cleanup of the Barge




 5          Canal.




 6               My first guestion is whether the remediation




 7          plan that is being proposed takes into account the




 8          preferred permanent route of the Southern Connector




 9          through the Barge Canal?




10               The second guestion that relates to that, I have




11          it,  there was an article in the Burlington Free




12          Press on September 23,  1997, and I'll guote one




13          sentence from it.




14               "Susan Compton,  a lawyer representing the City




15          of Burlington on the council," referring to the




16          Citizens Coordinating Council, "said the action plan




17          makes it possible that the Southern Connector might




18          someday be built through the Barge Canal."




19               My guestion is does the remediation plan




20          preclude construction of the Southern Connector,




21          specifically the CA line through the site?




22               And as a subsidiary guestion to that, in the




23          summary document for the plan of May 1998 report,




24          there is a statement that through legal mechanisms




25          place restrictions on portions of the site to









                     COURT REPORTERS ASSOCIATES

-------
 1          prevent residential use,  excavations and highly




 2          contaminated soil below five feet.




 3               My question is would this statement if that is




 4          part of the plan preclude any construction activity




 5          involving pilings or any sort of work greater than




 6          five feet deep where the CA segment is proposed?




 7               Thank you.




 8                         MS.  O'DONNELL: Thank you, Wayne. As




 9          I mentioned in my introductory comments, because




10          this is a formal hearing we will not be responding




11          to your guestions,  but I will be happy to talk about




12          it afterwards.




13                         MR.  SENVILLE: Thank you.




14                         MS.  O'DONNELL: Martin Johnson.




15                         MR.  JOHNSON: I have a short statement




16          just like George does. My name is Martin Johnson,




17          I'm speaking for the PRPs and I want to say the PRPs




18          support and endorse your proposed cleanup plan for




19          the site.




20                         MS.  O'DONNELL: Thank you very much.




21          Anyone else like to step forward and make a




22          comment?




23                         MS.  FISHER:  I'm Lori Fisher and I am




24          the Director of the Lake Champlain Committee and I'm




25          also a member of the Pine Street Barge Canal









                  COURT REPORTERS ASSOCIATES

-------
 1          Coordinating Council.




 2               Just over five years aco when the Lake Champlain




 3          Committee stood in this room we tried to pack this




 4          room with opponents, and we advocated strenuously




 5          against the EPA Barge Canal proposal for the site.




 6          And at the same time that we were vocal in our




 7          opposition, we also urged EPA to begin the process




 8          of finding a remedy for the Barge Canal anew,  this




 9          time in partnership with the community that was




10          going to live with that decision. That was the




11          message that was echoed by others and it was




12          listened to by EPA.




13               I think its often difficult for us as




14          individuals to own our mistakes and make changes. I




15          think it's even more rare that institutions do it,




16          but that is what EPA did in June of 1993 when they




17          shelved their proposed remedy and again in September




18          of that same year when they raised the formation of




19          a coordinating council which was the first time in




20          this nation where a public group making decisions by




21          consensus has been used to develop and recommend a




22          Superfund remedy. And in their response I think EPA




23          acted not like a bureaucracy but like a true steward




24          of the environment and a protector of the community




25          health.









                           COURT REPORTERS ASSOCIATES

-------
 1               The Coordinating Council's process has been one




 2          that has involved a lot of deliberation and patience




 3          and perseverance. The Lake Champlain Committee




 4          believes and wants to go on the record that after




 5          five years and the hundreds of meetings have really




 6          borne fruit with a remedy that is based on some




 7          science, that is environmentally protected,




 8          economically sound and responsive to community




 9          needs.




10               In 1993 the citizens of this region asked for a




11          remedy that was not intrusive,  that was protective




12          of Lake Champlain, and that to the extent possible




13          returned the plant back to the community. The




14          coordinating council has chosen and EPA has endorsed




15          a remedy that does just that. Not only will it deal




16          with contamination of the past, but it will also




17          protect water guality for the future.  We have really




18          been very pleased to move beyond our role,  the 1992




19          role as a critic to a partner in developing this




20          solution, and we commend you and the community




21          members who hung in there through five years,  and




22          also the PRPs,  particularly those with a base in




23          this region for trying to find a solution and




24          responding to community needs.  I think this is one




25          case where both the environmental bottom line and












                   COURT REPORTERS ASSOCIATES

-------
 1    the economic bottom line merged, and I think it is a




 2    good remedy. Thanks.




 3                    MS. O'DONNELL: Thank you, Lori.




 4         Is there anyone else who would like the make to




 5     statement?




 6         Seeing there are no hands coming forth, the




 7     meeting is now closed.




 8




 9                 (The hearing concluded at 7:30 p.m.)




10




11




12




13




14




15




16




17




18




19




20




21




22




23




24




25




                      COURT REPORTERS ASSOCIATES

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 1




 2               CERTIFICATE




 3




 4          I,  Carol A. Boone,  Notary Public and Court




 5     Reporter,  hereby certify that the foregoing pages,




 6     numbered 2 through 16 inclusive,  are a true and




 7     accurate transcription to the best of my ability of




 8     the hearing of THE PINE STREET BARGE CANAL PROJECT,




 9     taken before me on the 24th day of June, 1998, at




10     Contois  Auditorium,  City Hall, Burlington, Vermont,




11     in this  matter now pending before the EPA.




12




13          I further certify that I am not related to




14     counsel  nor any party to the case in this matter,




15     nor do,  I  have any interest in the outcome of the




16     case.




17




18




19                        




20




21




22




23




24




25









                    COURT REPORTERS ASSOCIATES

-------
                                              ATTACHMENT B
                       Written Comments Received during the Public Comment Period
                                        June 5 - August 7, 1998



From:       Fred G Hill 
To:         R1CAMAL.  R1WMD (LUMINO-KAREN)
Date:       6/9/98 7:42am
Subject:    Barge Canal Cleanup

Ms Lumino;

       I was a critic of the  initial measures proposed for cleaning up the Burlington (VT)  Barge Canal
area and should therefore  register an opinion about the current, revised plan. Thanks very much for
keeping me on your mailing list and updated with information. The current plan seems guite reasonable,
less drastic and more in keeping with the realities.
Fred G Hill
61-C Church St, Burlington, VT 05401
PO Box 503, Burlington, VT 05402
802-864-4385
hill@lemming.uvm.edu
       Fred G Hill

-------
                    Write your comments below and mail to EPA...

EPA wants your written comments on the options under consideration for dealing the Pine Street
Canal Superfund site. You can use the form below to send written comments. If you have questions about
how to comment, please call EPA Community Involvement Coordinator Sarah White at 617/565-9260 or EPA's
toll free number at comments, postmarked no later than July 8, 1998 to:

              Karen Lumino
              Remedial Project Manager
              U.S. Environmental Protection Agency
              Region 1, HBT
              JFK Federal Building
              Boston, MA 02203-0001
              or E-Mail to: lumino.karen@epamail.epa.gov
              FAX: 617/573-9662
At its meeting of June 25, 1998, the Burlington Planning Commission endorsed in concept the proposed
remediation plan for the Barge Canal site. It is far superior and more cost effective than the 1992
proposal which the Commission unanimously rejected. We are appreciative of the hard work of the members
of the Pine Street Barge Canal Coordinating Council and for EPA's support in allowing this level of
citizen involvement in devising an approriate soluton



From:       John Brabant COHNE.dec.anr.state.vt.us>
To:         R1CANAL R1WMD  (LUMINO-KAREN)
Date:       7/10/98 12:51pm
Subject:    (Fwd) Pine St. Barge Canal Comment - Bioturbation

Ms. Lumino, below is a copy of an email I sent to Stan Corneille at
VTANR...FYI.

	 Forwarded Message Follows 	
From:          "John Brabant" 
To:            Stan Corneille 
Date:          Thu, 9 Jul 1998 17:30:35 -0500
Subjict:       Pine St. Barge Canal Comment - Bioturbation
cc:            Skip Flanders ,
               George Desch ,
               Chuck Schwer 
Bcc:           johnk@anrimsgis,
               Johnb
Priority:      normal

Stan, in followup to our discussion in the hallway a few weeks ago regarding the remediation plan of
the Pine St.  Barge canal project, I am writing you this email so that you can include in the record an
issue that comes to mind. As we discussed, I saw the diagram in the Burlington Free Press and read the
associated article on the cleanup plan. The diagram and text indicated that the contaminated bottom
sediments would be isolated from the environment by virture of a layer of clean sediment (clay, silt??)
being distributed across the canal bottom at a prescribed thickness. My concern is whether the issue of
whether this "fix" took into account the possibility of bioturbation moving the contaminated sediments
the plan hopes to permanently isolate up into and throughout the confining layer. When I did consulting
work on PCB contaminated sediments in the Hudson River, the big discussion up in EPA land was that the
PCB's that were anticipated to have long since been buried under the continuing deposition of river
sediment, were being found on top and throughout the bottom sediments. It was concluded that this was
the result of burrowing organisms such as worms,  clams and the like, continually mixing the sediments
and redistributing the PCB's. This process is what has been termed "bioturbation".  It has caused
serious complications for the Hudson River PCB cleanup and is now a major factor that has to be
addressed in any plan to deal with the PCB contamination problem.

My guestions and comments are as follows:

       1.     Was bioturbation  considered  during the development  of  the cleanup plan??

       2.     If  so, on what  basis was  it  decided that  bioturbation  over the longer term will not be a
             concern??

       3.     If  bioturbation was considered and was considered to be  a concern, what measures  does the
             cleanup plan  contain to address this  concern??

       4.     Have  you  received  the record of other projects where bioturbation was a concern to find
             out what  the  level(s) of  concern should be and how  these concerns were addressed  (or are
             being addressed)  at these other projects?

-------
Would you please include the above comments/concerns with the comments received from the general public
and make sure that the Barge Canal Coordinating Council has a chance to review them. Would you also see
that I am placed on the mailing list for any responses issued to comments received. Thanks.   -John

John Brabant
Environmental Engineer
VT Solid Waste Management Program
vmail-(802)241-3463
email- johnb@dec.anr.state.vt.us
John Brabant
Environmental Engineer
VT Solid Waste Management Program
vmail-(802)241-3463
email- johnb@dec.anr.state.vt.us

-------
                           Linden E. Witherell

                        777 South Prospect Street
                        Burlington. Vermont 05401
                              (802)  862-8284

                              July 8, 1998


FACSIMILIE TRANSMISSION TO 617.573.9662


Karen Lumino
Remedial Project Manager
U.S. Environmental Protection Agency
Region 1 (HBT)
JFK Federal Building
Boston, MA 02203-0001

       Re:  Pine Street Canal Superfund Site

Dear Ms. Lumino:

I am writing to document my concerns regarding the "Cleanup Plan Proposed for Pine Street Barge Canal
Superfund Site Burlington, Vermont."

After reviewing all of the available information, attending meetings of the Pine Street Barge Canal
Coordinating Council, and participating in the public meeting on June 4, 1998, I have the following
concerns:

       •     The plan does  not  result in a cleanup of  the site,  but  rather merely covers-up the
            hazardous material on-site  resulting in continuing serious  ecological and public health
            hazards.
       •     The plan does  not  provide adeguate safeguards to reguire the Potentially Responsible
            Parties (PRPs)  to  take corrective action  if the proposed plan does not work.
       •     There was limited  opportunity for true public input and review before completion of the
            plan.

Concern With Proposed "Cleanup" at the Barge Canal Plan

As proposed, a sand/silt cap would be placed on the manufactured gas plant  (MGP) residue wastes and all
of the contaminants would remain on site. The theory is that the hazardous wastes are not presently in
contact with the environment and present no human health or ecological hazard. Further, the theory is
that the hazardous materials will continue to remain isolated ftom the environment and microorganisms
will, given time, break down the wastes into harmless materials.
Karen Lumino
July 8, 1998
Page 2

I have several concerns with the concept of "covering-up" the problem with a silt/sand cap, rather than
cleaning up the site. First, the volume of wastes resulting from the production of coal gas on the site
is immense. The volume is in excess of 600,000 cubic yards which, at the June 4, 1998 public meeting,
was described as the largest MGP site in the nation. MGP residue wastes are a complex mixture of many
harmful substances including heavy metals, such as lead and mercury, that were in the coal stock and
organic chemicals, such as polycyclic aromatic hydrocarbons (PAHs)  and volatile organic compounds
(VOCs) created during the gasification process.

At the meeting, a representative of Johnson Company  (JOCO), a firm hired by some of the PRPs, estimated
that of the 600,000 cubic yards ca wastes, at least 200,000 cubic yards are PAHs. These compounds are
carcinogenic. Further, it was revealed at the meeting that many VOCs are present in the wastes
including benzene, a known carcinogen and neurotoxin. Unfortunately, there is little information on the
volume of VOCs at the site. When asked about the volume of benzene on site, the JOCO representative
didn't know if there were ounces, guarts, gallons, or thousands of gallons on site.

Not only is there a very large volume of hazardous material at this site, but this material is on the
shore of Lake Champlain. In fact, much of this hazardous material is just under the surface of the
bottom of the Barge Canal inlet of Lake Champlain. This site is upstream of the water supply intake for
the City of Burlington.

The theory that microorganisms will ultimately break this material down to harmless material is also of
concern. How much time is reguired to accomplish this? None of the PRPs technicians at the June 4
meeting knew the answer. It is known that some of the coal tar residual waste has been on site since

-------
1895 and has not broken down into harmless substances yet.

Of greatest concern with the theory of microorganism breakdown is that the exact process of degradation
is not fully known. Further information is needed on the intermediate degradation products (IDPs).  Will
any of the IDPs be less dense than the existing compounds with resulting escape of this material tip
through the silt/sand cap? Will any of the IDPs be more soluble with resultant escape into the water
column? What is the toxicity of the IDPs? The answers to these guestions are needed before reliance is
placed on the theory that a silt/sand cap will contain the wastes and microorganisms will allow the
site to "heal" itself. Unfortunately,  it may not be possible to answer these guestions and future work
along these lines would result in even more resources being wasted.
Karen Lumino
July 8, 1998
Page 3

It would appear that tile safest course of action given the volume of the wastes,  the hazardous nature
of the wastes, and the location of these wastes would be to remove the wastes to a safe site that will
not result in release to the environment. The first ill-conceived attempt for dealing with this site,
the 1992 Plan, envisioned the removal of the wastes with storage on-site which resulted in a continued
threat to public health and the environment. The present ill-conceived plan of leaving the material
on-site under a silt/sand cap is obviously much less costly but it does not result in any less long
term threat to public health and the environment.

Concerns with the lack of adeguate safeguards to reguire the PRPs to take corrective action if the
proposed plan does not work.

For the reasons stated above, there are serious guestions about the long-term threat presented to the
public health and environment by the present "cleanup" plan. I have concerns about the adeguacy of
funds for long term monitoring of the site and corrective action if the proposed solution doesn't work.

As I understand the 1998 Plan, monitoring of the site is for only 30 years. However, there is no
estimate of how long it will take for the site to "heal" itself through microorganisms breaking down
the wastes. It certainly appears that wastes deposited at the site as early as 1895 still remain
hazardous. It may take centuries, not decades, for the site to "heal" itself. If the 1998 Plan is
accepted, the PRPs should be reguited to provide funds for the monitoring for a period egual to the
time estimated for the site to fully "heal" itself.

If the theory that a silt/sand cap will contain the wastes while microorganisms provide natural
"healing" doesn't work, corrective action such as removal of the wastes to a safe site will be
needed. Because of the long-term nature of the concept of natural "healing", recognizable failure may
not occur for decades or longer. The time period for recognition of failure becomes very apparent when
one considers that it took from 1995 (when the MGP began operation)  until the late 1980s until it was
recognized that "natural" on-site disposal of wastes was a failure.

Not only must one consider the long-term aspect of recognition of the failure, if it occurs, but
attention must also be given to the long-term economic viability of the private PRPs. One of the
largest PRPs, an electric power company, faces serious economic uncertainty with energy deregulation.
Another large PRP, a defense contractor, faces serious economic uncertainty and has undergone so many
reorganizations in recent years that most don't even know its current name.

In view of the long term nature of recognition of failure, if it occurs, of the 1998 Plan and the
uncertainty of the long term viability of some, if not all, of the private PRPs, bonding for future
corrective action, if reguired, should be reguired from the private PRPs at this time. Why should
taxpayers pay for cleanup in the future if failure does occur and the private PRPs no longer exist?
Karen Lumino
July 8, 199S
Page 4

It would be irresponsible for EPA to accept a "cleanup" plan with as much uncertainty and risk as the
1998 Plan without allocating the risk to the private PRPs by reguiring bonding at this time. It is
understood that bonding is not routinely reguired but this is an "innovative" plan and the reguirement
for bonding should be thought of as an innovative concept of allocating future risk. In any event, if
the plan is as good as has been proclaimed by the PRPs and their consultants, the cost of bonding
should be very reasonable.

Concern about limited public input into the 1998 Plan

In spite of the wide spread favorable publicity from the EPA concerning the Pine Street Barge Canal
Coordinating Council, there were several possible problems with this approach.

True public input by means of the Council was very limited. Membership on the Coordinating Council was
restricted. There was no public announcement by EPA calling for volunteers to serve on the Council. It
appears that membership on the Council was by invitation only.

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The majority of members on the Council were PRPs. Some of the Council members, such as the City of
Burlington and the State of Vermont, which would appear to represent the public,  were in fact PRPs.
Unfortunately, the PRPs had an inherent conflict of interest because of possible concern about the
costs of clean-up.

In addition to limiting the costs of clean up, there were other conflicts of interest with some of the
Council members. At the June 4th public meeting, the City of Burlington's representative seemed most
interested in getting increased development at the site.

The effectiveness of the Council was also limited because of the limited technical resources of the
non-PRP members. In a conversation with John Akey, he mentioned that the non-PRP members were almost
totally dependent on the information provided by the consultants hired by the PRPS. For example, John
said alternatives such as cold weather removal of the wastes to lessen the escape of VOC's and rail
transportation for removal of the wastes were not even introduced.

Another limitation uf ihe Council was the adoption of a consensus process for development of the 1998
Plan. The consensus process can result in solutions, which represent the lowest common denominator. In
addition, a consensus process is very time consuming and can result in wearing participants down.

Although the meetings of the Council were open to the public, public input was not encouraged. I
attended several meetings of the Council and found them to be extremely bureaucratic. There was little
opportunity to find out what was planned and even less opportunity to participate. It was as if the
Council was a club and outsiders could come and observe, but not participate, in the activities of the
club
Karen Lumino
July 8, 1998
Page 5

Unfortunately, the EPA has provided limited public input into this matter. It almost seems that EPA,
after spending years on this project, is now trying to rush the project to completion. I feel that the
June 4, 1998 public information meeting was the first real opportunity for the public to find out what
was planned. However, that public meeting, plus the formal hearing on June 24, have not allowed
sufficient time for true public input into this process.

In summary, I urge the EPA to:

       •     Carefully review the proposed containment by silt/sand cap with natural "healing" concept
            put forth in the 1998 Plan,
       •     Reguire a monitoring period consistent with the time necessary for the site to be rendered
            harmless by natural "healing",  if the  1998 Plan is  accepted by EPA,,
       •     Reguire the private PRPs to provide a  construction  bond at this time  to cover the costs  for
            removal and proper disposal of the wastes if failure occurs during the projected "healing"
            period, if the 1998 Plan is accepted by EPA,  and
       •     Allow for true public input by increasing the time  for public comments.

Please feel free to contact me if you have any guestions.




       WHEREAS,  the site known as the Barge Canal  in the City's South End has been contaminated by
industrial waste,  resulting in its designation by tile Environmental Protection Agency of the United
States of America  (EPA) as a hazardous waste site, and

       WHEREAS,  the site is close to neighborhoods and some of  the City's most utilized recreational
facilities, namely, the Bike Path and Oakledge Park, and

       WHEREAS,  the restoration of the Barge Canal lands is a fundamental part of the long-term
Waterfront usage plan, and

       WHEREAS,  the Barge Canal Coordinating Council,  which includes members of the community
representatives of tile Lake Champlain Committee and the Pine Street Arts and Business Association the
City of Burlington the EPA the Vermont Agency of Natural Resources, and the various corporations who
have operated varied industries on the site known as the Barge  Canal in the City's South End have
agreed in principal to a settlement which ensures  the safe containment of the environmental
contamination in a fiscally responsible way, and
Page   2

Resolution Relating to
                          BARGE CANAL RESRORATION

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      WHEREAS, the Barge Canal Coordinating Council endorses the proposed settlement

agreement;

      NOW THEREFORE BE IT RESOLVED that the City Council of Burlington urges

the EPA to accept this settlement as best for the community and the City.

      AND BE IT FURTHER RESOLVED that the City of Burlington urges the EPA to

begin work on the agreed-upon containment strategy as guickly as possible.

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