SIXTH FIVE-YEAR REVIEW REPORT FOR
BFI SANITARY LANDFILL (ROCKINGHAM) SUPERFUND SITE
ROCKINGHAM, VERMONT
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Prepared by
U.S. Environmental Protection Agency
Region I
Boston, Massachusetts
DDVAKI Digitally signed by BRYAN
dKYAIM OLSON
OLSON _Dateo2024.09.302,:2,:26
Bryan Olson, Director Date
Superfund Emergency Management Division
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Table of Contents
LIST OF ABBREVIATIONS & ACRONYMS ii
I. INTRODUCTION 1
Site Background 1
FIVE-YEAR REVIEW SUMMARY FORM 2
II. RESPONSE ACTION SUMMARY 3
Basis for Taking Action 3
Response Actions 3
Status of Implementation 5
IC Summary Table 6
Systems Operations/Operation & Maintenance 7
III. PROGRESS SINCE THE LAST REVIEW 8
IV. FIVE-YEAR REVIEW PROCESS 9
Community Notification, Involvement & Site Interviews 9
Data Review 9
Summary of the Spring 2023 SYR Monitoring Event Results 9
ROD Contaminants of Concern 10
1,4-Dioxane and Per- and Polyfluoroalkyl Substances (PFAS) Monitoring 11
Extent of Contamination 13
Site Inspection 13
V. TECHNICAL ASSESSMENT 14
QUESTION A: Is the remedy functioning as intended by the decision documents9 14
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy selection still valid9 15
QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy9 20
VI. ISSUES/RECOMMENDATIONS 21
OTHER FINDINGS 21
VII. PROTECTIVENESS STATEMENT 22
VIII. NEXT REVIEW 22
APPENDIX A - REFERENCE LIST
APPENDIX B - FIGURES
APPENDIX C - DATA TABLES
APPENDIX D - SITE BACKGROUND
APPENDIX E - CHRONOLOGY
APPENDIX F - PUBLIC NOTICE PRESS RELEASE
APPENDIX G - INTERVIEW SUMMARY
APPENDIX H - SITE INSPECTION CHECKLIST
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LIST OF ABBREVIATIONS & ACRONYMS
ARAR Applicable or Relevant and Appropriate Requirement
AST Aboveground Storage Tank
BFI-VT BFI Vermont
CD Consent Decree
CERCLA Comprehensive Environmental Response. Compensation, and Liability Act, 42 U.S.C.
9601 et seq.
CFR Code of Federal Regulations
COCs Contaminant of Concern
DSI Disposal Specialists. Inc.
EPA United States Environmental Protection Agency
ESD Explanation of Significant Differences
FYR Five-Year Review
ICs Institutional Controls
IGCL Interim Groundwater Cleanup Levels
I RULE Investigation and Remediation of Contaminated Properties Rule
LTMP Long term monitoring plan
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goal
NCP National Oil and Hazardous Substances Pollution Contingency Plan. 40 C.F.R. Part 300
ND Non-detect
NPL National Priorities List
NTCRA Non-Time Critical Removal Action
O&M Operation and Maintenance
PFAS Per- and Polyfluoroalkyl Substances
PFHpA Perfluoroheptanoic acid
PFHxS Perfluorohexanesulfonic acid
PFNA Perfluorononanoic acid
PFOA Perfluoroctanoic acid
PFOS Perfluorooctajie sulfonic acid
PRP Potentially Responsible Party
QAPP Quality Assurance Project Plan
RAO Remedial Action Objective
ROD Record of Decision
RPM Remedial Project Manager
SDWA Safe Drinking Water Act
SOW Statement of Work
TBC To be Considered
TSA Technical Services Assessment
UST Underground Storage Tank
UU/UE Unlimited Use/Unrestricted Exposure
VGES Vermont Groundwater Quality Enforcement Standards
VTANR Vermont Agency of Natural resources
VTDEC Vermont Department of Environmental Conservation
VI Vapor Intrusion
VOC Volatile Organic Compound
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Units of Measure
mg/L Milligrams per liter (equals ppm)
|ig/L Micrograms per liter (equals ppb)
ng/L Nanograms per liter (equals ppt)
ppm parts per million
ppb parts per billion
ppt parts per trillion
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I. INTRODUCTION
The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy
in order to determine if the remedy is and will continue to be protective of human health and the
environment. The methods, findings, and conclusions of reviews are documented in five-year review
reports such as this one. In addition, FYR reports identify issues found during the review, if any, and
document recommendations to address them.
The U.S. Environmental Protection Agency (EPA) is preparing this five-year review pursuant to the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121,
consistent with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP)(40 Code
of Federal Regulations (CFR) Section 300.430(f)(4)(ii)), and considering EPA policy.
This is the sixth FYR for the BFI Sanitary Landfill (Rockingham) Superfund Site (BFI Rockingham). The
triggering action for this statutory review is the September 2019 completion date of the previous (fifth)
FYR. The FYR has been prepared because hazardous substances, pollutants, or contaminants remain at
the Site above levels that allow for unlimited use and unrestricted exposure (UU/UE). The Site consists
of one Operable Unit, which is addressed in this FYR.
The BFI Rockingham Landfill Superfund Site Sixth Five-Year Review was led by Kevin Heine, EPA
Region 1 Remedial Project Manager (RPM). Other Region 1 participants included Courtney Carroll, risk
assessor, and Sarah Meeks, attorney; and Grahame Bradley, Vermont Department of Environmental
Conservation (VTDEC) site manager. Documents reviewed in support of this FYR are listed in Appendix
A. Figures are presented in Appendix B and tables in Appendix C.
The review commenced on February 29, 2024 with a FYR kickoff meeting held on that date.
Site Background
BFI Rockingham (the "Site"), also formerly known as the Disposal Specialists, Inc. (DS1) Landfill and
the BFI Sanitary Landfill, is located along U.S. Route 5, locally identified as Missing Link Road, in the
Town of Rockingham, Windham County, Vermont as shown on Figure 1, Appendix B. The 17-acre solid
waste landfill is located within a 120-acre parcel owned by BFI Waste Systems of North America, LLC.
The landfill is located approximately 500 feet west of and 200 feet higher than the nearby Connecticut
River. Abutting the landfill to the south and east is an approximately 12-acre area of the Site that includes
the former operations and hauling facility (office building, garage, former solid waste transfer area and
now vacant former facility manager's house), the landfill gas management system; and all or parts of six
parcels located east of Missing Link Road, four of which have residences on them, as shown on Figure 2,
Appendix B.
The landfill is situated on a glacial terrace located along the west side of the Connecticut River. Geological
cross section figures prepared as part of the Rl/FS are included in Appendix D, Site Background, and are
labeled as Figures 3 and 4. The majority of the waste within the landfill is underlain by a relatively thin
layer of sand deposits overlying varved lacustrine deposits comprised of interbedded clay and silt. The
lacustrine deposits and bedrock are generally separated by a sandy glacial till unit. Overburden is
approximately 200 feet thick on the southeast side of the landfill, with little or no overburden present on
the northwest side of the landfill. Bedrock under the Site consists of moderately fractured black and gray
phyllite and slate of the Littleton Formation. Overburden and bedrock groundwater flows are primarily
east to southeast from upland areas of the Site to the Connecticut River.
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BFI Rockingham was placed on the National Priorities List (NPL) in 1989. Refer to Appendix D for
additional Site background information and Appendix E for a more complete Site chronology.
FIVE-YEAR REV IEW SUMMARY FORM
SITE IDKM II IC A I ION
Site Name: BFI Sanitary Landfill (Rockingham) Supcrfund Site
EPA ID:
VTD980520092
Region: 1
State: VT
City/County: Rockingham / Windham
NPL Status: Final
Multiple OUs?
No
I
Has the site achieved construction completion?
Yes
Lead agency: EPA
Author name (Federal or State Project Manager): Kevin Heine
Author affiliation: EPA Region 1
Review period: 2/9/2024 - 9/30/2024
Date of site inspection: 6/12/2024
Type of rev iew: Statutory
Review number: 6
Triggering action date: 9/30/2019
Due date (fiveyears after triggering action date): 9/30/2024
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II. Response action summary
Basis for Taking Action
The Remedial Investigation (RI), conducted from 1992 to 1994 by DSI and BFI Vermont (BFI-VT), the
two Potentially Responsible Parties (PRPs), identified the landfill as the source of contamination found in
bedrock and overburden groundwater at the Site. Surface water in drainage ditches along Route 5 was
found to also contain Site-related contaminants.
The information collected during the Remedial Investigation and Feasibility Study (Rl/FS) was used by
EPA to conduct Human Health and Ecological Risk Assessments. The results indicated that an
unacceptable carcinogenic and noncarcinogenic risk would result from ingestion of groundwater in
bedrock. This was a hypothetical exposure scenario since no individuals were ingesting contaminated
groundwater at the Site due to the provision of an alternate water supply. The carcinogenic risk results
primarily from arsenic and vinyl chloride. Arsenic and manganese represented the majority of the non-
carcinogenic risk at the Site under both average and maximum exposure scenarios. Constituents that
exceeded a Federal Safe Drinking Water Act maximum contaminant level (MCL) or maximum
contaminant level goal (MCLG) in bedrock groundwater during RI sampling include: antimony, arsenic,
barium, benzene, bis (2-ethylhexyl) phthalate, chromium, nickel, pentachlorophenol, tetrachloroethylene,
trichloroethene, and vinyl chloride. In addition to these substances, exceedances of the State of Vermont
groundwater standards for 2-butanone, lead and xylene were also reported. Interim groundwater cleanup
levels (IGCLs) were established for contaminants of concern (COC) identified in the baseline risk
assessment found to pose an unacceptable risk to either public health or the environment. These include
the aforementioned 14 COCs, plus trichloroethylene, tetrachloroethene, bis (2-chloroisopropyl) ether,
methylene chloride, and manganese.
Based on the Ecological Risk Assessment and further sampling results as discussed in the ROD, EPA
concluded that adverse effects on the Connecticut River were not likely.
Response Actions
As a result of neighbor complaints and subsequent state sampling of six bedrock water supply wells
located in the vicinity of the Site in 1979, the State of Vermont required the operator, DSI, to provide
residences located east of the landfill with bottled water for potable use. In 1980, a new water supply well
was installed, and a distribution system was constructed to serve residents previously supplied with bottled
water. Subsequent bedrock water supply wells #2 and #3 were later installed for the water supply system
in 1987 and 1994. Well #2 is an open bedrock well from 1 18 to 400-feet below ground surface and well
#3 is an open bedrock well from 160 to 700-feet below ground surface. DSI entered into an agreement to
continue to supply off-site residences until EPA and VTDEC determine that the water beneath the
residences is acceptable for use as a water supply.
Two CERCLA cleanup actions have been implemented at the Site. The first was a Non-Time Critical
Removal Action (NTCRA) that was specified in a 1993 Action Memorandum. The NTCRA included
construction of the multilayer landfill cap, expansion of the existing landfill gas management system,
institutional controls (ICs) to protect the landfill cap, and operation and maintenance of the Route 5 Slope
Stabilization and Seepage Control System (Route 5 System). The Route 5 System consists of a shallow
overburden groundwater collection trench. The trench is bounded by sheet piling and was designed to
intercept a limited area of impacted overburden groundwater that historically discharged at the top of
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ravines located adjacent to Route 5 (a.k.a., Missing Link Road). Intercepted water is collected in an
aboveground storage tank (AST) for offsite treatment and disposal.
The multilayer landfill cap was constructed with a slope of 3:1 and includes: a gas vent layer, a compacted
low permeability native soil layer, a very low density, polyethylene geomembrane, a storm water drainage
tire chip layer, vegetative support soil and topsoil. Construction of the NTCRA action was completed in
July 1995 and EPA certified the Completion of Work Report in September 1996.
The second cleanup action, described in the 1994 Record of Decision (ROD), selected the natural
attenuation of groundwater, continued maintenance of the components implemented as part of the
NTCRA, long-term monitoring, and maintenance of ICs as the long-term cleanup approach at the Site.
Maintenance of ICs included preventing future use of the landfill that would damage the multilayer cap,
preventing groundwater use throughout the area of Site-related contamination, and providing a water
supply to residents with Site-related contaminated groundwater beneath their residences.
The ROD established the following remedial action objectives (RAOs).
Landfill (Source Area) Remedial Objectives:
Prevent, to the extent practicable, the potential for water to contact or infiltrate through the debris
mass;
Prevent, to the extent practicable, the generation of landfill seeps and the migration of landfill-
impacted surface water into the Connecticut River;
Control landfill gas emissions so methane gas does not present an explosion hazard; prevent, to
the extent practicable, the inhalation of landfill gas containing hazardous substance, pollutants, or
contaminants; and meet state and federal air standards;
Prevent, to the extent practicable, the migration of contaminated groundwater beyond the points
of compliance by controlling the source area;
Minimize the potential for slope failure of the debris mass associated with the multi-layer landfill
cap or any further action; and
Prevent, to the extent practicable, direct contact with and ingestion of debris within the landfill and
beneath the landfill.
Groundwater Remedial Objectives:
Prevent, to the extent practicable, the ingestion of landfill-impacted bedrock groundwater
exceeding EPA Safe Drinking Water Act MCLs, MCLGs, Vermont Primary Groundwater Quality
Standards, or in their absence, the more stringent of an excess cancer risk of lxlO"6 for each
compound or a hazard quotient of 1 for each non-carcinogenic compound by an individual who
may use the bedrock groundwater within the area of landfill-impacted groundwater or within an
area that could become impacted as a result of pumping activities; and
Restore the bedrock groundwater at the edge of the Waste Management Unit (solid waste boundary
shown on Figure 2) to: MCLs, MCLGs, Vermont Primary Groundwater Quality Standards, or in
their absence, the more stringent of an excess cancer risk of lxlO"6 for each compound or hazard
quotient of 1 for each non-carcinogenic compound.
Surface Water (Ecological) Remedial Objectives:
Protect off-site surface water by preventing the occurrence of landfill impacted seeps;
Meet federal and state ARARs for any surface-water discharge to the Connecticut River; and,
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Provide long-term monitoring of the surface water and sediments of the section of the Connecticut
River adjacent to the landfill to assure that no landfill-related impacts occur in the future.
Status of Implementation
The design of the NTCRA was initiated in October 1993 and completed in July 1994. The expansion of
the landfill gas extraction system and Site preparation activities were completed in May 1994. The multi-
layer landfill cap was completed in July 1995. Surface water (stormwater) control systems were completed
by August 1995 and a vegetative cover was established by October 1995.
EPA, VTDEC and the oversight contractor performed a final inspection in May 1996 and the cap and all
related appurtenances were determined to be constructed according to design, with a well-established
vegetative cover. The construction activities and completion were documented in a Completion of Work
Report that was approved by EPA in September 1996. The report documented the completion of the
NTCRA and the initiation of Post-Rem oval Site Control / Operation and Maintenance (O&M) by the
PRPs.
In 1996, DSL and BF1-VT entered into a Consent Decree (CD) (Civil Action #2:96-CV-309) with EPA to
perform the remedial actions required under the ROD. The remedy memorialized in the 1994 ROD
identified Monitored Natural Attenuation (MNA) for groundwater, ICs, and maintenance of the NTCRA
components.
The ROD anticipated that Interim Groundwater Cleanup Levels (IGCLs) would be achieved 15 years after
completion of the NTCRA. Due to the limited extent and low yield, overburden groundwater was not
considered to be a potential drinking water source or a current or future human exposure pathway;
therefore, IGCLs were not established for overburden groundwater. Long-term monitoring results did
show significant improvements in bedrock groundwater and surface water quality following construction
of the NTCRA. However, by 2008, long-term monitoring results indicated IGCLs for benzene, total
xylenes, tetrachloroethene, methylene chloride, 2-butanone, vinyl chloride, arsenic, manganese, barium
and chromium may not be met for bedrock groundwater at some locations within the timeframe estimated
in the ROD. Further, EPA and BF1-VT jointly concluded that meeting arsenic and manganese IGCLs
would be problematic due to the naturally occurring presence of these metals in bedrock fractures.
Accordingly, field investigation activities were performed and the long-term monitoring plan (LTMP) was
modified in 2009 and 2010 in consideration of a Technical Impracticability (Tl) evaluation. Based on the
completed evaluation, EPA determined that a TI waiver was not the preferred method of addressing the
ROD requirement for groundwater restoration in the bedrock aquifer. An Investigation Plan (Summit
2012) was subsequently prepared that identified additional actions necessary to ensure the continued
protection of human health and the environment. EPA issued an approval of the Investigation Plan in a
letter dated February 16, 2012.
The additional actions implemented as per the Investigation Plan are summarized below:
The Conceptual Site Model (CSM) was updated (Summit 2012c).
Potential vapor intrusion pathways related to structures located downgradient of the landfill
(Summit 2012d, 2014b) were evaluated.
Binding Water Supply Agreements between BF1-VT and downgradient property owners were
recorded on property deeds (require BF1-VT to supply potable water to downgradient landowners
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and to operate and maintain the water supply system until the EPA and VTDEC determine
groundwater restoration has been completed, as per the ROD) (Summit 2014b).
Confirmed that the existing water supply system (formally identified as the Missing Link Road
Water Supply System) installed to serve downgradient residences substantially meets existing
codes for public water lines. The system is classified as a Non-Public Water System that does not
require a state permit due to the limited number of users and connections. However, the EPA
requested verification that the water supply system substantially meets current state and federal
requirements for use as a public, multi-user supply system.
The Groundwater Reclassification Zone boundary, originally defined in 2009, was amended by
VTANR in 2013 to expand the boundary northward to include two additional properties due to
inaccurate survey coordinates utilized for the 2009 reclassification. The zone prevents
groundwater use throughout the area of Site-related contamination, as required by the ROD.
The groundwater quality monitoring program was reviewed to determine what monitoring was
needed until cleanup criteria are met and the LTMP was subsequently updated, with a revised
monitoring program that commenced in 2015.
An Explanation of Significant Differences (ESD) for the Site was completed in September 2014. The ESD
addressed why the bedrock groundwater cleanup at the site had not met the IGCLs established in the ROD
(see Appendix D, Table A-1) and revised the timeframe for the restoration of bedrock groundwater
(excluding VOCs) to between 2050 and 2070, and achievement of the IGCLs established in the ROD for
VOCs by 2025. It also revised the IGCLs for arsenic and lead because of changes in federal and state
standards for those chemicals and it documented the implementation of the additional ICs at the Site.
In August 2017, the enclosed flare component of the landfill gas extraction system was replaced with a
smaller candlestick flare. Because a candlestick flare requires less landfill gas to burn than an enclosed
flare, the landfill gas extraction system now operates more continuously and efficiently and provides better
long-term control of landfill gas and odors.
There have been no new remedial activities implemented at the Site since the 2019 FYR.
Institutional Controls:
ICs are required at the Site to ensure the protectiveness of the remedy and were identified as a remedy
component in the ROD. The restrictions required by the ICs appear to be in full force and effect as
determined by the IC evaluation activities discussed below. No further ICs or changes to the current ICs
are recommended at this time.
IC Summary Table
Table 1: Summary of Planned and/or Implemented ICs
Media, engineered
controls, and areas that do
not support IJU/UE based
on current conditions
ICs
Needed
ICs Called
for in the
Decision
Documents
Impacted
Parcel(s)
IC
Objective
Title of IC
Instrument
Implemented and
Date (or planned)
Groundwater
Yes
Yes
PRP-owned
Parcels:
4-505-894,
4-505-890,
4-107-032.
Rights of access
and groundwater
use restriction
Grant of
Environmental
Restrictions &
Right of Access.
June 1996
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PRP-owned
Parcels:
4-505-894,
Reclassified
4-505-890,
groundwater from
VTANR
4-107-032.
Class III to Class
Reclassification
Groundwater
Yes
Yes
Parcels owned
IV. prohibiting
Order (March 10,
by others:
future public water
2009, amended
4-107-014,
supply
November 6.
4-505-897,
development and
2013)
4-107-012,
use
4-107-010,
4-107-006.
Systems Operations/Operation & Maintenance
Operation, maintenance and monitoring activities are currently being implemented by the PRPs.
Monitoring reports are submitted at least annually to EPA and VTDEC for review, depending on the
frequency of sampling events. The Site is typically visited weekly by the PRP or their agents and is
inspected by EPA and VTDEC annually. The operation, maintenance and monitoring activities focus on:
Inspecting the vegetative cover of the cap and repair of any erosion;
Balancing the landfill gas extraction system and repair of any wells or conveyance lines;
Shipping leachate to an off-site treatment facility;
Collecting samples to monitor the restoration of groundwater; and
Providing potable water to four properties on River Front Drive and maintaining the water line and
system.
Routine operation and maintenance activities conducted during the most recent five-year review period
included regular operation and monitoring of the private water line system used to provide off-site
properties with drinking water; and regular operation and monitoring of the landfill gas management
system. Route 5 Seepage Control and Stabilization System, and the leachate collection system. Ongoing
maintenance of the landfill cap includes mowing and removal of vegetation from the storm water runoff
ditches and let down drainage features.
In addition, the following O&M activities were undertaken:
In 2019, the PRP proposed decommissioning several gas extraction wells that were ineffective in
extracting landfill gas and would not impact the capture of the gas collection system which can be
handled by the remaining gas extraction wells. Decommissioning occurred in 2019.
In 2020, the PRP relocated portions of the Missing Link Water Supply System from the former
Greenwood residence located on an adjacent parcel south of the landfill parcel to a more secure
location within the fenced portion of the Site, where a structure was built to house the treatment
system and water supply controls. The residential water system supply line was routed directly
from the new building to a point outside the front gate, thus eliminating the need for portions of
the system to be located on the less secure Greenwood lot.
In 2021, the PRP removed trees along the fence near the AST. Additionally, the motor that operates
the Site gate was replaced.
In 2022, the PRP replaced the above ground storage tank heater.
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In 2023, the PRP replaced the site gate operator. Additionally, a propane supplied automatic
generator was installed to operate the Missing Link Water Supply System and the Route 5
groundwater interceptor system.
In 2023, the PRP performed repairs to a leak in the Missing Link Water Supply System that was
identified on River Road.
In 2024, additional gas extraction wells identified as ineffective in extracting landfill gas were
decommissioned.
III. PROGRESS SINCE THE LAST REVIEW
This section includes the protectiveness determinations and statements from the last five-year review as
well as the recommendations from the last five-year review and the status of those recommendations.
Table 2: Protectiveness Determinations/Statements from the 2019 FYR
ou#
Protectiveness Determination
Protectiveness Statement
1 (Site Wide)
Short-term Protective
The remedy currently protects human health and the environment
because there is no current exposure to Site related contaminants to
humans or the environment at concentrations that would represent an
unacceptable risk. Existing protective measures and conditions at the
Site, including the landfill cap. the landfill gas collection system, the
private water supply system, and ICs. coupled with continued
maintenance activities and regular oversight inspections and
monitoring, help ensure that the remedy remains effective and
protective of human health and the environment.
However, in order for the remedy to be protective in the long term, the
long-term monitoring plan needs to be revised to include routine
monitoring for 1.4-dioxane and PFAS. including in samples collected
from the primary and backup drinking water supply wells for the
Missing Link Road Water Supply System, and from leachate.
Table 3: Status of Recommendations from the 2019 FYR
OU#
Issue
Recommendations
Current
Status
Current Implementation
Status Description
Completion
Date (if
applicable)
1
(Site
Wide)
1.4-dioxane
and PFAS
were
detected in
groundwater
monitoring
samples
collected
from the
Site.
Revise the LTMP to include routine
monitoring for 1.4-dioxane and
PFAS. including 1.4-dioxane and
PFAS sampling of the primary and
backup drinking water supply wells
for the Missing Link Road Water
Supply System, and 1.4-dioxane and
PFAS sampling of leachate.
Completed
Commencing November 2019,
routine monitoring has
included 1.4-dioxane and
PFAS for the primary and
backup drinking water supply
wells for the Missing l ink
Road Water Supply System,
leachate. and monitoring
wells.
11/1/2019
The results of the 1,4-dioxane and PFAS monitoring completed since November 2019 have been evaluated
in the annual reports and are summarized in the Data Review section below. The primary and backup
drinking water supply wells have not detected either 1,4-dioxane or PFAS since monitoring began. Both
1,4-dioxane and PFAS have been detected in the leachate samples and in select monitoring wells.
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IV. FIVE-YEAR REVIEW PROCESS
Community Notification. Involvement & Site Interviews
EPA issued an online news release in February 2024 to announce that the FYR was underway. A copy of
the news release is available in Appendix F. The results of the review and the report will be made available
at EPA's site profile page at www.epa.gov/superfutid/bfi.
During the FYR process, interviews were conducted to document any perceived problems or successes
with the remedy that has been implemented to date. The results of these interviews are summarized below.
Appendix G includes the completed interview forms.
A local resident connected to the Missing Link Water Supply System was interviewed as part of the FYR.
The resident reported being well informed about the Site's activities and progress but requested an
additional point of contact for water supply issues that could arise.
A longtime resident and past president of the Hit or Miss Club, an abutter to the Site, was not aware of
the periodic monitoring (once every four years) of the club's water supply well. EPA confirmed that the
responsible party or its agent provides monitoring data for the Hit or Miss water supply well to the club
and discusses results with members when requested.
Rockingham Town Manager, Scott Pickup, was also interviewed. Mr. Pickup considers himself informed
regarding the Site and is not aware of any current problems or possible future issues with the Site.
Data Review
A long-term monitoring program is being implemented at the Site to monitor the remedy for natural
attenuation of contaminants present since the ROD was signed in 1994. Environmental monitoring data
are available for overburden and bedrock groundwater, shallow overburden groundwater collected by the
Route 5 System groundwater collection trench, a surface seep (Seep SW-6) located along Route 5, the
landfill cap tire chip drainage layer, Connecticut River surface water, and landfill leachate. Monitoring
data is collected as per the frequencies specified in the Long-Term Monitoring Plan (LTMP). The
comprehensive Fall 2023 Monitoring Report presents a summary of historical data through 2023.
Summary of the 2023 FYR Monitoring Event Results
The majority of the 2023 FYR annual sampling event was completed from November 13 - 17, 2023, with
additional long-term monitoring events previously completed during the spring of 2023. Monitoring
included the sampling or attempted sampling of: overburden and bedrock monitoring wells (9 overburden
wells and 19 bedrock wells), the tire chip drainage layer. Seep SW-6, the Route 5 Shallow Groundwater
Collection System (and AST), the lined ash monofill leachate collection system (consisting of an
underground storage tank (UST)) and four water supply wells (the Missing Link Road Water Supply
System primary and backup wells, the Hit or Miss Club supply well, and one local (non-impacted, non-
Site well) residential well for background data (Mxxxxy) [Note: residential wells are partially and
intentionally obscured to provide privacy]. One overburden well (MW-B 13) and Seep SW-6 could not be
sampled due to insufficient water. Sampling activities for the sampling event followed an EPA-approved
Site-Specific Quality Assurance Project Plan (QAPP, HW 2023).
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ROD Contaminants of Concern
The COC arsenic was detected in one (Pxxxxr) of the eight offsite residential wells sampled on a rotating
basis during the 2020-2024 FYR period at a concentration of 1 1.8 (.ig/L in November 2022, marginally
above the IGCL of 10 ug/L. Arsenic has historically been detected in seven of the eight offsite residential
wells that are monitored on a rotating basis according to the LTMP. All offsite residential wells are in
locations around the Site that are not hydraulically downgradient of the landfill and thus provide
background levels for the area.
COCs detected in the Missing Link Road Water Supply System above the IGCL (prior to treatment) during
the 2020-2024 FYR period include arsenic and lead. The system's Primary Well #2 has been the sole
source of water delivered to the residences along Riverview Drive and no exceedances have occurred in
the water after treatment. Backup Well #3 has had detections of arsenic and lead, as further described
below. While this well has not been used as a water supply well, it is regularly monitored along with
Primary Well #2 in case it is temporarily needed, and treatment systems are in place for use as needed to
address possible exceedances for metals as described below.
Water sourced from Primary Well #2 is filtered at the wellhead prior to distribution to the water supply
system and residents. Backup Well #3 has an arsenic reduction system that treats groundwater sourced
from it prior to distribution. Pre- and post-treatment samples collected from Primary Well # 2 were below
the applicable drinking water standards during the FYR period. Untreated water from the Backup Well #3
was above the 10 (.ig/L IGCL for arsenic during the FYR period as follows: 73.6 ug/L in May 2021, 44.4
|.ig/L in October 2021, 16.2 |ig/L in May 2022, 29.4 (.ig/L in November 2022, 38.7 ug/L in May 2023, and
23.9 |.ig/L in November 2023. In addition, untreated water from Backup Well #3 was above the 15 (.ig/L
IGCL for lead at 27.4 (.ig/L in May 2022, and 20.9 (.ig/L in November 2022. Historical data for the Missing
Link Supply Wells, including sampling from this FYR period, is summarized in Table 8, Appendix C.
Data from the Fall 2023 FYR monitoring event is summarized in Table 4, Appendix C to present
exceedances of the IGCLs in groundwater collected from the 27 overburden and bedrock monitoring wells
sampled. Concentrations of certain COCs in samples from overburden and bedrock monitoring wells
exceed one or more IGCLs established in the ROD for bedrock groundwater and/or the current
State/Federal groundwater standards. The primary COCs observed in the Fall 2023 sampling event are
arsenic (7 of 27 wells), chromium (2 of 27 wells), lead (11 of 27 wells), and manganese (12 of 27 wells).
VOCs exceeding the IGCLs are found in 3 of 27 wells and all three wells are overburden wells. As
previously noted, bedrock wells are the wells used to measure compliance with the ROD. VOCs detected
above the IGCL in Fall 2023 were 2-butanone, vinyl chloride, and total xylenes. Over the 5-year review
period (2020-2024), concentrations of COCs nickel and tetrachloroethane have only been detected above
IGCLs in select wells intermittently.
Four bedrock wells were sampled for SVOCs as part of the FYR. Concentrations of SVOCs did not exceed
IGCLs in any of the samples collected. It was also noted that the current detection limit for bis (2-
chloroisopropyl) ether and pentachl orophenol is above the 1 (.ig/L IGCL. The current lowest achievable
detection limit by the contract lab for the compounds meets the requirement listed in the Remedial Action
Statement of Work (SOW) contained in the Consent Decree (the SOW requires the detection limit to be
below 5 ug/L). However, because this detection limit does not allow for the detection of bis (2-
chloroisopropyl) ether and pentachl orophenol down to the 1 ug/L IGCL, a future modification to the SOW
or related work plan may be necessary. In addition, the detection limit for bis(2-ethylhexyl) phthalate in
the sample collected from MW-J38 is above the 6 (.ig/L IGCL. The current lowest achievable detection
limit offered by contracted laboratories for the compound does not meet the requirement listed in the
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Remedial Action Statement of Work (SOW) contained in the Consent Decree (the SOW requires the
detection limit to be below 5 ug/L); therefore, a future modification to the SOW or related work plan may
be necessary unless lower laboratory detection limits become available.
A statistical analysis was performed by contractors to the PRP to evaluate trends in COCs in groundwater
that exceeded IGCLs in 2023. Statistical trends were prepared and evaluated using the non-parametric
Mann-Kendall test, which is only performed for parameters with more than five data points with detections
above the laboratory reporting limit. Time series plots were visually interpreted to verify more recent
trends in the data. The visual evaluation may be useful for situations where a contaminant statistically has
no trend, or where a contaminant may have peaked and is presently declining over a period of several
years. A Mann-Kendall analysis utilizes the entire data set. It does not differentiate individual time periods.
As a result, shorter periods of time may be visually interpreted to provide a complimentary tool to Mann-
Kendall analysis. A summary of the 2023 well concentrations exceeding IGCLs and the trend summary
is included in Tables 5 (bedrock) and Table 6 (overburden) in Appendix C and visually shown in the trend
charts contained in Appendix B.
Overall, the VOCs and inorganics detected in overburden and bedrock wells in 2023 are consistent with
historic results and trends. The overburden wells MW-C16, MW-E22 and MW-J35 exceed IGCLs for
VOCs, specifically 2-butanone, vinyl chloride, and total xylene. Total xylenes showed an increasing
statistical and visual trend in MW-E22. Prior to the comprehensive FYR sampling period, total xylenes
were last monitored during the 2020 monitoring period. The VOCs methylene chloride, vinyl chloride,
and total xylenes, as well as 2-butanone, TCE, and PCE, were previously detected at elevated
concentrations in the upgradient shallow overburden well MW-B13D in the mid- to late-1990"s. MW-
B13D is an on site monitoring well located between the landfill and MW-J3 5. In the Conceptual Site Model
Update (Summit 2012b), it was postulated that the delayed migration of VOCs to deeper overburden wells
suggest that a "slug" of VOC-impacted groundwater has slowly migrated downward through the low
permeability overburden deposits. However, significant or increasing levels of the VOCs have not been
detected in bedrock. The VOCs present in bedrock well MW-3, directly downgradient of MW-13D, do
not appear to indicate a significant increasing trend of VOCs in bedrock groundwater. Methylene chloride
has only been detected at this location twice over the past 10 years (2010 and 2024 at similar
concentrations). Xylenes at this location have been stable or decreasing and had concentrations below
both the IGCL and the EPA and VTDEC MCLs, since 2021.
The trends in arsenic and manganese in groundwater wells are generally decreasing, with exceptions as
noted below. None of the bedrock or overburden wells exceeding the IGCL for arsenic had upward
statistical trends. Of the wells with manganese exceeding the IGCL, none exhibited statistical increases in
manganese and only one of nine bedrock wells and one of three overburden wells exhibited visual
increases in manganese. The trend in lead in groundwater wells were not statistically increasing for any
location; however, three of eight bedrock wells exhibited increases in lead (when the data was interpreted
visually). The observed trends appear consistent with long-term trends used to estimate the additional 30-
50 years required to achieve the cleanup identified in the ESD.
1.4-Dioxane and Per- and Polvfluoroalkvl Substances (PFAS) Monitoring
Analysis of samples for 1,4-dioxane and PFAS was completed for groundwater samples collected from
four monitoring wells in October 2020, November 2021, November 2022, and November 2023 as
specified in the Long-Term Monitoring Plan (Haley Ward 2023b). In addition, samples from the Missing
Link Water Supply System have been analyzed for the presence of 1,4-dioxane and PF AS during bi-annual
sampling events since the fall of 2020.
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Analytical results for the 2020-2023 sampling events showed that 1,4-dioxane and PFAS results were
below laboratory detection limits in all samples collected from the Missing Link Water Supply system.
Analytical results for the November 2023 sampling event showed that 1,4-dioxane was detected in
groundwater collected from four monitoring wells at concentrations that ranged from 5.2 (.ig/L in MW-
J37, a downgradient deep bedrock monitoring well, to 14,000 (.ig/L in MW-J35, a shallow overburden
monitoring well located downgradient of the landfill that has historically been impacted by VOCs.
Groundwater results above the USE PA carcinogenic risk-based screening level (RSL) of 0.46 (.ig/L for
1,4-dioxane also include 40 (.ig/L in MW-7, a deep bedrock well located downgradient of the landfill and
proximal to MW-J35. No current risk is attributable to these concentrations as ICs are in place that restrict
groundwater use across the Site and analytical results for the water supply wells are below laboratory
detection limits.
Analytical results for the 2023 sampling event showed that various PFAS compounds were detected in
the AST samples and two monitoring wells (MW-7 and MW-J35). Groundwater results above the
Verrnont Groundwater Quality Enforcement Standards (VGES) of 20 ng/L (ppt) for any combination of
perfluorooctanoic acid (PFOA), perfluorooctane sulfonate (PFOS), pert]uorononanoic acid (PFNA),
pert!uoroheptanoic acid (PFHpA) and pert!uorohexanesulfoni c acid (PFHxS) and/or April 10, 2024 EPA
issued MCLs include combined PFAS values of 74 ng/L in the AST, 3.2 ng/L in MW-7, and 289 ng/L in
MW-J35.
The 2023 data shows that multiple PFAS compounds were detected above the EPA MCLs. For AST
(shallow groundwater) samples, 2023 results showed PFOA, PFOS, and PFHxS were detected above EPA
MCLs. PFAS was not detected above laboratory detection limits in the UST leachate sample. Results for
the two monitoring wells (MW-7 and MW-J35) indicate that PFOA, PFOS, and PFHxS were detected
above EPA MCLs in at MW-J35 in 2023. More specifically, at MW-J35 PFHxS was detected at 45 ng/L
and PFOA at 150 ng/L; at the AST PFHxS at 14 ng/L, PFOS at 15 ng/L, and PFOA at 33 ng/L, all
exceeding EPA MCLs of 10 ng/L for PFHxS and 4 ng/L for PFOS and PFOA. Groundwater results above
the EPA combined (PFHxS, PFNA, HFPO-DA, and PFBS) Hazard Index (HI) of 1 (unitless) specified in
the recently issued USEPA Drinking Water MCLs, was observed as follows: AST with a combined HI of
1.6, and MW-J35 with a HI of 4.7. PFAS detections above MCLs and PFAS mixtures exceeding HI 1 do
not result in current risk because there is no current exposure to drinking water due to the ICs in place.
Additionally, PFAS were below detection limits in water supply wells. Concentrations for PFAS
compounds observed during the 2023 FYR sampling event will be useful for comparison to future
monitoring results and trend analysis.
Table 7, Appendix C presents a summary of the 2020 through 2023 sampling results for 1,4 dioxane and
PFAS.
Trend analysis was performed on locations with detections of 1,4-dioxane and/or PFAS compounds.
Locations analyzed include the AST, UST, MW-7, MW-J35, and MW-J37. No statistically significant
trends were present for 1,4-dioxane in any of the above-listed locations. Due to the limited PFAS data set,
a statistical PFAS trend was performed for the AST only. A decreasing statistical trend was observed in
the AST PFNA concentrations. No additional statistical trends were observed for other PFAS compounds.
Trend results are presented in Appendix B.
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Extent of Contamination
The lateral extent of groundwater contamination in overburden and bedrock groundwater has generally
remained the same as the last FYR and COCs are generally stable. VOCs and inorganics detected in
overburden and bedrock wells in 2023 are consistent with historic results and trends. The overburden wells
MW-C16, MW-E22 and MW-J35 exceed IGCLs for VOCs, specifically 2-butanone, vinyl chloride, and
total xylene. Total xylenes showed an increasing statistical and visual trend in MW-E22. Increasing trends
are attributed to the localized slow downward migration of impacted groundwater through silty clay
overburden deposits (Summit 2012c; Summit 2014a), with total xylenes showing an increasing statistical
and visual trend in MW-E22.
The lateral extent of VOCs in bedrock groundwater has typically been limited to a narrow zone between
MW-6 and MW-9, while the lateral extent of VOCs in overburden groundwater occurs in a slightly wider
zone between B-7 and the seep SW-6. Chromium and barium exceedances in groundwater monitoring
wells have sporadically been observed in isolated areas around MW-B13D and MW-9 respectively.
VOCs, chromium and barium are interpreted to be the result of migration of these constituents from the
landfill.
VOCs present this FYR period in bedrock well MW-3, directly downgradient of MW-13D, do not appear
to indicate a significant increasing trend of VOCs in bedrock groundwater. Xylenes at this location have
been stable or decreasing and had concentrations below both the IGCL and the EPA and VTDEC MCLs,
since 2021.
The trends in arsenic and manganese in groundwater wells are generally decreasing, with exceptions as
noted below. None of the bedrock or overburden wells exceeding the IGCL for arsenic had upward
statistical trends. Of the wells with manganese exceeding the IGCL, none exhibited statistical increases in
manganese and only one of nine bedrock wells and one of three overburden wells exhibited visual
increases in manganese. The trend in lead in groundwater wells were not statistically increasing for any
location, however three of eight bedrock wells exhibited increases in lead when the data was interpreted
visually.
Concentrations of manganese and arsenic that exceed the IGCL occur in areas located closest to and
downgradient of the landfill; however, note that arsenic concentrations above the IGCL have also been
reported at multiple background residential water supply wells (i.e. reference wells) located in the area of
the Site; which are routinely sampled as part of long-term monitoring activities. The presence of
manganese and arsenic in groundwater affected by the landfill is likely the result of a reducing
environment attributable to the landfill that has mobilized naturally occurring arsenic and manganese, as
opposed to a migrating plume of arsenic and manganese from the landfill.
Site Inspection
The inspection of the Site was conducted on 6/12/2024. Attendees included Kevin Heine, RPM, and
Darrel Swatts, CIC from the EPA and Graham Bradley, VTDEC Project Manager. PRP representatives
included Angelo Liquori, Republic Services, and Roger Bellerose, Blue Granite Environmental
Consultants, LLC. The purpose of the inspection was to assess the protectiveness of the remedy.
No issues impacting current and/or future protectiveness were observed. Necessary onsite documents were
readily available and observed and institutional controls and general site conditions were observed to be
in adequate conditions, including fencing, gates, and signage. Engineered systems including the landfill
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cap, vegetative features, drainage swales, letdown channels, and interceptor trenches were observed and
no deficiencies were noted.
A complete inspection report can be found in Appendix H.
V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents9
Yes. Remedial actions continue to operate and function as designed by the following:
The multilayer landfill cap remains intact to isolate and prevent direct contact with the solid waste
contained in the landfill. Both the solid waste mass and cap appear intact and stable against slope
movement at this time. The June 12, 2024 inspection did not identify changes in cap conditions or
the presence of settlement features beyond those that occurred during past FYR periods and do not
impact the functionality of the landfill cap.
A reduction in the groundwater elevations near the landfill and the decline in leachate collection
system flow volumes are both indicators that the landfill cap has minimized the infiltration of
surface water through the solid waste mass.
Long-term improvements in the quality of shallow groundwater intercepted by the Route 5 System
are also indicative of a decline in contaminants present in shallow overburden groundwater
intercepted by the trench.
The lack of new seeps at the Site and the intermittent flow of Seep SW-6 indicate that the landfill
cap and the Route 5 System (groundwater interceptor trench) are effectively reducing the flow of
contaminated shallow groundwater that could develop into seeps and potentially impact surface
water.
The landfill gas management system has controlled landfill gas emissions, so methane gas does
not represent an explosion hazard, and prevented the release and subsequent exposure (inhalation)
of landfill gas potentially containing hazardous substances, pollutants or contaminants. Installation
of a candlestick flare has increased the operational time of the gas treatment system which is an
improvement over the previous flare which was working intermittently because it required more
gas flow.
The private water supply system (Missing Link Water Supply) serving four residents on Riverfront
Drive continues to deliver drinking water to nearby residents and meet State and Federal water
quality standards.
There has been no indication that contaminated groundwater in bedrock is spreading outside the
Groundwater Reclassification Zone. As shown in Annual Monitoring Reports, contaminant
concentration trends in groundwater are generally stable or decreasing, however, reports do not
provide figures showing Site contaminants are limited to the Groundwater Reclassification Zone.
Potential climate change impacts include changes in precipitation, increasing risk of floods, and
changes in temperature. Climate change is not anticipated to impact the remedy as implemented
and performance of the on site controls because the elevation of the landfill engineered cap and
other associated structures are outside of identified flood zones and constructed with sufficient
resiliency and adequately maintained and monitored to withstand climate changes, including
increases in precipitation events and their magnitude and increases in temperature.
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System Operations/O&M
Operation and maintenance of the landfill cap, drinking water supply system, gas
management system and leachate and shallow groundwater seepage have followed
standard operating procedures, and continue to maintain the effectiveness of site
remediation.
To date, potential effects from climate change have not impacted the system operations
on site; the landfill footprint is outside of identified floodplains and the landfill cap is
inspected/maintained regularly and performing as designed.
Implementation of Institutional Controls and Other Measures
As noted in the latest 2023 Annual Inspection and the 2024 FYR Site Inspection, access
controls (e.g., fencing and warning signs) are in place and effective in preventing
unauthorized entry to the Site.
The institutional controls to prevent installation of new drinking water wells in the
Groundwater Reclassification Zone are in place and are effective at preventing exposure
to contaminated groundwater.
Financial Assurance instruments are in place for the Site.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy selection still valid9
Question 6 Summary:
No. There have been changes in exposure assumptions, risk assessment methods, and toxicity values since
the time of remedy selection; however, the RAOs are still valid. Since the 1994 ROD, 1,4-dioxane and
PFAS compounds have been discovered at the Site at levels above respective federal and/or state drinking
water standards (i.e., the standards which were used in selecting site-specific IGCLs identified in decision
documents). After continued monitoring, EPA will evaluate whether 1,4-dioxane or any PFAS compounds
should be added to the remedy as a COC. The changes as described below are not expected to alter the
short-term protectiveness of the remedy because a private water line serves downgradient households,
and the multilayer landfill cover remains intact. Additionally, ICs are in place which prevent installation
of new drinking water wells and prohibit use of groundwater at the Site until groundwater cleanup goals
are achieved.
Changes in Standards and THCs
New standards (federal or state statutes and/or regulations), as well as new to be considered (TBC)
guidances, should be considered during the five-year review process as part of the protectiveness
determination. Under the NCP, if a new federal or state statute and/or regulation is promulgated or a new
TBC guidance is issued after the ROD is signed, and, as part of the five-year review process it is
determined that the standard needs to be attained or new guidance procedures followed to ensure that the
remedy is protective of human health and the environment, then the five-year review should recommend
that a future decision document be issued that adds the new standard as an ARAR or guidance as a TBC
to the remedy.
EPA guidance states:
"Subsequent to the initiation of the remedial action new standards based on new scientific information or
awareness may be developed and these standards may differ from the cleanup standards on which the
remedy was based. These new ... [standards] should be considered as part of the review conducted at least
every five years under CERCLA ง 121(c) for Sites where hazardous substances remain on-site. The review
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requires EPA to assure that human health and the environment are being protected by the remedial action.
Therefore, the remedy should be examined in light of any new standards that would be applicable or
relevant and appropriate to the circumstances at the Site or pertinent new [standards], in order to ensure
that the remedy is still protective. In certain situations, new standards or the information on which they
are based may indicate that the Site presents a significant threat to health or environment. If such
information comes to light at times other than at the five-year reviews, the necessity of acting to modify
the remedy should be considered at such times." (See CERCLA Compliance with Other Laws Manual:
Interim Final (Part 1) EPA/540/G-89/006 August 1988, p. 1-56.)
Changes to the IGCLs from the 1994 ROD were made in the 2014 ESD for arsenic (10|ig/L) to
match changes in the federal Safe Drinking Water Act (SDWA) MCL and lead (15|ig/L) to be
consistent with the Safe Drinking Water Act (SDWA) Action Level. Revisions to the IGCLs for
arsenic and lead in the ESD ensures the remedy remains protective of human health and the
environment.
In April 2024 the EPA announced the final National Primary Drinking Water Regulation for six
PFAS, establishing enforceable levels (MCLs) as discussed below.
PFAS Activities at BFI Landfill
The purpose of this section is to present current information related to PFAS activities at the Site and to
evaluate whether there are any potential impacts to remedy protectiveness from PF AS. On April 10, 2024,
EPA issued MCLs for six PFAS contaminants, including PFOA, PFOS, PFNA, HFPO-DA (Gen-X),
PFHxS, and PFBS:
Compound
Final MCL
PFOA
4 ppt
PFOS
4 ppt
PFHxS
10 ppt
PFNA
10 ppt
HFPO-DA (Gen-X)
10 ppt
Mixtures containing two or more of PFHxS,
1 (unitless)
PFNA, HFPO-D A, and PFBS
Hazard Index 1
The following subsections discuss the relevant PFAS toxicity values and state standards that are currently
available, followed by a discussion of Site activities related to PFAS and protectiveness conclusions.
PFAS Toxicity Values
This section presents the toxicity values that EPA currently has available for PFAS compounds.
2024 Non-Cancer Toxicity Value for PFDA
In July 2024, EPA released a non-cancer organ specific reference dose (RfD) value for PFDA of 2 x 10-9
mg/kg-day based on a new IRIS value. Previously there was no toxicity value available for PFDA.
2024 Cancer and Non-cancer Toxicity Values for PFOA and PFOS
On April 10, 2024, EPA issued new MCLs for PFOA and PFOS (4 ppt individually) which utilize updated
toxicity values for cancer and non-cancer effects developed by EPA Office of Water. The new oral cancer
slope factors are 2.93 x 10~4 [mg/kg/day]"1 for PFOA and 3.95 x 101 [mg/kg/day]"1 for PFOS. For non-
cancer, the new oral reference dose values are 3 x io-8 (mg/kg/d) for PFOA and 1 x 10~7 (mg/kg/d) for
PFOS. It is noted that toxicity values for PFHxS, PFNA, HFPO-DA (Gen-X), and PFBS are not changed
with the new MCLs.
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2023 Non-cancer Toxicity Values for PFODA, TfTetA, PFDoDA, PFUDA, PFHxA, PFPrA, HQ-115
In November 2023, EPA adopted new non-cancer oral reference dose (RfD) values for multiple PFAS
compounds based on toxicity values developed by the State of Wisconsin Department of Health Services
which include Pert]uorooctadecanoic acid (PFODA) 4 x 10 2 mg/kg-day. Pert]uorotetradecanoic acid
(PFTetA) 1 x 10 3 mg/kg-day. Pert!uorododecanoic acid (PFDoDA) 5 x 10 5 mg/kg-day, and
Pert!uoroundecanoic acid (PFUDA) 3 x 10 4 mg/kg-day.
Additionally, new oral RfD values were released for two PFAS compounds based on toxicity values
published by the EPA Office of Research and Development (ORD) which include Pert!uoropropanoic
acid (PFPrA) 5 x 10 4 mg/kg-day and Lithium bis[(trifluoromethyl)sulfony azanide (HQ-1 15) 3 x 10 4
mg/kg-day, also known as l,l,l-Trifluoro-N-(trifluoromethanesulfonyl)methanesulfonamide (TFS1).
These values were determined to be based on similar methods and procedures as those used for other Tier
3 toxicity values. It is noted that currently there are no analytical methods available for PFODA and the
two ORD compounds PFPrA and HQ-1 15/TFSI.
In April 2023, EPA released a new non-cancer oral reference dose (RfD) of 5 x 10 4 mg/kg-day for
Perfluorohexanoic acid (PFHxA) based on an IRIS value.
2022 Non-cancer Toxicity Value for PFBA
In December 2022, EPA released a new non-cancer oral reference dose (RfD) of 1 x 10 3 mg/kg-day for
Perfluorobutanoic acid (PFBA) based on a new IRIS value.
Additional State Standards
On July 6, 2019, the Vermont Agency of Natural Resources (VTANR) adopted an amended Groundwater
Protection Rule and Strategy.1 The amendment, among other things, updated the list of groundwater
enforcement standards. In particular, the amendment finalized a groundwater enforcement standard of 20
ng/L (ppt) for any combination of PFO A, PFOS, PFNA, PFHpA and PFHxS. (See Groundwater Protection
Rule and Strategy, Appendix One.2) Vermont also promulgated MCLs of 20 ng/L (ppt), individually or
combined, for the same five PFAS compounds in public drinking water through an amendment of its
Water Supply Rules, adopted on March 17, 2020.3
At this time EPA has made no determination of whether these updated V ermont groundwater enforcement
standards will need to be added as an ARAR for this Site; however, they would only be considered if they
are more stringent than federal standards and identified as applicable to shallow groundwater.
Summary of PFAS Activities at BFI Landfill
The most recent 2023 data (Table 7) shows that multiple PFAS compounds were detected above the EPA
MCLs. For AST samples, 2023 results showed PFOA, PFOS, and PFHxS were detected above EPA
MCLs. PFAS was not detected above laboratory detection limits in the UST leachate sample. Results for
the two monitoring wells indicate that PFOA, PFOS, and PFHxS were detected above EPA MCLs in 2023.
Groundwater results above the EPA combined (PFHxS, PFNA, HFPO-DA, and PFBS) Hazard Index (HI)
of 1 (unitless) specified in the recently issued USE PA Drinking Water MCLs, was observed in the
1 VT ANR, Chapter 12 of the Environmental Protection Rules: Groundwater Protection Rule and Strategy. Adopted July 6,
2019.
2 The groundwater enforcement standard of 20 ppt for any combination of the five PFAS was previously adopted and continued
in two emergency rules dated July 11. 2018, and January 8, 2019.
3 See Vermont's Water Supply Rule. 16-3 VT. Code 500 (2020).
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following: AST with a combined HI of 1.6, and MW-J35 with a HI of 4.7. PFAS detections above MCLs
and PFAS mixtures exceeding HI 1 do not result in current risk because there is no current exposure to
drinking water due to ICs in place. Additionally, PFAS were below detection limits in water supply wells,
which is consistent with non-detect results collected since 2020.
EPA will evaluate whether any PF AS compound should be added as a contaminant of concern for the Site
to ensure that the remedy is protective in the long term. As there is no current use of groundwater on the
Site and a private water line and ICs are in place preventing exposure to Site-impacted groundwater, the
PFAS standards do not affect the short-term protectiveness of the remedy on-site. The Missing Link Water
Supply results have concentrations below the updated drinking water MCLs, and PFAS monitoring will
continue to be monitored in the drinking water supply twice a year during routine monitoring.
1,4-Dioxane at BFILandfill
There is no current federal MCL for 1,4-dioxane. Using 2013 updated IRIS toxicity information and the
standard Superfund risk assessment approach, EPA's carcinogenic risk range of 10"6 to 10"4 for 1,4-
dioxane equates to a concentration range of 0.46 to 46 |ig/L (ppb).
On July 6, 2019, the VTANR adopted an amended Groundwater Protection Rule and Strategy. The
amendment, among other things, updated the list of groundwater enforcement standards. In particular, the
amendment finalized a groundwater enforcement standard of 0.3 |ig/L (ppb) for 1,4-dioxane.
As discussed in Section IV, 1,4-dioxane has been detected in the AST, UST, and select monitoring wells
on site above the applicable risk assessment range (0.46 |ig/L); however 1,4-dioxane has not been detected
in the drinking water supplied to nearby residents via the Missing Link Water Supply System. As there is
no current use of groundwater on the Site and a private water line and ICs are in place preventing exposure
to Site-impacted groundwater, the occurrence of 1,4-dioxane does not affect the short-term protectiveness
of the remedy on-site. Analytical results for the Missing Link Water Supply System are below the updated
guidelines, and 1,4-dioxane monitoring will continue to be monitored in the drinking water supply twice
a year during routine monitoring. EPA will evaluate whether 1,4-dioxane should be added as a
contaminant of concern for the Site to ensure that the remedy is protective in the long term.
Floodplain
Federal regulations at 40 CFR Part 6, Appendix A identified in the ROD were withdrawn. Furthermore,
these regulations, and therefore the current CERCLA remedy, only addressed potential floodplain
impacts up to the 100-year flood elevation. Current federal floodplain regulations at 40 CFR Part 9
require a greater assessment of potential floodplain impacts, including preventing the release of
contamination from waste management units and other remedial infrastructure up to the 500-year
floodplain elevation. EPA has assessed potential floodplain impacts from a 500-year flood event on the
landfill engineered cap and associated infrastructure by reviewing the Federal Emergency Management
Agency (FEMA) Flood Insurance Rate Map (FIRM) available via the fema.gov National Flood Hazard
Layer (NFHL) Viewer. No remedial infrastructure has been identified in the AE flood hazard zone, with
a base flood elevation of 305 feet, associated with floodplain areas of the Site adjacent to the
Connecticut River, and 500-year flood events are unlikely to pose a risk to the Site.
Because EPA has not identified any protectiveness issues at this time, we do not include a
recommendation to add this requirement as an ARAR in a future determination.
Sixth Five Year Review Report BFI Landfill | Rockingham, Vermont
18
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Changes in Toxicity and Other Contaminant Characteristics
2024 Hexavalent Chromium cancer and non-cancer toxicity values
In August 2024, EPA finalized a non-cancer oral reference dose (RfD) and a non-cancer inhalation
reference concentration (RfC) for hexavalent chromium (Cr(VI)) based on new IRIS toxicity values.
Additionally, EPA finalized a new oral slope factor and inhalation risk unit for Cr(VI) based on new IRIS
cancer toxicity values.
The new IRIS values for oral slope factor and inhalation unit risk indicate that hexavalent chromium is
less toxic from cancer effects compared to previous values. The oral cancer slope factor, previously 0.5
(mg/kg-day)"1, now is 0.16 (mg/kg-day)"1. The carcinogenic inhalation risk unit previously was 8.4xl0"2
|ig/m3 now is 1.1 xlO"2 |ig/m3. This toxicity change would result in a decreased cancer risk from exposure
to hexavalent chromium.
The new IRIS values for non-cancer indicate that hexavalent chromium is more toxic from non-cancer
effects compared to previous values. Previously, the oral RfD was 3xl0"3 mg/kg-day and now is 9xl0"4
mg/kg-day. The inhalation RfC, previously lxlO"4 mg/m3, now is 3xl0"5 mg/m3. This toxicity change
would result in increased non-cancer risk from exposure to hexavalent chromium.
Chromium was identified as a COC in groundwater with an IGCL of 50 (.ig/L. Groundwater monitoring
results for 2023 showed that chromium exceeded the IGCL in two bedrock monitoring wells (MW-9 and
MW-J38). However, detections of chromium do not impact the protectiveness of the remedy because there
is no current use of groundwater on the Site and a private water line and ICs are in place preventing
exposure to Site-impacted groundwater.
2020 Antimony non-cancer values
In 2020, a new non-cancer inhalation reference concentration (RfC) was adopted for antimony based on
an updated toxicity value from ATSDR. There was no RfC value available previously.
Antimony was identified as a COC in groundwater with an IGCL of 6 (.ig/L. Groundwater monitoring
results for 2023 showed that antimony was detected in one bedrock monitoring well below the IGCL. This
update does not alter the protectiveness of the remedy because there is no current use of groundwater on
the Site and a private water line and ICs are in place preventing exposure to Site-impacted groundwater.
Changes in Risk Assessment Methods
There have been no notable changes in risk methodologies since the previous FYR.
Changes in Exposure Pathways
Land use and expected land use in the area around the site remains unchanged with rural residential land
use. There are no observed changes to physical site conditions that could affect the protectiveness of the
remedy.
Ecological Risk Considerations
2021 Development of the Ecological Screening Values (ESVs) for per- and poly-fluorinated alkyl
substances
The ecological screening values (ESVs) have been developed to support screening-level ecological risk
assessments sites where per- and poly-fluorinated alkyl substances (PFAS) have been detected in soils,
19
Sixth Five Year Review Report BFI Landfill | Rockingham, Vermont
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sediment, and surface waters. The ESVs, developed for eight PFAS, represent PFAS concentrations in
soil, sediment, and surface water at or below which chronically exposed biota are not expected to be
adversely affected and ecological risks or other impacts are unlikely.
The ESVs support the screening level steps (Steps 1 and 2 of eight steps) of EPA's Ecological Risk
Assessment Guidance for Superfund and may be applied at sites undergoing investigation for the historic
release or disposal of PFAS, to identify whether PFAS levels pose potential unacceptable ecological risks.
Sites that have concentrations of PFAS that exceed ESVs may require further investigation in a baseline
ecological risk assessment, which in turn may support risk-management decisions and actions to reduce
risks. These ESVs are solely for use in conducting screening-level ecological risk assessments and are not
recommended or intended for use as default cleanup values.
The ESVs were developed for the following media and receptors:
Soils for invertebrates;
Soils for plants;
Soils for avian and mammalian wildlife;
Surface water for freshwater and marine aquatic biota;
Surface water for aquatic-dependent avian and mammalian wildlife.
Soil, sediment, and surface water have not been screened for PF AS as part of routine monitoring. Impacts
to these media directly attributable to the site are not anticipated based upon the current conceptual site
model of Site contaminants consolidated under a protective landfill cover designed to hold wastes in place
and keep them isolated from other media located outside of the landfill area.
Vapor Intrusion Investigations for BFI Landfill
Exposure to VOCs through vapor intrusion (VI) was evaluated during the previous FYR period, and noted
vapor intrusion was not a pathway of concern.
Expected Progress Towards Meeting RAOs
The Site remedy continues to be effective in meeting the goals of the RAOs although the timeframe to
meet the goals was adjusted as documented in the 2014 ESD. Arsenic and manganese are the principal
constituents of concern requiring an extended period of time to restore bedrock groundwater to IGCLs
(2050 to 2070). The VOCs concentrations at bedrock compliance wells have decreased to concentrations
at or approaching the IGCLs, such that they are no longer considered to be a driving factor for predicting
the timeframe for the restoration of bedrock groundwater quality at the Site. VOC IGCLs were expected
to be achieved in bedrock groundwater by 2025, and during the 2024 monitoring concentration of VOCs
detected in bedrock wells were below IGCL standards.
Overall, no changes to remedial actions, contaminant concentrations, pathways, or toxicity have come to
light that affect the current protectiveness of the remedy.
QUESTION C : Has any other information come to light that could call into question the protectiveness
of the remedy9
No.
Sixth Five Year Review Report BFI Landfill | Rockingham, Vermont
20
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VI. ISSUES/RECOMMENDATIONS
Issues/ Recommendations
Oll(s) without issues/Recommendations Identified in the Five-Year Review:
None.
Issues and Recommendations Identified in the Five-Year Review:
OU(s): OU1
(sitewide)
Issue Category: Monitoring
Issue: Since the 1994 ROD. 1,4-dioxane and PFAS compounds have been
discovered in Site groundwater at levels above respective federal and/or state
drinking water standards (i.e., the standards which were used in selecting site-
specific IGCLs identified in decision documents). After continued monitoring.
EPA will evaluate whether these compounds should be added to the remedy as a
coc
Recommendation: Continued monitoring for 1,4-dioxane and PFAS are necessary
as part of the Site long-term monitoring program to determine whether these
compounds are attributable to wastes that remain on site and whether their presence
could affect the long-term protectiveness of the remedy.
Affect Current
Protectiveness
Affect Future
Protectiveness
Party
Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA
9/30/2028
OTHFR FINDINGS
In addition, the following are recommendations that were identified during the FYR and should improve
management of Site O&M and reduce costs, but do not affect current and/or future protectiveness:
Significant upgrades and changes were made to the Missing Link Road Water Supply System this
review period. Considering the last review of the water system, including both a regulatory review,
physical evaluation, and operations and maintenance (O&M) manual were last
prepared/documented in 2013, these activities should again be performed, documented and
submitted to EPA as verification that the water system substantially meets current state and federal
requirements for use as a public, multi-user supply system.
Opportunities to sample Seep-6 should be made outside of seasonally dry periods given the
propensity for the seep to be dry. Revise the LTMP as necessary to include annual routine
monitoring for PFAS and 1,4-dioxane at Seep-6 during seasonally wet periods.
Annual Monitoring Reports should provide figures that show whether Site contaminants are within
the Groundwater Reclassification Zone.
The detection limit for bis(2-ethylhexyl) phthalate is above the 6 (ig/L IGCL. The current lowest
achievable detection limit offered by contracted laboratories for the compound does not meet the
requirement listed in the Remedial Action Statement of Work (SOW) contained in the Consent Decree
21
Sixth Five Year Review Report BFI Landfill | Rockingham, Vermont
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(the SOW requires the detection limit to be below 5 ug/L). Because current detection limits do not allow for
the detection of bis(2-chloroisopropyl) ether and pentachlorophenol down to the 1 ug/L IGCL, a future
modification to the SOW or related work plan may be necessary.
Issues with sampling protocols for groundwater low-flow sampling and the use of sampling
equipment for sample collection were identified as deviations from the QAPP during an EPA audit
of the Spring 2019 sampling event. In consideration of past audit results and the introduction of
new consultants to Site O&M activities within the last year, it's recommended that the PRP and
its agents/contractors assure the proper implementation of all Site-specific QAPP and O&M
requirements and procedures.
Continue to monitor existing institutional controls and foster positive relations with nearby
residents and the local community to help ensure groundwater use remains restricted across the
Site.
VII. PROTECTIVENESS STATEMENT
Silewide IVolccliMMicss Slittemciil
Protectiveness Determination: Planned Addendum
Short-term Protective Completion Date:
Not applicable
Protectiveness Statement:
The remedy currently protects human health and the environment because there is no current exposure
of Site related contaminants to humans or the environment at concentrations that would represent an
unacceptable risk. Existing protective measures at the Site, including the landfill cap. the landfill gas
collection system, the private water supply system, and ICs. coupled with continued maintenance
activities and regular oversight and monitoring, help ensure that the remedy remains effective and
protective of human health and the environment. However, in order for the remedy to be protective in
the long-term, an evaluation of whether 1,4-dioxane and PFAS compounds need to be added as site
COCs should be conducted.
VIII. NEXT REVIEW
The next five-year review report for the BFI Rockingham Landfill Superfund Site is required five years
from the completion date of this review
Sixth Five Year Review Report BFI Landfill | Rockingham, Vermont
22
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APPENDIX A
REFERENCE LIST
-------
REFERENCES
Balsam Environmental Consultants, Inc., 1994. "Feasibility Study Disposal Specialists, Inc. Site
Rockingham, Vermont."
Civil & Environmental Consultants, Inc., 2024. "2023 Annual Monitoring Report, Disposal
Specialists, Inc. Landfill. "May 2024
CES, Inc. 2014a, 2014 Vapor Intrusion Investigation Summary Report, Disposal Specialists, Inc.
Landfill, Rockingham, Vermont. April 2014
CES, Inc. 2015b, Vapor Intrusion Investigation Summary Report, Disposal Specialists, Inc.
Landfill, Rockingham, Vermont. August 2015
CES, Inc. 2018 1,4 Dioxane Results Fall 2018 Letter, Disposal Specialists, Inc. Landfill,
Rockingham, Vermont. February 2019
Dames & Moore, Inc., 1994. "Demonstration of Compliance Plan Non-Time Critical Removal
Action for the Disposal Specialists, Inc. Landfill, Rockingham, Vermont. "
Dames & Moore, Inc., 1997. "Long-Term Monitoring Plan, Disposal Specialists, Inc. Site,
Rockingham, Vermont."
Ecological Screening Values can be found in: Derivation of PFAS Ecological Screening Values,
M. Grippo, J. Hayse, I. Hlohowskyj, and K. Picel, Environmental Science Division, Argonne
National Laboratory, September 2021
Jurgens, B.C., McMahon, P.B., Chapelle, F.H., andEberts, S.M. (2009), An Excelฎ Workbook for
Identifying Redox Processes in Ground Water: U.S. Geological Survey Open- File Report 2009-
1004
Haley Ward, 2021. "2020 Annual Monitoring Report, Disposal Specialists, Inc. Landfill,
Rockingham, Vermont. " April 2021
-------
Haley Ward, 2022. "2021 Annual Monitoring Report, Disposal Specialists, Inc. Landfill,
Rockingham, Vermont." May 2022
Haley Ward, 2023a. "2022 Annual Monitoring Report, Disposal Specialists, Inc. Landfill,
Rockingham, Vermont." March 2023
Haley Ward 2023b. "Long-Term Monitoring Plan, Disposal Specialists, Inc. Site, Rockingham,
Vermont. ", October 24, 2023
M. Grippo, J. Hayse, I. Hlohowskyj, and K. Picel. 2021. Derivation of PFAS Ecological Screening
Values, Environmental Science Division, Argonne National Laboratory, September 2021.
Summit Environmental Consultants, Inc., 2009. "Field Investigation Work Plan Supporting
Technical Impracticability Evaluation, DSI Landfill, Rockingham, Vermont.
Summit Environmental Consultants, Inc., 2012a. "Investigation Plan, DSI Rockingham Landfill,
Rockingham, Vermont", January 12, 2012.
Summit Environmental Consultants, Inc., 2012b. "Conceptual Site Model Update, Disposal
Specialist Inc. Landfill, Rockingham, Vermont", August 2012.
Summit Environmental Consultants, Inc., 2012c. "Vapor Intrusion Evaluation, Disposal Specialist
Inc. Landfill, Rockingham, Vermont", August 2012.
Summit Environmental Consultants, Inc., 2013b. "Residential Water Supply System and Missing
Link Road Non-Public Water Supply System Operations and Maintenance Manual, DSI
Rockingham Landfill, Rockingham, Vermont", June 7, 2013.
United States of America and State of Vermont, 1996. "Consent Decree " and Statement of Work.
USATSDR 2021. ToxicologicalProfileforPerfluoroalkyls.
https://www.atsdr.cdc.gov/toxprofiles/tp200.pdf
USEPA 2014. Explanation of Significant Differences, BFI Rockingham Landfill Superfund Site,
Rockingham Vermont. September 29, 2014.
-------
USEPA 2019. Fifth live-Year Review Report for BFI Rockingham Landfill Superfund Site,
Rockingham Vermont. September 30, 2019.
US EPA. 2021. Human Health Toxicity Values for Hexafluoropropylene Oxide (HFPO) Dimer
Acid and Its Ammonium Salt (CASRN13252-13-6 and CASRN 62037-80-3) Also Known as "Gen-
X Chemicals." Office of Water, Health and Ecological Criteria Division, Washington, DC,
October 2021.
US EPA. 1988. CERCLA Compliance with Other Laws Manual: Interim Final (Part 1)
EPA/540/G-89/006 August 1988.
US EPA. 2014. Human Health Evaluation Manual, Supplemental Guidance: Update of Standard
Default Exposure Factors Memorandum. OSWER Directive 9200.1-120.
US EPA. 2017. Transmittal of Update to the Adult Lead Methodology's Default Baseline Blood
Lead Concentration and Geometric Standard Deviation Parameters Memorandum, May 17,
2017. OLEMDirective 9285.6-56.
USEPA. 2018. Vapor Intrusion Screening Level (VISL) Calculator. Office of Land and
Emergency Management, Office of Superfund Remediation and Technology Innovation (OSRTI),
May 2018. https://www.epa.gov/vaporintrusion/vapor-intrusionscreening- levels-calculator
US EPA. 2021. Provisional Peer-Reviewed Toxicity Values for Perfluorobutane Sulfonic Acid
(PFBS) and Related Compound Potassium Perfluorobutane Sulfonate. Office of Research and
Development, Center for Public Health and Environmental Assessment, EPA/690/R-21/001F,
2021.
US EPA. 2021. Recommendations on the Use of Chronic or Subchronic Non-cancer Values for
Superfund Human Health Risk Assessments Memorandum, May 26, 2021. Office of Land and
Emergency Management, Washington, DC, 2021.
US EPA. Integrated Risk Information System (IRIS). Available at https://w ww. epa.sov/iris
US EPA. Provisional Peer-Reviewed Toxicity Values. Available at
https://w ww. epa. gov/pprtv
US EPA. Regional Screening Level Tables. Available at https://www. epa.gov/risk/regional-
screening-levels-rsls-generic-tables
URS Corporation, 2009. 'Fall 2008 Semi-Annual Monitoring Report, Disposal Specialists, Inc.
Site, Rockingham, Vermont".
-------
VTANR, 2013. "Findings of Fact & Reclassification Order Amendment to the Groundwater
Reclassification at the DSILandfill Rockingham Vermont, "prepared by The Vermont Agency of
Natural Resources, dated November 4, 2013, and executed November 6, 2013.
-------
APPENDIX B
FIGURES
-------
Charles!
NORTH
Saint
Catherines
Cem
Oliver
Lo veII Cem
APPROX. LIMITS
WASTE
GreQt Meadow
i
7
Civil & Environmental
Consultants, Inc.
31 Bellows Road
Raynham, MA 02767
Ph: 774.501.2176
www.cecinc.com
DISPOSAL SPECIALIST, INC. LANDFILL
MISSING LINK ROAD (RTE 5)
ROCKINGHAM, VERMONT
LOCATION MAP
DRAWN BY:
AWD
DATE:
MAR. 2024
CHECKED BY:
VAFM
DWG SCALE;
1"=2400'
APPROVED BY:
JDK
PROJECT NO:
337-300
FIGURE NO.:
1. TOPOGRAPHIC MAP BASED ON 2018 U.S.G.S TOPOGRAPHIC QUADRANGLE
BELLOWS FALLS, VERMONT.
SCALE IN FEET
2400
4800
-------
MW9
O EW 11A
ฃ.RW-4
LANDFILL SOLID WASTE BOUNDARY
SOIL VAPOR PROBE
MONITORING WELL
MONITORING WELL ANNUAL SAMPLING
GAS EXTRACTION WELL
CT RIVER OR SEEP SAMPLING LOCATION
FORMER WATER SUPPLY WELL (NOT IN USE)
MISSING LINK ROAD NON-PUBLIC WATER
SYSTEM WATER SUPPLY LINE
ACTIVE WATER SUPPLY WELL
SCALE IN FEET
NOTES
1. RESIDENTIAL WELLS SAMPLED DURING LONG-TERM
MONITORING ACTIVITIES ARE NOT SHOWN ON THIS SITE
PLAN.
2. STORMWATER CULVERTS EAST OF ROUT 5 WERE
LOCATED APPROXIMATELY USING HISTORICAL FIGURES.
3. SOIL VAPOR PROBES ARE SHOWN IN APPROXIMATE
LOCATIONS.
4. INFORMATION SHOWN WAS PROVIDED ELECTRONICALLY
BY HALEY WARD. CEC HAS NOT VERIFIED THE
ACCURACY OF THIS INFORMATION.
5. FIGURE BASED ON HALEY WARD FIGURE DATED
04/02/2021.
MHilj
Civil & Environmental
Consultants, Inc.
31 Bellows Road
Rayriham, MA 02767
Ph: 774.501.2176
www.cecinc.com
AWC CHECKED BY:
MAR. 2024 DWG SCALE:
r=200'
DISPOSAL SPECIALIST, INC. LANDFILL
MISSING LINK ROAD, ROCKINGHAM, VT
SITE PLAN
ANNUAL SAMPLING
PROJECT NO:
337-300
NORTH
LEGEND
BEDROCK
OUTCROP parcel
AREA 4-505-949
RW3A
PARCEL
4-107-006
(RUMRILL)
PARCEL
4-107-014
(BANHOL2ER)
PARCEL
4-107-012
(JOHNSON)
PARCEL
4-107-010
(GLYNN/STRICKLAND)
-------
ฉ
NORTH
NOTES
t. RESIDENTIAL WELLS SAMPLED DURING LONG-TERM MONITORING ACTIVITIES ARE NOT SHOWN ON THIS AREA.
2. STROMWATER CULVERTS EAST OF ROUT 5 WERE LOCATED APPROXIMATELY USING HISTORICAL FIGURES.
3. SOIL VAPOR PROBES ARE SHOWN IN APPROXIMATE LOCATIONS.
4. PARCEL LINES COURTESY OF ROCKINGHAM GIS AND AND SHOULD BE CONSIDERED APPROXIMATE.
5. FIGURE BASED ON HALEY WARD FIGURE DATED 04/02/2021.
LEGEND
LANDFILL SOLID WASTE BOUNDARY
6 MONITORING WELL
GAS EXTRACTION WELL
^ CT RIVER OR SEEP SAMPLING LOCATION
A FORMER WATER SUPPLY WELL (NOT IN USE)
0 RESIDENTIAL WELL LOCATION
MISSING LINK ROAD NON-PUBLIC WATER
SYSTEM WATER SUPPLY LINE - WATERLINE RESTRICTION AREA
-ivil & Environmental
Consultants, Inc.
3 I Bellows Road
Rayriham, MA 02767
Ph: 774.501.2176
www.cecinc.com
DISPOSAL SPECIALIST, INC. LANDFILL
MISSING LINK ROAD, ROCKINGHAM, VT
SITE PLAN
RESIDENTIAL WELL LOCATIONS
DRAWN BY:
XX
1
CHECKED BY:
VAFJV
APPROVED BY:
JDK
DATE:
MAR. 202
! DWG SCALE:
r=300'
PROJECT NO:
337-300
-------
"i
-------
"i
-------
1. MONITORING WELLS USED TO DEVELOP THE DEEPER BEDROCK GROUNDWATER
POTENTIOMETRIC CONTOURS INCLUDE WELLS K-40, H-28, J-38, MW-4, MW-7,
MW-10, C-18, E24 & G-26.
2. BASED ON FIGURE DATED 02/22/23 BY HALEY WARD.
LEGEND
SCALE IN FEET
200
400
-$ฆ MONITORING WELL
o GAS EXTRACTION WELL
S CT RIVER OR SEEP SAMPLING LOCATION
A FORMOER WATER SUPPLY WELL (NOT IN USE)
NR NOT RECORDED
(100.0)
LANDFILL SOLID WASTE BOUNDRY
PROPERTY BOUNDARY (APPROXIMATE)
SHALLOW BEDROCK GROUNDWATER POTENTIOMETRIC
SURFACE CONTOUR (DASHED WHERE INTERPRETED)
GROUNDWATER ELEVATION
GROUNDWATER ELEVATION
INTERPRETED FLOW DIRECTION
EBE
Civil & Environmental
Consultants, Inc.
3 I Bellows Road
Raynham, MA 02767
Ph: 774.501.2176
www.cecinc.com
AWC
03/11/2.
CHECKED BY:
DWG SCALE:
r=200'
DISPOSAL SPECIALISTS, INC. LANDFILL
MISSING LINK ROAD (ROUT 5)
ROCKINGHAM, VERMONT
DEEPER BEDROCK GROUNDWATER
POTENTIOMETRIC SURFACE CONTOUR MAP
APPROVED BY:
PROJECT NO:
337-300
-------
AST
Time-Series Graph of 1,4-Dioxane
Sample Date
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
Mann-Kendall Trend Analysis
Parameter: 1,4-Dioxane
Location: AST
Original Data (Not Transformed)
Non-Detects Replaced with Detection Limit
95% Confidence Level
Xj
Xk
Xj - Xk
Positives
N<
23
28
-5
0
1
27
28
-1
0
2
22
28
-6
0
3
27
28
-1
0
4
23
28
-5
0
5
23
28
-5
0
6
24
28
-4
0
7
27
23
4
1
7
22
23
-1
1
8
27
23
4
2
8
23
23
0
2
8
23
23
0
2
8
24
23
1
3
8
22
27
-5
3
9
27
27
0
3
9
23
27
-4
3
10
23
27
-4
3
11
24
27
-3
3
12
27
22
5
4
12
23
22
1
5
12
23
22
1
6
12
24
22
2
7
12
23
27
-4
7
13
23
27
-4
7
14
24
27
-3
7
15
23
23
0
7
15
24
23
1
8
15
24
23
1
9
15
S Statistic = 9 - 15 = -6
Comparing at 1.0 - (0.05 / 2) = 97.5% confidence level (two-tailed)
Probability of obtaining S >= |-6| is 0.548
0.548 >= 0.025 indicating no evidence of a trend
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
AST
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
AST
Time-Series Graph of Perfluoroheptanoic acid (PFHpA)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
Mann-Kendall Trend Analysis
Parameter: Perfluoroheptanoic acid (PFHpA)
Location: AST
Original Data (Not Transformed)
Non-Detects Replaced with Detection Limit
95% Confidence Level
Xj
Xk
Xj - Xk
Positives
N(
12
15
-3
0
1
16
15
1
1
1
14
15
-1
1
2
14
15
-1
1
3
11
15
-4
1
4
11
15
-4
1
5
13
15
-2
1
6
16
12
4
2
6
14
12
2
3
6
14
12
2
4
6
11
12
-1
4
7
11
12
-1
4
8
13
12
1
5
8
14
16
-2
5
9
14
16
-2
5
10
11
16
-5
5
11
11
16
-5
5
12
13
16
-3
5
13
14
14
0
5
13
11
14
-3
5
14
11
14
-3
5
15
13
14
-1
5
16
11
14
-3
5
17
11
14
-3
5
18
13
14
-1
5
19
11
11
0
5
19
13
11
2
6
19
13
11
2
7
19
S Statistic = 7 - 19 = -12
Comparing at 1.0 - (0.05 / 2) = 97.5% confidence level (two-tailed)
Probability of obtaining S >= |-12| is 0.178
0.178 >= 0.025 indicating no evidence of a trend
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
AST
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
Mann-Kendall Trend Analysis
Parameter: Perfluorohexanesulfonic acid (PFHxS)
Location: AST
Original Data (Not Transformed)
Non-Detects Replaced with Detection Limit
95% Confidence Level
Xj
Xk
Xj - Xk
Positives
Negatives
12
12
0
0
0
13
12
1
1
0
13
12
1
2
0
13
12
1
3
0
11
12
-1
3
1
13
12
1
4
1
13
12
1
5
1
13
12
1
6
1
13
12
1
7
1
13
12
1
8
1
11
12
-1
8
2
13
12
1
9
2
13
12
1
10
2
13
13
0
10
2
13
13
0
10
2
11
13
-2
10
3
13
13
0
10
3
13
13
0
10
3
13
13
0
10
3
11
13
-2
10
4
13
13
0
10
4
13
13
0
10
4
11
13
-2
10
5
13
13
0
10
5
13
13
0
10
5
13
11
2
11
5
13
11
2
12
5
13
13
0
12
5
S Statistic =12-5 = 7
Comparing at 1.0 - (0.05 / 2) = 97.5% confidence level (two-tailed)
Probability of obtaining S >= |7| is 0.473
0.473 >= 0.025 indicating no evidence of a trend
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
AST
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
Mann-Kendall Trend Analysis
Parameter: Perfluorononanoic acid (PFNA)
Location: AST
Original Data (Not Transformed)
Non-Detects Replaced with Detection Limit
95% Confidence Level
Xj
Xk
Xj - Xk
Positives
Negatives
2.5
2.7
-0.2
0
1
2.5
2.7
-0.2
0
2
2
2.7
-0.7
0
3
2.1
2.7
-0.6
0
4
ND<1.7
2.7
-1
0
5
ND<1.7
2.7
-1
0
6
1.7
2.7
-1
0
7
2.5
2.5
0
0
7
2
2.5
-0.5
0
8
2.1
2.5
-0.4
0
9
ND<1.7
2.5
-0.8
0
10
ND<1.7
2.5
-0.8
0
11
1.7
2.5
-0.8
0
12
2
2.5
-0.5
0
13
2.1
2.5
-0.4
0
14
ND<1.7
2.5
-0.8
0
15
ND<1.7
2.5
-0.8
0
16
1.7
2.5
-0.8
0
17
2.1
2
0.1
1
17
ND<1.7
2
-0.3
1
18
ND<1.7
2
-0.3
1
19
1.7
2
-0.3
1
20
ND<1.7
2.1
-0.4
1
21
ND<1.7
2.1
-0.4
1
22
1.7
2.1
-0.4
1
23
ND<1.7
ND<1.7
0
1
23
1.7
ND<1.7
0
1
23
1.7
ND<1.7
0
1
23
S Statistic = 1 - 23 = -22
Comparing at 1.0 - (0.05 / 2) = 97.5% confidence level (two-tailed)
Probability of obtaining S >= |-22| is 0.0056
0.0056 < 0.05 indicating a trend
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
AST
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
Mann-Kendall Trend Analysis
Parameter: Perfluorooctanesulfonic acid (PFOS)
Location: AST
Original Data (Not Transformed)
Non-Detects Replaced with Detection Limit
95% Confidence Level
Xj
Xk
Xj - Xk
Positives
Negatives
15
14
1
1
0
14
14
0
1
0
15
14
1
2
0
13
14
-1
2
1
13
14
-1
2
2
15
14
1
3
2
17
14
3
4
2
14
15
-1
4
3
15
15
0
4
3
13
15
-2
4
4
13
15
-2
4
5
15
15
0
4
5
17
15
2
5
5
15
14
1
6
5
13
14
-1
6
6
13
14
-1
6
7
15
14
1
7
7
17
14
3
8
7
13
15
-2
8
8
13
15
-2
8
9
15
15
0
8
9
17
15
2
9
9
13
13
0
9
9
15
13
2
10
9
17
13
4
11
9
15
13
2
12
9
17
13
4
13
9
17
15
2
14
9
S Statistic =14-9 = 5
Comparing at 1.0 - (0.05 / 2) = 97.5% confidence level (two-tailed)
Probability of obtaining S >= |5| is 0.634
0.634 >= 0.025 indicating no evidence of a trend
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
AST
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
Mann-Kendall Trend Analysis
Parameter: Perfluorooctanoic acid (PFOA)
Location: AST
Original Data (Not Transformed)
Non-Detects Replaced with Detection Limit
95% Confidence Level
Xj
Xk
Xj - Xk
Positives
Nc
31
33
-2
0
1
34
33
1
1
1
31
33
-2
1
2
33
33
0
1
2
27
33
-6
1
3
28
33
-5
1
4
34
33
1
2
4
34
31
3
3
4
31
31
0
3
4
33
31
2
4
4
27
31
-4
4
5
28
31
-3
4
6
34
31
3
5
6
31
34
-3
5
7
33
34
-1
5
8
27
34
-7
5
9
28
34
-6
5
10
34
34
0
5
10
33
31
2
6
10
27
31
-4
6
11
28
31
-3
6
12
34
31
3
7
12
27
33
-6
7
13
28
33
-5
7
14
34
33
1
8
14
28
27
1
9
14
34
27
7
10
14
34
28
6
11
14
S Statistic = 11 - 14 = -3
Comparing at 1.0 - (0.05 / 2) = 97.5% confidence level (two-tailed)
Probability of obtaining S >= |-3| is 0.812
indicating no evidence of a trend
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
AST
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
Mann-Kendall Trend Analysis
Parameter: USEPA COMBINED (PFOS & PFOA)
Location: AST
Original Data (Not Transformed)
Non-Detects Replaced with Detection Limit
95% Confidence Level
X]
Xk
Xj - Xk
Positives
Ne
46
47
-1
0
1
48
47
1
1
1
46
47
-1
1
2
46
47
-1
1
3
40
47
-7
1
4
43
47
-4
1
5
51
47
4
2
5
48
46
2
3
5
46
46
0
3
5
46
46
0
3
5
40
46
-6
3
6
43
46
-3
3
7
51
46
5
4
7
46
48
-2
4
8
46
48
-2
4
9
40
48
-8
4
10
43
48
-5
4
11
51
48
3
5
11
46
46
0
5
11
40
46
-6
5
12
43
46
-3
5
13
51
46
5
6
13
40
46
-6
6
14
43
46
-3
6
15
51
46
5
7
15
43
40
3
8
15
51
40
11
9
15
51
43
8
10
15
S Statistic = 10 - 15 = -5
Comparing at 1.0 - (0.05 / 2) = 97.5% confidence level (two-tailed)
Probability of obtaining S >= |-5| is 0.634
0.634 >= 0.025 indicating no evidence of a trend
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
AST
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
Mann-Kendall Trend Analysis
Parameter: (PFOA, PFOS, PFHxS, PFHpA and PFNA)
Location: AST
Original Data (Not Transformed)
Non-Detects Replaced with Detection Limit
95% Confidence Level
Xj
72.5
79.5
75
75.1
62
67
78.7
Xk
76.7
76.7
76.7
76.7
76.7
76.7
76.7
Xj - Xk
-4.2
2.8
-1.7
-1.6
-14.7
-9.7
2
Positives Negatives
1
1
2
3
4
5
5
79.5
75
75.1
62
67
78.7
72.5
72.5
72.5
72.5
72.5
72.5
7
2.5
2.6
-10.5
-5.5
6.2
3
4
5
5
5
6
5
5
5
6
7
7
75
75.1
62
67
78.7
79.5
79.5
79.5
79.5
79.5
-4.5
-4.4
-17.5
-12.5
-0.8
6
6
6
6
6
8
9
10
11
12
75.1
62
67
78.7
75
75
75
75
0.1
-13
-8
3.7
7
7
7
8
12
13
14
14
62
67
78.7
75.1
75.1
75.1
-13.1
-8.1
3.6
8
8
9
15
16
16
67
78.7
62
62
5
16.7
10
11
16
16
78.7
67
11.7
12
16
S Statistic = 12 - 16 = -4
Comparing at 1.0 - (0.05 / 2) = 97.5% confidence level (two-tailed)
Probability of obtaining S >= |-4| is 0.72
0.72 >= 0.025 indicating no evidence of a trend
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-3
Time-Series Graph of Arsenic
Sample Date
Clean-Up Standard 10 |jg/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-3
Time-Series Graph of Lead
Sample Date
Clean-Up Standard 0.015 mg/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-3
Clean-Up Standard 180 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-4
Time-Series Graph of Arsenic
Clean-Up Standard 10 |ig/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-4
Clean-Up Standard 0.015 mg/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-4
Clean-Up Standard 180 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-6
Clean-Up Standard 10 |ig/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-6
Clean-Up Standard 0.015 mg/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-6
Clean-Up Standard 180 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-7
Clean-Up Standard 180 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-7
Time-Series Graph of 1,4-Dioxane
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
Mann-Kendall Trend Analysis
Parameter: 1,4-Dioxane
Location: MW-7
Original Data (Not Transformed)
Non-Detects Replaced with Detection Limit
95% Confidence Level
Xj
Xk
Xj - Xk
Positives
Negatives
63
29
34
1
0
41
29
12
2
0
39.5 B *+
29
10.5
3
0
41
63
-22
3
1
39.5 B *+
63
-23.5
3
2
39.5 B *+
41
-1.5
3
3
S Statistic = 3-3 = 0
Comparing at 1.0 - (0.05 / 2) = 97.5% confidence level (two-tailed)
Probability of obtaining S >= |0| is 1.25
1.25 >= 0.025 indicating no evidence of a trend
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-7
Time-Series Graph of Perfluorobutanesulfonic acid (PFBS)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-7
Time-Series Graph of Perfluoroheptanoic acid (PFHpA)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-7
Time-Series Graph of Perfluorohexanesulfonic acid (PFHxS)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-7
Time-Series Graph of Perfluorononanoic acid (PFNA)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-7
Time-Series Graph of Perfluorooctanesulfonic acid (PFOS)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-7
Time-Series Graph of Perfluorooctanoic acid (PFOA)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-7
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-9
Clean-Up Standard 50 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-9
Clean-Up Standard 0.015 mg/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-9
Clean-Up Standard 180 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-B3
Clean-Up Standard 0.015 mg/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
2000
MW-B7
Time-Series Graph of Manganese
1500 -
1000
500-
O
Sample Date
Clean-Up Standard 180 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
6000
MW-C15
Time-Series Graph of Manganese
Sample Date
Clean-Up Standard 180 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-C16
Clean-Up Standard 2 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-C17
Time-Series Graph of Arsenic
20
15
CD
O
Sample Date
Clean-Up Standard 10 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-C17
Clean-Up Standard 15 mg/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-C17
Clean-Up Standard 180 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
20000
MW-D19
Time-Series Graph of Manganese
15000
Clean-Up Standard 800 ug/L
Disposal Specialists, Inc.
Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-E22
Clean-Up Standard 400 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
30
MW-E24
Time-Series Graph of Arsenic
25-
20-
15-
10-
0-
O)
Sample Date
Clean-Up Standard 10 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-G25
Clean-Up Standard 10 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-G25
Clean-Up Standard 0.015 mg/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-G25
Clean-Up Standard 180 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-J35
Clean-Up Standard 170 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-J35
Clean-Up Standard 400 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-J35
Time-Series Graph of Arsenic
Clean-Up Standard 10 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-J35
Time-Series Graph of Lead
0.031
0.025 -
Sample Date
Clean-Up Standard 0.015 mg/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-J35
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
Mann-Kendall Trend Analysis
Parameter: 1,4-Dioxane
Location: MW-J35
Original Data (Not Transformed)
Non-Detects Replaced with Detection Limit
95% Confidence Level
Xj
Xk
Xj - Xk
Positives
IS
32000
280
31720
1
0
25000
280
24720
2
0
14000 B *+ F2
280
13720
3
0
25000
32000
-7000
3
1
14000 B *+ F2
32000
-18000
3
2
14000 B *+ F2
25000
-11000
3
3
S Statistic = 3-3 = 0
Comparing at 1.0 - (0.05 / 2) = 97.5% confidence level (two-tailed)
Probability of obtaining S >= |0| is 1.25
1.25 >= 0.025 indicating no evidence of a trend
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-J35
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-J35
Time-Series Graph of Perfluorohexanesulfonic acid (PFHxS)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-J35
Time-Series Graph of Perfluorononanoic acid (PFNA)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-J35
Time-Series Graph of Perfluorooctanesulfonic acid (PFOS)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
200
MW-J35
Time-Series Graph of Perfluorooctanoic acid (PFOA)
150 ~
100
50
O
Sample Date
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
200
MW-J35
Time-Series Graph of USEPA COMBINED (PFOS PFOA)
100
50
o
Sample Date
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-J35
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-J36
Clean-Up Standard 0.015 mg/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-J37
Clean-Up Standard 900 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-J37
Time-Series Graph of 1,4-Dioxane
1
Sample Date
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
Mann-Kendall Trend Analysis
Parameter: 1,4-Dioxane
Location: MW-J37
Original Data (Not Transformed)
Non-Detects Replaced with Detection Limit
95% Confidence Level
Xj
Xk
Xj - Xk
Positives
Negatives
1.2
3.8
-2.6
0
1
2.4
3.8
-1.4
0
2
5.2
3.8
1.4
1
2
2.4
1.2
1.2
2
2
5.2
1.2
4
3
2
5.2
2.4
2.8
4
2
S Statistic = 4-2 = 2
Comparing at 1.0 - (0.05 / 2) = 97.5% confidence level (two-tailed)
Probability of obtaining S >= |2| is 0.75
0.75 >= 0.025 indicating no evidence of a trend
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-J37
Time-Series Graph of Perfluoroheptanoic acid (PFHpA)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-J37
Time-Series Graph of Perfluorohexanesulfonic acid (PFHxS)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-J37
Time-Series Graph of Perfluorononanoic acid (PFNA)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-J37
Time-Series Graph of Perfluorooctanesulfonic acid (PFOS)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-J37
Time-Series Graph of Perfluorooctanoic acid (PFOA)
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
MW-J38
Clean-Up Standard 50 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-J38
Clean-Up Standard 0.015 mg/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
MW-J38
Clean-Up Standard 180 ug/L
Disposal Specialists, Inc. Landfill (Rockingham)
2023 Annual Monitoring Report
-------
UST
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
Mann-Kendall Trend Analysis
Parameter: 1,4-Dioxane
Location: UST
Original Data (Not Transformed)
Non-Detects Replaced with Detection Limit
95% Confidence Level
Xj
Xk
Xj - Xk
Positives
Negatives
5.8
5.7
0.1
1
0
5.1
5.7
-0.6
1
1
5.3
5.7
-0.4
1
2
5.5
5.7
-0.2
1
3
5
5.7
-0.7
1
4
5.4
5.7
-0.3
1
5
6.3
5.7
0.6
2
5
5.1
5.8
-0.7
2
6
5.3
5.8
-0.5
2
7
5.5
5.8
-0.3
2
8
5
5.8
-0.8
2
9
5.4
5.8
-0.4
2
10
6.3
5.8
0.5
3
10
5.3
5.1
0.2
4
10
5.5
5.1
0.4
5
10
5
5.1
-0.1
5
11
5.4
5.1
0.3
6
11
6.3
5.1
1.2
7
11
5.5
5.3
0.2
8
11
5
5.3
-0.3
8
12
5.4
5.3
0.1
9
12
6.3
5.3
1
10
12
5
5.5
-0.5
10
13
5.4
5.5
-0.1
10
14
6.3
5.5
0.8
11
14
5.4
5
0.4
12
14
6.3
5
1.3
13
14
6.3
5.4
0.9
14
14
S Statistic =14-14 = 0
Comparing at 1.0 - (0.05 / 2) = 97.5% confidence level (two-tailed)
Probability of obtaining S >= jOj is 1.096
1 096 >= 0.025 indicating no evidence of a trend
Disposal Specialists, Inc. Landfill (Rockingham)
6th Five-Year Review
-------
APPENDIX C
DATA TABLE
-------
Table 4
2023 Summary Of Groundwater Exceeding IGCL Cleanup Standards
DSI Landfill - Rockingham, Vermont
Table 4 Summary of Groundwater Exceeding
IGCL Cleanup Standards November 2023 Five Year Review Sampling
Parameter Group Volatile Organic Compounds Metals _ .
Compounds
Interim Groundwater Cleanup
Level (IGCL) |jg/L
g
V
o
T
CN
8
o
8
o
o
2
8
8
-
-
Parameter/
Well ID
2-Butanone
Benzene
Methylene Chloride
Tetrachloroethene
Trichloroethene
Vinyl Chloride
Xylenes, Total
Arsenic *
Antimony
Barium
Chromium
Lead *
Manganese **
Nickel
Bis (2-chloroi so propyl)
ether
Bis (2-ethyl hexyl)
phthalate
Pentachloro phenol
Total # of Exceedances
By Well
MW-3
X
X
X
X
X
X
NA
3
MW-4
X
X
X
X
X
3
MW-6
X
X
X
X
X
3
MW-7
X
X
X
X
X
y
2
MW-9
X
X
X
X
X
NA
3
MW-10
X
X
X
NA
0
MW-B3
X
X
NA
1
1
O)
c
MW-C17
X
X
X
X
X
NA
3
MW-C18
X
X
NA
0
'c
MW-E23
X
X
NA
G
1
MW-E24
X
X
NA
1
o
ฆ6
MW-G25
X
X
X
NA
3
CO
MW-G26
X
X
X
NA
Q
MW-H27
NA
0
MW-H28
X
NA
0
MW-J37
X
X
NA
1
MW-J38
X
X
X
X
X
X
3
MW-K39
X
X
NA
0
MW-K40
X
X
NA
0
26
MW-B7
X
X
NA
1
*
MWC15
X
X
X
NA
1
-1
MW-C16
X
X
X
X
X
X
NA
1
c
MW-D19
X
X
NA
1
ฆp
MW-E21
X
NA
0
ฃ
MW-E22
:z
X
X
X
X
NA
1
O
MW-J35
X
X
X
X
X
X
X
NA
4
MW-J36
X
X
X
NA
1
1 1
1 1
10
Total # of
Exceedances
for Parameter
Fall 2023
1
0
0
0
0
1
2
7
0
0
2
11
12
0
0
0
0
36
Notes:
X Parameter reported above laboratory detection limit but concentration is below the IGCL cleanup criteria
Parameter reported above laboratory detection limit and reported concentration exceeds the IGCL cleanup
criteria
Parameter reported as Not Detected; however laboratory detection limit is above the IGCL cleanup criteria
indicated.
Interim Groundwater Cleanup Levels (IGCLs) established in the 1994 ROD for bedrock compliance wells. The
IGCL for arsenic was reduced from 50 to 10 ug/L and the IGCL for lead was reduced from 20 to 15 ug/L in the
First Explanation of Significant Differences (ESD), dated September 29,2014.
The cleanup level for manganese is 180 ug/L unless manganese is the only metal above the cleanup level,
then a cleanup level of 900 ug/L is used.
Overburden groundwater quality is compared to IGCLs when assessing the progress of the site remedy.
-------
Table 4
2022 Summary Of Groundwater Exceeding IGCL Cleanup Standards
DSI Landfill - Rockingham, Vermont
Table 4 Summary of Groundwater Exceeding
Cleanup Standards
IGCL
Parameter Group Volatile Organic Compounds
Metals
Interim Groundwater Cleanup
Level (IGCL) mq/L
o
K.
o
CN
o
3
o
o
o
o
8
iO
8
ป
o
CO
0
Parameter /
Well ID
2-B uta none
Benzene
Methylene Chloride
Tetrac h loroethe ne
Trichloroethene
Vinyl Chloride
Xylenes, Total
Arsenic *
Antimony
Barium
Chromium
Lead *
Manganese **
Nickel
MW-3
X
X
X
X
X
X
X
X
MW-4
X
X
X
MW-6
X
X
X
X
ฃ
0
MW-7
X
X
X
'E
0
MW-9
X
X
X
X
2
MW-10
X
X
0
0
"O
MW-G25
X
X
0
MW-J37
X
X
MW-J38
X
X
X
X
X
Total # of
Exceed a nces
for Parameter
November 2022
0
0
0
0
0
0
0
3
0
1
2
0
6
2
reported above laboratory detection limit but concentration is below the IGCL cleanup criteria
reported above laboratory detection limit and reported concentration exceeds the IGCL cleanup criteria
reported as Not Detected; however laboratory detection limit is above the IGCL cleanup criteria indicated.
Interim Groundwater Cleanup Levels (IGCLs) established in the 1994 ROD for bedrock compliance wells. The IGCL for arsenic was reduced from 50 to 10 ug/L and the
IGCL for lead was reduced from 20 to 15 ug/L in the First Explanation of Significant Differences (ESD), dated September 29, 2014.
The cleanup level for manganese is 180 ug/L unless manganese is the only metal above the cleanup level, then a cleanup level of 900 ug/L is used.
Overburden groundwater quality is compared to IGCLs when assessing the progress of the site remedy.
Parameter
I Parameter
Parameter
-------
Table 4
2021 Summary Of Groundwater Exceeding IGCL Cleanup Standards
DSI Landfill - Rockingham, Vermont
Table 4 Summary of Groundwater Exceeding
IGCL Cleanup Standards
Parameter Group Metals
Interim Groundwater Cleanup
Level (IGCL) |jg/L
o
o
o
o
o
lO
lO
o
o
o
o
00
0
Parameter/
Well ID
Arsenic *
Antimony
Barium
Chromium
Lead *
Manganese **
Nickel
-------
Table 4
2020 Summary Of Groundwater Exceeding IGCL Cleanup Standards
DSI Landfill - Rockingham, Vermont
Table 4 Summary of Groundwater Exceeding
IGCL Cleanup Standards
Parameter Group Metals
Interim Groundwater Cleanup
Level (IGCL) |jg/L
o
o
o
o
o
lO
lO
o
o
o
o
00
o
o
Parameter/
*
E
1
0
M
0
c
Well ID
Arsenic
O
|
~c
<
Barium
E
g
o
Lead *
D
0)
c
0
S
Nickel
MW-4
X
X
X
-------
Table 5: Summary of Analytes in Bedrock Monitoring Wells Exceeding IGCLs
Screened Unit
Well
Analyte
IGCL
(ug/L)
USEPA MCL &
VTDEC
Standard
Fall 2023
Concentration
(ug/L)
Average
Concentration
(ug/L)
Statistical Trend
Visual Trend
Arsenic
10
10
297
551
None
None
SBR
MW-3
Lead
15
15
220
3
None
None
Manganese*
180
300
1.320
1.645
None
None
Arsenic
10
10
12.6
12.8
None
None
DBR
MW-4
Lead
15
15
41.0
3.3
None
Increasing
Manganese*
180
300
5.600
2.624
None
None
Arsenic
10
10
186
183
Decreasing
None
DBR
MW-6
Lead
15
15
34
3
None
Increasing
Manganese*
180
300
1.240
1.445
Decreasing
None
DBR
MW-7
Manganese*
900
300
1.610
1.743
NA
NA
Chromium
50
100
512
231
Increasing
Increasing
DBR
MW-9
Lead
15
15
26
3
None
Increasing
Manganese*
180
300
852
531
None
Increasing
SBR
MW-B3
Lead
15
15
17
2
Decreasing
None
Arsenic
10
10
19.9
14.2
NA
NA
DBR
MW-C17
Lead
15
15
36.0
16.2
None
Increasing
Manganese*
180
300
653
203
NA
NA
DBR
MW-E24
Arsenic
10
10
20.1
19.5
NA
NA
Arsenic
10
10
23.5
10.5
Decreasing
None
SBR
MW-G25
Lead
15
15
24.0
3.2
None
None
Manganese*
180
300
510
378
Decreasing
None
SBR
MW-J37
Manganese*
180
300
2.110
2.593
None
None
Chromium
50
100
62.4
135.6
None
None
DBR
MW-J38
Lead
15
15
70.0
3.6
None
None
Manganese*
900
300
745
2.229
None
None
Notes:
USEPA MCL = United States Environmental Protection Agency Maximum Contaminant Level (most current). The EPA has not issued a
Maximum Contaminant Level (MCL) for manganese
VTDEC = Vermont Department of Conservation Interim Groundwater Quality Standards (revised 12/27/2013) IGCL = Interim Groundwater
Cleanup Level for bedrock wells identified in the Remedial Statement of Work
NA = Not analyzed. Data set not suitable for Mann-Kendall (does not contain minimum number of detections needed), and/or does not have
three or more sample results for visual trend analysis. NS = Not sampled in 2017 due to insufficient volume of water in the well
Average Concentration = The average concentration was calculated using data from the four most recent consecutive sampling events, if
available, and not including duplicates.
A = Value exceeds the IGCL Standard, but meets USEPA and VTDEC Drinking Water Standards
* = The IGCL for manganese is 180 ug/L if multiple metals are reported above the IGCL or 900 ug/L if manganese is the
only metal reported above the IGCL
SBR = Shallow Bedrock DBR = Deep Bedrock
ug/L = micrograms per liter or parts per billion
Trend = Trend is based on Mann-Kendall statistical analysis and qualitative analysis None = No trend
Decreasing = Increasing trend at 95% confidence interval Increasing = Decreasing trend at 95% confidence interval
I-S or D-S = Increasing/Decreasing trend; however, time series graphs for recent data visually shows no trend.
-------
Table 6: Summary of Analytes Exceeding IGCLs in Overburden Monitoring Wells
Screened
Unit
Well
Analyte
IGCL
(ug/L)
USEPA MCL &
VTDEC
Standard
Fall
2023Concentrati
on (ug/L)
Average
Concentration
(ug/L)
Statistical Trend
Visual Trend
SOB
MW-B7
Manganese*
900
300
1.960
1.492
None
Increasing
SOB
MW-C15
Manganese*
900
300
3.880
2.859
None
None
DOB
MW-C16
Vinyl Chloride
2
2
2.6
1.5
NA
NA
SOB
MW-D19
Manganese
900
300
1.220
1.759
None
None
DOB
MW-E22
Xylenes, Total
400
10.000
10.000
5.275
Increasing
Increasing
2-Butanone
170
4.200**
8.300
16.575
None
None
DOB
MW-J35
Xylenes, Total
400
10.000
2.000
1.775
None
None
Lead
15
15
23
3
None
None
Arsenic
10
10
19.5
18
None
None
SOB
MW-J36
Lead
15
15
24
2
None
None
Notes:
US EPA MCL = United States Environmental Protection Agency Maximum Contaminant Level (most current). The EPA has not issued a Maximum
Contaminant Level (MCL) for manganese
VTDEC = Vermont Department of Conservation Interim Groundwater Quality Standards (revised 12/27/2013) IGCL = Interim Groundwater Cleanup
Level for bedrock wells identified in the Remedial Statement of Work
NA = Not analyzed. Data set not suitable for Mann-Kendall (does not contain minimum number of detections needed), and/or does not have three or
more sample results for visual trend analysis. NS = Not sampled in 2017 due to insufficient volume of water in the well
Average Concentration = The average concentration was calculated using data from the four most recent consecutive sampling events, if available. The values used to calculate the
average concentration are noted in Appendix G
A = Value exceeds the IGCL Standard but meets US EPA and VTDEC Drinking Water Standards
* = The IGCL for manganese is 180 ug/L if multiple metals are reported above the IGCL. The IGCL for manganese is 900 ug/L if manganese is the only metal reported
above the IGCL
** = The USEPA has not issued a standard for 2-Butanone (Methyl Ethyl Ketone). The VTDEC has issued a standard of 4,200 ug/L
*** = Detection limit for analyte has historically been reported above the IGCLs and analyte has historically been detected at concentrations that exceeded the IGCLs;
therefore, analyte is listed as an exceedance
SOB = Shallow Overburden DOB = Deep Overburden
ug/L = micrograms per liter or parts per billion
Trend = Trend is based on Mann-Kendall statistical analysis and qualitative analysis None = No trend
Decreasing = Increasing trend at 95% confidence interval Increasing = Decreasing trend at 95% confidence interval
I-S or D-S = Increasing/Decreasing trend; however, time series graphs for recent data visually shows no trend.
-------
-------
Table 7
Summary of 1,4 Dioxane and PFAS Analytical Results in Select Groundwater Moinitoring and Drinking Water Wells
Results
USEPA
Health
Advisory
VTDEC
Groundwater
Enforcement
Standard
Missing Link
Water Supply
Well 2 Pre
Missing Link
Water Supply
Well 2 Pre DUP
Missing Link
Water Supply
Well 2 Post
Missing Link
Water Supply
Well 3 Pre
Missing Link
Water Supply
Well 2 Pre
Missing Link
Water Supply
Well 2 Pre DUP
Missing Link
Water Supply
Well 2 Post
Missing Link
Water Supply
Well 3 Pre
5/11/2022
5/11/2022
5/11/2022
5/11/2022
11/2/2022
11/2/2022
11/2/2022
11/2/2022
Sampling Method
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Stratum
Deep Bedrock
Side Gradient
Deep Bedrock
Side Gradient
Deep Bedrock
Side Gradient
Deep Bedrock
Side Gradient
Deep Bedrock
Side Gradient
Deep Bedrock
Side Gradient
Deep Bedrock
Side Gradient
Deep Bedrock
Side Gradient
Screen Depth (ft-bgs)
1,4-Dioxane (jjg/L)
200
0.3
0.20 U
0.20 U
0.20 U
0.20 U
0.20 U
0.20 U
0.20 U
0.20 U
Perfluorobutanesulfonic acid
(PFBS) (ng/L)
1.8 U
1.8 U
1.8 U
1.8 U
1.9 U
1.8 U
1.8 U
1.9 U
Perfluoroheptanoic acid
(PFHpA) (ng/L)
20
1.8 U
1.8 U
1.8 U
1.8 U
1.9 U
1.8 U
1.8 U
1.9 U
Perfluorohexanesulfonic acid
(PFHxS) (ng/L)
20
1.8 U
1.8 U
1.8 U
1.8 U
1.9 U
1.8 U
1.8 U
1.9 U
Perfluorononanoic acid
(PFNA) (ng/L)
20
1.8 U
1.8 U
1.8 U
1.8 U
1.9 U
1.8 U
1.8 U
1.9 U
Perfluorooctanesulfonic acid
(PFOS) (ng/L)
70
20
1.8 U
1.8 U
1.8 U
1.8 U
1.9 U
1.8 U
1.8 U
1.9 U
Perfluorooctanoic acid
(PFOA) (ng/L)
70
20
1.8 U
1.8 U
1.8 U
1.8 U
1.9 U
1.8 U
1.8 U
1.9 U
USEPA COMBINED (ng/L)
(PFOS & PFOA)
70
3.6 U
3.6 U
3.6 U
3.6 U
3.8 U
3.6 U
3.6 U
3.8 U
VTDEC COMBINED (ng/L)
(PFOA, PFOS, PFHxS, PFHpA and
PFNA)
20
9.0 U
9.0 U
9.0 U
9.0 U
9.5 U
9.0 U
9.0 U
9.5 U
Notes:
Exceeds US EPA Health Advisory
Exceeds VTDEC Health Advisory
EB - Sample related to equipment blank because the sample pump used was a portable bladder pump deconed and with a new PFAS free bladder.
* = Laboratory Control Sample or Laboratory Control Sample Duplicate is outside acceptable limits.
Bold values indicate blank contamination from field or equipment blank
U = Not Detected at listed detection limit
OB -Overburden
NA- Not applicable
NS - No sample collected
NS Dry - No sample because well dry
1= Value is estimated maximum possible concentration.
-------
Table 7
Summary of 1,4 Dioxane and PFAS Analytical Results in Select Groundwater Moinitoring and Drinking Water Wells
Results
USEPA
Health
Advisory
VTDEC
Groundwater
Enforcement
Standard
Missing Link
Water Supply
Well 2 Pre
Missing Link
Water Supply
Well 2 Pre DUP
Missing Link
Water Supply
Well 2 Post
Missing Link
Water Supply
Well 3 Pre
Missing Link
Water Supply
Well 2 Pre
Missing Link
Water Supply
Well 2 Pre DUP
Missing Link
Water Supply
Well 2 Post
Missing Link
Water Supply
Well 3 Pre
5/13/2021
5/13/2021
5/13/2021
5/13/2021
10/5/2021
10/5/2021
10/5/2021
10/5/2021
Sampling Method
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Stratum
Deep Bedrock
Side Gradient
Deep Bedrock
Side Gradient
Deep Bedrock
Side Gradient
Deep Bedrock
Side Gradient
Deep Bedrock
Side Gradient
Deep Bedrock
Side Gradient
Deep Bedrock
Side Gradient
Deep Bedrock
Side Gradient
Screen Depth (ft-bgs)
1,4-Dioxane (jjg/L)
200
0.3
0.20 U
0.20 U
0.20 U
0.20 U
0.20 U
0.20 U
0.20 U
0.20 U
Perfluorobutanesulfonic acid
(PFBS) (ng/L)
1.8 U
1.8 U
1.7 U
1.8 U
1.9 U
1.8 U
1.9 U
1.8 U
Perfluoroheptanoic acid
(PFHpA) (ng/L)
20
1.8 U
1.8 U
1.7 U
1.8 U
1.9 U
1.8 U
1.9 U
1.8 U
Perfluorohexanesulfonic acid
(PFHxS) (ng/L)
20
1.8 U
1.8 U
1.7 U
1.8 U
1.9 U
1.8 U
1.9 U
1.8 U
Perfluorononanoic acid
(PFNA) (ng/L)
20
1.8 U
1.8 U
1.7 U
1.8 U
1.9 U
1.8 U
1.9 U
1.8 U
Perfluorooctanesulfonic acid
(PFOS) (ng/L)
70
20
1.8 U
1.8 U
1.7 U
1.8 U
1.9 U
1.8 U
1.9 U
1.8 U
Perfluorooctanoic acid
(PFOA) (ng/L)
70
20
1.8 U
1.8 U
1.7 U
1.8 U
1.9 U
1.8 U
1.9 U
1.8 U
USEPA COMBINED (ng/L)
(PFOS & PFOA)
70
3.6 U
3.6 U
3.4 U
3.6 U
3.8 U
3.6 U
3.8 U
3.6 U
VTDEC COMBINED (ng/L)
(PFOA, PFOS, PFHxS, PFHpA and
PFNA)
20
9.0 U
9.0 U
8.5 U
9.0 U
9.5 U
9.0 U
9.5 U
9.0 U
Notes:
Exceeds US EPA Health Advisory
Exceeds VTDEC Health Advisory
EB - Sample related to equipment blank because the sample pump used was a portable bladder pump deconed and with a new PFAS free bladder.
* = Laboratory Control Sample or Laboratory Control Sample Duplicate is outside acceptable limits.
Bold values indicate blank contamination from field or equipment blank
U = Not Detected at listed detection limit
OB -Overburden
NA- Not applicable
NS - No sample collected
NS Dry - No sample because well dry
1= Value is estimated maximum possible concentration.
-------
Table 7
ummary of 1,4 Dioxane and PFAS in Select Groundwater Moinitoring and Drinking Water Wells
USEPA
Health
Advisory
VTDEC
Groundwater
Enforcement
Standard
Water Supply
Wei 2 Pre
Missing L nk
WaterSupply
Well 2 Pre
DUP
Water Supply
Wei 2 Post
Missing Link
WaterSupply
Wei 3 Pre
W ater Supply
Wei 3 Post
FIELD BLANK
MW-B3 EB
MWJ35 EB
MW-J35
MW-3
MW-4
MW-6
MW-7
MW-9
MW-10 EB
MW-13D
MW-D-19
MW-D20 MW-E22
MW-E22
Duplicate
MW-G25
MW-J37 EB
MW J38FB
10/20/2020
10/20/2020
10/20/2020
10/20C020
10C0C020
10/20/2020
10/21/2020
5/4/2020
10/21/2020
10/21/2020
10/22/2020
10/22/2020
10/21/2020
10/22/2020
10/22/2020
10C1C020
10/21 /2020
10/21/2020
10/20/2020
10/20/2020
10/20/2020
10/22/2020
10/22/2020
Sampling Method
Grab
Grab
Grab
Grab
Grab
Grab
Portable Bladder
NA
Dedicated Baile,
Submersible
Dedicated Bailer
NA
NA
NA
Blad"mp
BlaDdedtrpeudmp
Peristalic Pump
Submersible
Stratum
sfd? Gradient
ฐeepฎedmck
ฐeepFedmck
ฐeepFedmck
ฐeepFedmck
NA
%zz:':s
I!
KSS
Shallow
II
sxs
Deep
OvTrburden
Deep
Deep Overburden
Deep Overburden
Shalow
sxs
Screen Depth (ft-bgs)
NA
48.8-58.8
30-40
30-40
141.6-151.6
181.6-211.6
132.4-142.4
170-190
58-68
90-110
32.4-42.4
11.9-26.9
93-103
74.6 - 84.6
74.6-84.6
5.8-15.8
50-60
97.8-111.2
0.3
0.2 U
0.2 U
0.19 U
0.2 U
0.19 U
0.2 U
0.2 U
25000 E*
NS
NS
76 E
300 E
41 E
NS
0.2
NS
NS
NS
13 E
13 E
0.2 U
2.4 E
004
(PFBS) (ng/L)
1.7 U
1.8 U
1.7 U
1.7 U
1.7 U
1.7 U
1.8 U
NA
NS
NS
12
2.7
NS
1.7 U
NS
NS
NS
1.7U
1.7 U
1.7 U
2.1
3.3
Perfluoroh eptanoic acid (PFHpA)
(ng/L)
20
1.7U
1.8 U
1.7U
1.7U
1.7U
1.7U
1.8 U
NA
NS
NS
25
25
3.3
NS
1.7U
NS
NS
NS
1.7 U
1.7 U
1.7 U
1.7 U
1.7 U
rpeFrfHxT(ng/L)neSUlf0n'CaC,d
20
1.7U
1.8 U
1.7U
1.7U
1.7U
1.7U
1.8 U
NA
NS
NS
'
17
1.7 U
NS
1.7U
NS
NS
NS
1.7 U
1.7 U
1.7 U
1.7 U
1.7 U
(PFNA) (ng/L)
20
1.7U
1.8 U
1.7U
1.7U
1.7U
1.7U
1.8 U
NA
NS
NS
7.6
2.3
1.7 U
NS
1.7U
NS
NS
NS
1.7 U
1.7U
1.7U
1.7 U
1.7 U
(PF OS) (ng/L)
70
20
1.7U
1.8 U
1.7U
1.7U
1.7U
1.7U
1.8 U
NA
NS
NS
12
43 I
1.7 U
NS
1.7U
NS
NS
NS
1.7 U
1.7 U
1.7 U
1.9
6.2
(PF OA) (ng/L)
70
20
1.7U
1.8 U
1.7U
1.7U
1.7U
1.7U
1.8 U
NA
NS
NS
31
49
2.3
NS
1.7U
NS
NS
NS
2
1.7 U
1.9
2.2
3.5
USE PA COM BIN ED (ng/L)
(PFOS &PFOA)
70
20
1.7 U
1.8 U
1.7 U
1.7 U
1.7U
1.7 U
1.8 U
NA
NS
NS
43
92
2.3
NS
1.7U
NS
NS
NS
2
1.7 U
1.9
4,
9.7
20
1.7 U
1.8 U
1.7 U
1.7 U
,7U
1.7 U
1.8 U
NA
NS
NS
79.6
136.3
5.6
NS
1.7 U
NS
NS
NS
2
,7U
1.9
4,
9.7
328 Exceeds VTDEC HeaIth Ad]isory
0.21 U Bo Id value flagged due to b lank contamination from field or eq uipment blank
NS- No sample collected
-------
Table 8
Inorganic and Organic Analytical Data
DSI Missing Link Road Non-Public Water Supply System Wells
Disposal Specialists, Inc. Landfill
Rockingham, Vermont
ABBREVIATIONS
U
Not Detected
UJ
Not Detected, detection limit estimated
J
Laboratory estimated value
J-
Laboratory estimated value, biased low
J+
Laboratory estimated value, biased high
TB
Parameter Detected in Trip Blank
EB
Parameter Detected in Equiment Blank
IGCL
Interim Groundwater Cleanup Levels, established in the 1994 Record of Decision - see Note 2
MCL
Maximum Contaminant Level - see Note 2
-
An IGCL or MCL has not been established
A
Dissolved metals result (field filtered 0.45 micron filter); all other results are for Total Metals
*
The standard listed for lead is an action level, not a Maximum Contaminant Level
su
Standard Units
uS/cm
micro ohms per centimeter
NTU
nephelometric turbidity units
mV
millivolts
ug/L
micrograms per Liter, parts per billion
ND-TIC
Analyte searched for as a Tenatively Identified Compound and Not Detected
NA
Not Analyzed
BOLD
Exceeds EPA MCL and/or Groundwater Clean-up Level
NOTES
1.
All results reported in micrograms per liter (ug/l), unless otherwise specified
2.
US Environmental Protection Agency National Primary Drinking Water Quality Standards Maximum
Contaminant Levels (MCL). *The value for lead is an Action Level, not an MCL.
3.
IGCLs for BFI Rockingham Landfill Superfund Site apply to bedrock compliance monitoring wells. Note
that the values listed reflect the 2014 First Explanation of Siginficant Differences decrease in the IGCL
for arsenic and lead to be consistent with the MCL.
4.
A Tier I Plus data validation was completed on the data reported since June 2014 and laboratory
results were qualified in accordance with the National Functional Guidelines for Superfund Organic
Methods Data Review (lasted revision).
5.
Primary Well #2 water is treated with a particulate filter. Backup Well #3 water treated with an arsenic
& iron treatment system.
6.
Sampler was unfamiliar with new water system plumbing and did not collect an actual post-treament
sample from Backup Well#3 on 9/23/2013. A follow up sample was collected on 11/4/2013 to verify
that treatment system was working properly.
7.
Sampler was unfamiliar with new water system plumbing and did not collect a representative post-
treament sample from Backup Well#3 on 6/10/2014 (insufficient purging of treatment system). A follow
up sample was collected on 9/10/2014.
8.
A follow up pre-treatment and post-treatment sample from Primary Well#2 was collected on
12/15/2015.
9.
All data prior to 2023 was provided to Civil & Environmental Consultants (CEC) by the previous
consulting firm. This data has not been quality checked by CEC.
Page 1
-------
Table 8
Inorganic Analytical Data
DSI Missing Link Road Non-Public Water Supply System Wells
Disposal Specialists, Inc. Landfill
Rockingham, Vermont
Sample Location
Sample Date
interim
Groundwater
Cleanup
Level
MISSING LINK ROAD
MISSING LINK ROAD
MISSING LINK ROAD
MISSING LINK ROAD
MISSING LINK ROAD
MISSING LINK ROAD
EPA MCL
(PRIMARY-WELL 2)
(PRIMARY-WELL 2)
(PRIMARY-WELL 2)
(PRIMARY-WELL 2)
(PRIMARY-WELL 2)
(PRIMARY-WELL 2)
2014/06/10
2014/06/10
2014/06/10
2014/10/15
2014/10/15
2014/10/15
Pre or Post Treatment
(See Note 5)
Pre-Treatment
Post-Treatment
Post-Treatment
Duplicate
Pre-Treatment
Pre-Treatment
Duplicate
Post-Treatment
Arsenic (ug/L)
10
10
10.0 u
10.0U
10.0 u
10U
10U
10U
Barium (ug/L)
2000
1000
200 U
200 U
200 U
200 U
200 U
200 U
Chromium (ug/L)
100
50
10.0 U
10.0U
10.0 U
10U
10U
10U
Iron (ug/L)
-
100 U
100 U
100 U
100 U
100 U
100 U
Lead (ug/L)
15*
15
3.0 U
8.6
9
3 UJ
28.2 J
4.9
Manganese (ug/L)
-
180/ 900
15 U
60.1 J
142 J
15 U
15 U
15 U
Nickel (ug/L)
-
100
40.0 U
40.0 U
40.0 U
40 U
40 U
40 U
Sodium (ug/L)
-
5000 U
5000 U
5000 U
5000 U
5000 U
5000 U
Field Parameters
pH (S.U.)
8.87
8.42
NA
6.56
NA
6.43
Specific Cond. (uS/cm)
95
86
NA
62
NA
61
Temperature (degrees C)
10.9
10.9
NA
11.1
NA
11.2
Turbidity (NTU)
0.24
0.16
NA
0.5
NA
0.09
Oxidation Red. Pot. (mV)
-17
44
NA
207
NA
208
Diss. Oxygen (mg/L)
N
NA N
A N
A N
A N
A
A
Page 2
-------
Table 8
Inorganic Analytical Data
DSI Missing Link Road Non-Public Water Supply System Wells
Disposal Specialists, Inc. Landfill
Rockingham, Vermont
Sample Location
Sample Date
EPA MCL
Interim
Groundwater
Cleanup
Level
MISSING LINK ROAD
(PRIMARY-WELL 2)
2015/06/17
MISSING LINK ROAD
(PRIMARY-WELL 2)
2015/06/17
MISSING LINK ROAD
(PRIMARY-WELL 2)
2015/08/27
MISSING LINK ROAD
(PRIMARY-WELL 2)
2015/08/27
MISSING LINK ROAD
(PRIMARY-WELL 2)
2015/09/30
MISSING LINK ROAD
(PRIMARY-WELL 2)
2015/09/30
MISSING LINK ROAD
(PRIMARY - WELL 2)
2015/12/15
MISSING LINK ROAD
(PRIMARY-WELL 2)
2015/12/15
Pre or Post Treatment
(See Note 5)
Pre-Treatment
Post-Treatment
Pre- Treatment
Post- Treatment
Pre-Treatment
Post-Treatment
Pre-Treatment
(See Note 8)
Post-Treatment
(See Note 8)
Arsenic (ug/L)
10
10
1 U
1 U
2
1
1 U
1 U
1 U
1 U
Barium (ug/L)
2000
1000
2 U
2.4
9
4
2 U
3.4
NA
NA
Chromium (ug/L)
100
50
10U
10U
1U
1U
10U
10U
NA
NA
Iron (ug/L)
-
100 U
215
550
50U
100 U
115
50 U
50 U
Lead (ug/L)
15*
15
7.9
15.6
19
1
5 UJ
5 UJ
NA
NA
Manganese (ug/L)
-
180/ 900
15 U
168
16
5U
15 U
271
5 U
5 U
Nickel (ug/L)
-
100
10U
12.1
2
6
10U
10U
NA
NA
Sodium (ug/L)
-
5000 U
5000 U N
NA
A
5000 U
5000 U N
NA
A
Field Parameters
pH (S.U.)
6.63
6.68
8.11
7.22
7.97
7.21 N
NA
A
Specific Cond. (uS/cm)
83
56
170
135
115
72
NA
NA
Temperature (degrees C)
12.9
12.4
12.9
14.9
13.9
14
NA
NA
Turbidity (NTU)
0.32
0.04
8.51
1.7
0.15
0.19
NA
NA
Oxidation Red. Pot. (mV)
217
192
97
145
98
145
NA
NA
Diss. Oxygen (mg/L)
N
NA N
A N
A N
A N
A N
A N
A
A
Page 3
-------
Table 8
Inorganic Analytical Data
DSI Missing Link Road Non-Public Water Supply System Wells
Disposal Specialists, Inc. Landfill
Rockingham, Vermont
Sample Location
Sample Date
EPAMCL
interim
Groundwater
Cleanup
Level
MISSING LINK ROAD
(PRIMARY-WELL 2)
2016/05/23
MISSING LINK ROAD
(PRIMARY-WELL 2)
2016/05/23
MISSING LINK ROAD
(PRIMARY-WELL 2)
2016/10/19
MISSING LINK ROAD
(PRIMARY-WELL 2)
2016/10/19
MISSING LINK ROAD
(PRIMARY-WELL 2)
2016/10/19
Pre or Post Treatment
(See Note 5)
Pre-Treatment
Post-Treatment
Pre-Treatment
Pre-Treatment
Duplicate
Post-Treatment
Arsenic (ug/L)
10
10
1 U
1 U
1 U
1 U
1 U
Barium (ug/L)
2000
1000
2 U
2 U
1.8
1.8
2.0
Chromium (ug/L)
100
50
10U
10U
1 U
1 U
1 U
Iron (ug/L)
-
100 U
100 U
67.7
32
19.3 U
Lead (ug/L)
15*
15
10U
10U
10U
10U
10U
Manganese (ug/L)
-
180/ 900
15 U
15 U
1.4
0.9
2.5
Nickel (ug/L)
-
100
10U
10U
1.3 U
1.3 U
9.7
Sodium (ug/L)
-
5000 U
5000 U
2120
2210
2180
Field Parameters
pH (S.U.)
N
NA
A
7.91
7.91
7.55
Specific Cond. (uS/cm)
NA
NA
70
70
64
Temperature (degrees C)
NA
NA
12.3
12.3
12.9
Turbidity (NTU)
NA
NA
0.87
0.87
0.4
Oxidation Red. Pot. (mV)
NA
NA
180
180
201
Diss. Oxygen (mg/L)
N
NA N
A N
A N
A
A
Page 4
-------
Table 8
Inorganic Analytical Data
DSI Missing Link Road Non-Public Water Supply System Wells
Disposal Specialists, Inc. Landfill
Rockingham, Vermont
Sample Location
Sample Date
EPAMCL
interim
Groundwater
Cleanup
Level
MISSING LINK ROAD
(PRIMARY-WELL 2)
2017/06/14
MISSING LINK ROAD
(PRIMARY - WELL 2)
2017/06/14
MISSING LINK ROAD
(PRIMARY-WELL 2)
2017/06/14
MISSING LINK ROAD
(PRIMARY-WELL 2)
2017/10/27
MISSING LINK ROAD
(PRIMARY-WELL 2)
2017/10/27
MISSING LINK ROAD
(PRIMARY-WELL 2)
2017/10/27
Pre or Post Treatment
(See Note 5)
Pre-Treatment
Pre-Treatment
Duplicate
Post-Treatment
Pre-Treatment
Pre-Treatment
Duplicate
Post-Treatment
Arsenic (ug/L)
10
10
1 U
1 U
1 U
2.2
1 U
1 U
Barium (ug/L)
2000
1000
2.2
1.8
1.5
10.1
1.8
2.1
Chromium (ug/L)
100
50
1 U
1 U
1 U
3.5
1 U
1 U
Iron (ug/L)
-
247
107
19.3 U
1570
151
35.5
Lead (ug/L)
15*
15
24.7
7.7
3 U
31.5
3 U
9.2
Manganese (ug/L)
-
180/ 900
127
72.8
0.4 U
57.7
3.5
16
Nickel (ug/L)
-
100
38.7
20.3
3
40 U
40 U
45.7
Sodium (ug/L)
-
2170
2100
2130
2550
1870
1840
Field Parameters
pH (S.U.)
7.27
7.27
7.35
7.56
7.56
7.31
Specific Cond. (uS/cm)
123
123
112
190
190
182
Temperature (degrees C)
12.4
12.4
11.8
11.9
11.9
12.1
Turbidity (NTU)
0.51
0.51
0.09
0.9
0.9
0.15
Oxidation Red. Pot. (mV)
138
138
143
156
156
150
Diss. Oxygen (mg/L)
N
NA N
A N
A N
A N
A
A
Page 5
-------
Table 8
Inorganic Analytical Data
DSI Missing Link Road Non-Public Water Supply System Wells
Disposal Specialists, Inc. Landfill
Rockingham, Vermont
Sample Location
Sample Date
EPAMCL
interim
Groundwater
Cleanup
Level
MISSING LINK ROAD
(PRIMARY-WELL 2)
2018/5/22
MISSING LINK ROAD
(PRIMARY - WELL 2)
2018/5/22
MISSING LINK ROAD
(PRIMARY-WELL 2)
2018/5/22
MISSING LINK ROAD
(PRIMARY-WELL 2)
2018/10/18
MISSING LINK ROAD
(PRIMARY-WELL 2)
2018/10/18
MISSING LINK ROAD
(PRIMARY-WELL 2)
2018/10/18
Pre or Post Treatment
(See Note 5)
Pre-Treatment
Pre-Treatment
Duplicate
Post-Treatment
Pre-Treatment
Pre-Treatment
Duplicate
Post-Treatment
Arsenic (ug/L)
10
10
1 U
1
1 U
1 J+
1 U
1 U
Barium (ug/L)
2000
1000
200 U
200 U
200 U
200 U
200 U
200 U
Chromium (ug/L)
100
50
10U
10U
10U
10U
10U
10U
Iron (ug/L)
-
100 U
100 U
100 U
100 U
100 U
100 U
Lead (ug/L)
15*
15
4.4
3 U
4.6
3 U
3 U
3 U
Manganese (ug/L)
-
180/900
15 U
15 U
18.3
15 U
15 U
15 U
Nickel (ug/L)
-
100
40 U
40 U
40 U
40 U
40 U
40 U
Sodium (ug/L)
-
5000 U
5000 U
5000 U
5000 U
5000 U
5000 U
Field Parameters
pH (S.U.)
7.96
7.96
7.9
5.86
5.86
6.22
Specific Cond. (uS/cm)
98
98
63
65
65
62
T emperature (degrees C)
10.1
10.1
10.4
10.9
10.9
11.6
Turbidity (NTU)
0.96
0.96
0.44
0.87
0.87
0.84
Oxidation Red. Pot. (mV)
160
160
189
191
191
218
Diss. Oxygen (mg/L)
N
NA N
A N
A N
A N
A
A
Page 6
-------
Table 8
Inorganic Analytical Data
DSI Missing Link Road Non-Public Water Supply System Wells
Disposal Specialists, Inc. Landfill
Rockingham, Vermont
Sample Location
Sample Date
EPA MCL
Interim
Groundwater
Cleanup
Level
MISSING LINK ROAD
(PRIMARY-WELL 2)
2019/04/15
MISSING LINK ROAD
(PRIMARY-WELL 2)
2019/04/15
MISSING LINK
ROAD (PRIMARY
-WELL 2)
2019/11/25
MISSING LINK ROAD
(PRIMARY-WELL 2
DUPLICATE)
2019/11/25
MISSING LINK ROAD
(PRIMARY-WELL 2)
2019/11/25
MISSING LINK
ROAD (PRIMARY-
WELL 2)
2020/05/04
MISSING LINK
ROAD (PRIMARY -
WELL 2
DUPLICATE)
MISSING LINK
ROAD
(PRIMARY-
WELL 2)
MISSING LINK
ROAD(BACKUP-
WELL 3)
2020/10/20
Pre or Post Treatment
(See Note 5)
Pre-Treatment
Post-Treatment
Pre-Treatment
Pre-Treatment
Post-Treatment
Pre-Treatment
Pre-Treatment
Post-Treatment
Post- Treatment
Arsenic (ug/L)
10
10
1 U
1
1.2
2.6
1U
1 U
1
1 U
1 U
Barium (ug/L)
2000
1000
200 U
200 U
200 U
200 U
200 U
200 U
200 U
204
200 U
Chromium (ug/L)
100
50
10.0U
10U
10.0U
10.0U
10U
10U
10U
10U
10U
Iron (ug/L)
-
100 U
100 U
123J
876J
100 U
100 U
100 U
4450
182
Lead (ug/L)
15*
15
11.1
3 U
4.1J
32.2J
3 U
3 U
3 U
6.7
3 U
Manganese (ug/L)
-
180/900
48.8
15 U
15U
32.3
23.7
15 U
15 U
23900
224
Nickel (ug/L)
-
100
40.0 U
40 U
40U
40.0 U
40 U
40 U
40 U
40 U
40 U
Sodium (ug/L)
-
5000 U
5000 U
5000 U
5000 U
5000 U
5000 U
5000 U
5000 U
5790
Field Parameters
pH (S.U.)
6.84
6.68
7.83
7.83
7.36 N
NA N
A
A
7.3
Specific Cond. (uS/cm)
52
51
79
79
130
NA
NA
NA
72
Temperature (degrees C)
10.1
10.9
9
9
10
NA
NA
NA
13
Turbidity (NTU)
1.11
1.94
<5
<5
<5
NA
NA
NA
<5
Oxidation Red. Pot. (mV)
175
157
101.2
101.2
110.1
NA
NA
NA
-108
Diss. Oxygen (mg/L)
N
NA
A
7.1
7.1
7.1 N
NA N
A
A
8.7
Page 7
-------
Table 8
Inorganic Analytical Data
DSI Missing Link Road Non-Public Water Supply System Wells
Disposal Specialists, Inc. Landfill
Rockingham, Vermont
Sample Location
Sample Date
EPAMCL
interim
Groundwater
Cleanup
Level
MISSING LINK
ROAD (PRIMARY -
WELL 2) 2021/5/13
MISSING LINK ROAD
(PRIMARY-WELL 2
DUPLICATE)
2021/5/13
MISSING LINK ROAD
(PRIMARY-WELL 2)
2021/5/13
MISSING LINK
ROAD (BACKUP
WELL 3)
2021/5/13
MISSING LINK
ROAD (PRIMARY-
WELL 2) 2021/10/5
MISSING LINK ROAD
(PRIMARY - WELL 2
DUPLICATE) 2021/10/5
MISSING LINK ROAD
(PRIMARY-WELL 2)
2021/10/5
MISSING LINK
ROAD(BACKUP-
WELL 3)
2021/10/5
Pre or Post Treatment
(See Note 5)
Pre-Treatment
Pre-Treatment
Post-Treatment
Pre- Treatment
Pre-Treatment
Pre-Treatment
Post-Treatment
Pre- Treatment
Arsenic (ug/L)
10
10
1 U
1 U
1 U
73.6
1 U
1 U
1 U
44.4
Barium (ug/L)
2000
1000
200 U
200 U
200 U
200 U
200 U
200 U
200 U
200 U
Chromium (ug/L)
100
50
10U
10U
10U
10U
10U
10U
10U
10U
Iron (ug/L)
-
100 U
100 U
100 U
8340
100U
100 U
100 U
3660
Lead (ug/L)
15*
15
3.6 J
13.8 J
3 U
5.7
10.8
12.8
3 U
14.1
Manganese (ug/L)
-
180/ 900
15 U
15 U
15 U
39.2
15 U
15 U
17.7
22.7
Nickel (ug/L)
-
100
40 U
40 U
40 U
40 U
40 U
40 U
40 U
40 U
Sodium (ug/L)
-
5000 U
5000 U
5000 U
13200
5000 U
5000 U
5000 U
14500
Field Parameters
pH (S.U.)
6.3
NA
6.6
7.H
6
A
5.9
7
Specific Cond. (uS/cm)
368
NA
75
161
65
NA
55
156
T emperature (degrees C)
11
NA
11
11
12.4
NA
14.3
12.9
Turbidity (NTU)
<5
NA
<5
52
<5
NA
<5
<5
Oxidation Red. Pot. (mV)
66
NA
80
39
162
NA
190
137
Diss. Oxygen (mg/L)
9.8
NA
10
3.1
9.5
NA
9.7
3.2
Page 8
-------
Table 8
Inorganic Analytical Data
DSI Missing Link Road Non-Public Water Supply System Wells
Disposal Specialists, Inc. Landfill
Rockingham, Vermont
Sample Location
Sample Date
EPAMCL
interim
Groundwater
Cleanup
Level
MISSING LINK
ROAD (PRIMARY
WELL 2)
2022/5/11
MISSING LINK ROAD
(PRIMARY-WELL 2
DUPLICATE)
2022/5/11
MISSING LINK
ROAD (PRIMARY
-WELL 2)
2022/5/11
MISSING LINK
ROAD (BACKUP
-WELL 3)
2022/5/11
MISSING LINK
ROAD (PRIMARY
WELL 2)
2022/11/2
MISSING LINK ROAD
(PRIMARY-WELL 2
DUPLICATE)
2022/11/2
MISSING LINK ROAD
(PRIMARY-WELL 2)
2022/11/2
MISSING LINK ROAD
(BACKUP-WELL 3)
2022/11/2
Pre or Post Treatment
(See Note 5)
Pre-Treatment
Pre-Treatment
Post-Treatment
Pre- Treatment
Pre-Treatment
Pre-Treatment
Post-Treatment
Pre- Treatment
Arsenic (ug/L)
10
10
1.0U
1.0U
1.0U
16.2
1.0U
1.0U
1.0U
29.4
Barium (ug/L)
2000
1000
200 U
200 U
200 U
200 U
200 U
200 U
200 U
200 U
Chromium (ug/L)
100
50
10.0U
10.0 U
10.0U
10.0 U
10.0 U
10.0 U
10.0U
10.0 U
Iron (ug/L)
-
100 U
100 U
100 U
1090
100 U
100 U
100 U
2730
Lead (ug/L)
15*
15
3.0 U
3.0 U
3.0 U
27.4
3.0 U
3.0 U
3.0 U
20.9
Manganese (ug/L)
-
180/ 900
15.0 U
15.0 U
15.0 U
15.0 U
15.0 U
15.0 U
15.0 U
15.0 U
Nickel (ug/L)
-
100
40.0 U
40.0 U
40.0 U
40.0 U
40.0 U
40.0 U
40.0 U
40.0 U
Sodium (ug/L)
-
5000 U
5000 U
5000 U
12000
5000 U
5000 U
5000 U
10600
Field Parameters
pH (S.U.)
7.0
NA
8.3
7.4
6.9
NA
7.3
7.1
Specific Cond. (uS/cm)
70
NA
93
134
65
NA
79
140
T emperature (degrees C)
11
NA
11
11
11
NA
12
11
Turbidity (NTU)
<5
NA
<5
16
<5
NA
6
44
Oxidation Red. Pot. (mV)
104
NA
51
44
65
NA
37
96
Diss. Oxygen (mg/L)
10.3
NA
11.1
4.5
10.9
NA
11.0
2.5
Page 9
-------
Table 8
Inorganic Analytical Data
DSI Missing Link Road Non-Public Water Supply System Wells
Disposal Specialists, Inc. Landfill
Rockingham, Vermont
Sample Location
Sample Date
EPA MCL
interim
Groundwater
Cleanup
Level
MISSING LINK ROAD
(PRIMARY-WELL 2)
2023/05/23
MISSING LINK ROAD
(PRIMARY-WELL 2
DUPLICATE)
2023/05/23
MISSING LINK ROAD
(PRIMARY-WELL 2)
2023/05/23
MISSING LINK ROAD
(BACKUP-WELL 3)
2023/05/23
MISSING LINK ROAD
(PRIMARY-WELL 2)
2023/11/14
MISSING LINK ROAD
(PRIMARY-WELL 2
DUPLICATE)
2023/11/14
MISSING LINK ROAD
(PRIMARY-WELL 2)
2023/11/14
MISSING LINK ROAD
(BACKUP-WELL 3)
2023/11/14
Pre or Post Treatment
(See Note 5)
Pre-Treatment
Pre-Treatment
Post-Treatment
Pre- Treatment
Pre-Treatment
Pre-Treatment
Post-Treatment
Pre- Treatment
Arsenic (ug/L)
10
10
1.0U
1.0U
1.0U
38.7
1.0U
1.0U
1.0U
23.9
Barium (ug/L)
2000
1000
200 U
200 U
200 U
200 U
200 U
200 U
200 U
200 U
Chromium (ug/L)
100
50
10.0U
10.0U
10.0 U
10.0 U
10.0 U
10.0 U
10.0 U
10.0 U
Iron (ug/L)
-
100 U
100 U
100 U
1950
100 U
100 U
100U
1420
Lead (ug/L)
15*
15
3.0 U
3.0 U
3.0 U
6.2
3.0 U
3.0 U
3.0 U
7.7
Manganese (ug/L)
-
180/ 900
15.0 U
15.0 U
15.0 U
15.1
15.0 U
15.0 U
15.0 U
15.0 U
Nickel (ug/L)
-
100
40.0 U
40.0 U
40.0 U
40.0 U
40.0 U
40.0 U
40.0 U
40.0 U
Sodium (ug/L)
-
5000 U
5000 U
5000 U
12900
5000 U
5000 U
5000 U
11700
Field Parameters
pH (S.U.)
6.2
NA
7.5
6.6
7.5
NA
5.8
6.0
Specific Cond. (uS/cm)
57
NA
75
152
61
NA
56
156
Temperature (degrees C)
11
NA
12
11
9
NA
8
9
Turbidity (NTU)
<5
NA
<5
24
<5
NA
<5
22
Oxidation Red. Pot. (mV)
133
NA
54
135
-26
NA
84
106
Diss. Oxygen (mg/L)
9.7
NA
10.6
2.5
10.0
NA
9.3
3.2
Page 10
-------
ent
Pre-Treatment Duplicate
Post-T reatment
Pre-T reatment
Post-T reatment
Pre-T reatment
Post-T reatment
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.21 UJ
0.21 UJ
0.21 UJ
0.21 UJ
0.5 U
0.5 U
0.14 UJ
0.14 UJ
0.14 UJ
0.14 UJ
0.5 U
0.5 U
0.14 UJ
0.14 UJ
0.14 UJ
0.14 UJ
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
10 U
10 U
2.5 U
2.5 U
2.5 UJ
2.5 UJ
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
10 U
10 U
2.5 U
2.5 U
2.5 UJ
2.5 UJ
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
10 U
10 U
2.5 U
2.5 U
2.5 UJ
2.5 UJ
10 U
10 U
2.5 U
2.5 U
2.5 UJ
2.5 UJ
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1 U
1 U
0.5 U
0.5 U
0.5* U
0.5* U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
ND-TIC
ND-TIC
0.053 UJ
0.053 UJ
0.053 UJ
0.053 UJ
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1 U
1 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
-------
ent
Pre-Treatment Duplicate
Post-T reatment
Pre-T reatment
Pre-T reatment Duplicate
Post-T reatment
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.21 U
0.21 U
0.21 U
0.21 U
0.21 U
0.14 U
0.14 U
0.14 U
0.14 U
0.14 U
0.14 U
0.14 U
0.14 U
0.14 U
0.14 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5* U
2.5* U
2.5 U
2.5 U
2.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.053 U
0.053 U
0.053 U
0.053 U
0.053 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5* U
0.5* U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5* U
0.5* U
0.5* U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5* U
0.5* U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
-------
Pre-T reatment
Pre-T reatment Duplicate
Post-T reatment
Pre-T reatment
Pre-T reatment Duplicate
Post-T reatment
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
-------
Post-T reatment
Pre-T reatment
Pre-T reatment
Post-T reatment
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
2.5 U
2.5 U
2.5 U
2.5 U
0.5 U
0.5 U
0.5 U
0.5 U
2.5 U
2.5 U
2.5 U
2.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
-------
Pre-T reatment
Post-T reatment
Pre-T reatment
(See Note 2)
Post-T reatment
(See Note 2)
Pre-T reatment
Post-T reatment
0.5 U
1.0 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
2.5 U
100
5.0 U
120
10 U
10 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
2.5 U
5.0 U
5.0 U
5.0 U
10 U
10 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 U N
NA
A
0.5 U
0.5 U
2.5 U
5.0 U
5.0 U
5.0 U
10 U
10 U
2.5 U
68
10 U
30
10 U
10 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
1 U
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0.5 U
1.0 u
2.0 U
2.0 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
ND-TIC
ND-TIC
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 U N
NA
A
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
1 u
1 u
0.5U
0.67
1.2
0.5 U
2
1.9
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.55
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
1 U
1 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
1.0 u
0.5 U
0.5 U
0.5 U
0.5 U
-------
ent
Post-T reatment
Pre-T reatment
Post-T reatment
Pre-T reatment
Post-T reatment
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
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0.5 U
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0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.21 UJ
0.21 U
0.21 U
0.21 U
0.21 U
0.14 UJ
0.14 U
0.14 U
0.14 U
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2.5 U
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20
0.5 U
0.5 U
0.5 U
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2.5 U
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0.5 U
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2.5 UJ
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2.5 U
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7.5*
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0.5 U
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0.5 U
0.5 U
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0.5 U
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0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
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0.5 U
0.5 U
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0.5* U
0.5* U
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0.5 U
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0.5 U
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0.5 U
0.5 U
0.5 U
-------
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Post-T reatment
Pre-T reatment
Post-T reatment
Pre-T reatment
Post-T reatment
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
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0.5 U
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0.5 U
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0.16 U
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2.5 U
23
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0.5 U
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0.5 U
0.5 U
0.5 U
0.5 U
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0.5 U
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0.5 U
0.5 U
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0.58*
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0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
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0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
-------
nent
Pre-T reatment
Post-T reatment
Pre-T reatment
Pre-T reatment
Pre-T reatment
Post-T reatment
0.5 U
0.5 U
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0.5 U
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0.5 U
0.5 U
0.5 UJ
0.5 U
0.5 U
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1.0 U
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0.5 U
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0.5 U
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0.5 U
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0.5 U
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1.0 U
1.0 U
1.0 UJ
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0.5 U
0.5 U
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0.5 U
0.5 U
0.5 U
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0.5 U
0.5 UJ
0.5 U
0.5 U
0.5 U
-------
ent
Post-T reatment
Pre-T reatment
Pre-T reatment
Pre-T reatment
Post-T reatment
Pre-T reatment
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
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0.5 U
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10 U
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2.5 U
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2.5 U
0.5 U
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0.5 U
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0.5 U
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0.5 U
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0.5 U
0.5 U
0.5 U
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0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
10 U
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2.5 U
2.5 U
2.5 U
2.5 U
13
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3.7 U
3.7 U
3.7 U
3.7 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
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0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
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0.5 U
0.5 U
0.5 U
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0.5 U
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0.5 U
1.0 U
1.0 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
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ost-T reatment
Pre-T reatment
Pre-T reatment
Pre-T reatment
Post-T reatment
Pre-T reatment
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
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0.5 U
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0.5 U
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0.5 U
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0.5 U
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0.5 U
0.5 U
0.5 U
2.5 U
2.5 U
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2.5 U
2.5 U
2.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
0.5 U
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0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
3.7 U
3.7 U
3.7 U
3.7 U
3.7 U
3.7 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
0.5 U
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0.74
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APPENDIX D
SITE BACKGROUND
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Civil & Environmental Consultants. Inc.
SITE BACKGROUND
Physical Characteristics
The BFI-Rockingham Landfill Superfund Site (the "Site"), also known as the Disposal Specialist,
Inc. (DS1) Landfill, is located along U.S. Route 5, locally known as Missing Link Road, in the
Town of Rockingham, Windham County, Vermont as shown on Figure 1 in Appendix B. The 17-
acre solid waste landfill is located on a terrace approximately 500 feet from and 200 feet higher in
elevation than the Connecticut River floodplain and wetlands are present at the base of the steep
slopes at the bank of the Connecticut River. However, wetlands and floodplain areas are not
present with the 25-acre area that encompasses the landfill and operating facility, which consists
of an office building, garage, former solid waste transfer station with associated former storage
areas, and landfill gas management system. The Site includes the landfill area and the abutting
rural residential areas impacted by the Site as shown on Figure 2. Sampling locations including
the Missing Link wells and water supply system are also shown on Figure 2.
Geology
The landfill occupies approximately 17 acres and is situated on a glacial terrace located along
the west side of the Connecticut River. Geological cross sections prepared as part of the Rl/FS
are included as Figures 3 and 4 in Appendix D. Most waste within the landfill is underlain by a
relatively thin layer of sand deposits overlying varved lacustrine deposits comprised of
interbedded clay and silt. The lacustrine deposits and bedrock are generally separated by a sandy
glacial till unit. From top to bottom the overburden sediments include a sand and silty sand,
varved clayey silt, silty sand grading downward to sand and glacial till. Overburden sediments
are approximately 200 feet thick on the southeast side of the landfill, with little or no overburden
present on the northwest side of the landfill.
Bedrock under the Site consists of moderately fractured black and gray phyllite and slate of the
Littleton Formation. Sulfide minerals are present within fractures, and fractures in rock core and
outcrops were frequently coated with reddish brown oxides. The dominant fractures within the
bedrock are foliation parallel and are near-vertical to steeply dipping and north-northeast
trending. A less common cross- foliation fracture population oriented perpendicular to foliation
that are much shorter in length than foliation-parallel fractures. In some areas, located along the
west side of the landfill, waste may be situated in close proximity to bedrock and precipitation
percolating through the waste mass in these areas may infiltrate into the fractured bedrock.
Hydrology
31 Bellows Road, Raynham, MA 02767 | 2 Corporation Way, Suite I 60, Pea body, MA 0 I 960
p: 774-501-2176 f: 774-501-2669 | www.cecinc.com
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CEC Project 337-300
Page 2
The varved lacustrine deposits underlying the majority of the landfill impedes the
vertical/downward migration of water beneath the landfill resulting in predominantly horizontal
flow within the overlying sand deposits. As shown on the interpreted potentiometric surface
contour map for shallow overburden groundwater (Figure 4 in Appendix B), overburden
groundwater at the Site flows easterly towards the Connecticut River. Groundwater elevations at
shallow and deeper overburden well couplets indicate that there is a component of downward flow.
Water levels in shallow overburden declined after the installation of the landfill cap; however,
water levels in deeper overburden (varved lacustrine deposits) did not respond significantly to
landfill capping.
The majority of the impacted shallow overburden groundwater is currently intercepted by the
Route 5 Seepage Control and Stabilization System (Route 5 System) located on the western side
of Route 5, which was constructed to collect groundwater formerly discharging to a drainage
ditch via seeps along Route 5. The base of the trench intersects the geological transition from
fine sands to laminated/varved sands to 1 aminated/varvedclayey silt at an elevation of 420 feet
NGVD. Groundwater collected by the Route 5 System is disposed at an off-site disposal facility.
The Route 5 System intercepted the majority of the seeps identified in the RI, however, one
impacted seep (Seep SW-6) continues to flow on a seasonal basis. The occurrence of flow at this
location has appeared to decrease significantly over time in in relation to installation of the cap
and seepage control system.
Interpreted potentiometric surface contour maps for shallow bedrock and deeper bedrock are
included as Figure 6 and Figure 7 in Appendix B, respectively. Shallow bedrock is represented
by monitoring wells generally screened within the upper 10 feet ofbedrock, while deeper bedrock
wells are generally screened greater than 50 feet from the bedrock surface. On a site-wide scale
the horizontal component of groundwater flow in shallow and deeper bedrock flows is to the
southeast toward the Connecticut River. However, while Figures 6 and 7 provide the general
direction of groundwater flow, the actual flow pathways in bedrock are likely more complex
because flow in fractured bedrock is strongly controlled by the number, aperture (size),
orientation and interconnectivity of bedrock fractures, as well as the tortuosity of flow paths
within individual fractures. Bedrock ground water discharges to the Connecticut River valley
located approximately 500 feet to the east of the landfill boundary.
Land and Resource Use
The land use within a one-mile radius of the Site supports primarily low-density rural residential
housing, light agriculture, undeveloped forest land and commercial activities. Approximately
2,700 people live within one mile and 6,400 people live within three miles of the Site. The PRPs
supply water via the Missing Link Road Non-Public Water System to four residential properties
located between the landfill and the Connecticut River. Several private residential water supply
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CEC Project 337-300
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wells in the vicinity of the Site are sampled periodically. Natural resources near the Site include
groundwater, surface water, fish and game, arable land, forest, woodland and minerals.
The current and future land use of the landfill itself is non-residential because of the
impracticability of constructing residences on a closed sanitary landfill. Current land-use
restrictions prevent development that could damage the landfill cap. The areas surrounding the
landfill are considered residential.
However, much of the area surrounding the landfill is not suitable for development due to steep
topography, proximity of floodplains and development setbacks from the Connecticut River.
Groundwater usage restrictions (groundwater reclassification and Water Supply Agreements
recorded at the Registry of Deeds) have been established to restrict the use of groundwater at
properties located downgradient of the DSL Landfill. Water Supply Agreements have been
recorded at the Registry of Deeds for the four residences that the PRPs supply potable water to
via the Missing Link Road Non- Public Water System. The groundwater aquifer below the
landfill property and properties located between the landfill and the Connecticut River was
reclassified from Class 111 to Class IV groundwater by VTANR on March 10, 2009 (amended
November 6, 2013). Class IV groundwater is not suitable for potable use. The current ICs
(groundwater reclassification. Water Supply Agreements and deed restrictions on BFI-owned
property) established to restrict the use of bedrock groundwater at properties located
downgradient of the landfill area and within the Site-related impacted groundwater area are
protective of human health and documented in the 2014 ESD.
Prior to the implementation of the site remedy, an Ecological Risk Assessment, as discussed in
the ROD, concluded that high aluminum, chromium, iron and lead concentration in the
Connecticut River that were attributable to seeps within the hydraulic influence of the landfill
posed a threat to ecological receptors in the Connecticut River. However, the installation of the
Route 5 System eliminated the majority of the seepage areas, and monitoring results from
Connecticut River samples collected during long-term monitoring activities have met ambient
water quality criteria for many years, which indicate the landfill is not adversely affecting the
Connecticut River.
History of Contamination
Prior to the 1960's, the Site was an undeveloped woodland. Landfill operations at the Site first
started in 1968 (under the ownership of Harry K Shepard, Inc.) following the removal of
significant quantities of borrow material (fill) from the property for the construction of Interstate
91. In 1969, Harry K Shepard, Inc. deeded the landfill to Disposal Specialist, Inc., and Harry K
Shepard, Inc. was continued as a solid waste and industrial waste hauling company. The DSI
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CEC Project 337-300
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landfill and Harry K Shepard, Inc. were acquired by Browning-Ferris Industries, Inc. (BF1) in
1973, and Harry K Shepard, Inc. subsequently changed its name to Browning-Ferris Industries
of Vermont, Inc. (BFI-VT).
From 1968 until 1991, the landfill received residential, commercial and industrial solid and liquid
waste. Approximately 1.2 million cubic yards of solid waste were disposed in the landfill during
its operation. The majority of wastes were placed in unlined landfill cells, with the exception that
municipal incinerator ash was placed in a lined monofill cell located in the southeastern section
of the landfill from 1986 to 1989. The monofill cell was capped in 1989. Wastes continued to be
disposed in the unlined landfill cells until landfilling activities at the Site ceased in November
1991.
In 1989, BFI-VT installed an active landfill gas collection system to comply with the Vermont
air pollution control regulations. Landfill gas is extracted from numerous gas extraction wells
through an underground piping network and landfill gas is subsequently combusted at an on-
site flare. The landfill gas collection and treatment system is currently operated and maintained
pursuant to a permit issued by the Vermont Air Pollution Control Division.
Neighbors began reporting potential groundwater quality impacts in 1977. In 1979, VTDEC
collected and analyzed drinking water samples from six bedrock water supply wells located in
the vicinity of the landfill. Metals and volatile organic compounds (VOCs) consistent with
impacts attributable to the DSI landfill were reported in some of the bedrock water supply wells
sampled, and the State of Vermont required DSI to provide residences located east of the landfill
with bottled water for potable use. In 1980, a new water supply well was installed on DSI property
and a distribution system was constructed to serve residents previously supplied with bottled
water. DSI entered into an agreement to continue to supply
off-site residences until EPA and VTDEC determine that the water beneath the residences is
acceptable for use as a water supply.
In the past, the overburden groundwater in the immediate vicinity of the landfill contained VOCs,
SVOCs and metals attributable to the landfill. The overburden contamination was limited to the
area east and hydraulically downgradient of the landfill and the east side of Route 5.
Contaminants at shallow depths (in sandy overburden above varve lacustrine sediments)
extended short distances to discharge points (seeps) at the top of ravines adjacent to the east side
of Route 5 (EPA, 1994).
A shallow overburden groundwater collection trench (the Route 5 Seepage Control and
Stabilization System, the "Route 5 System") was constructed in the fall and winter of 1992 to: 1)
collect groundwater seepage discharging within the storm water drainage ditch to the east of the
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landfill and immediately adjacent to Route 5; 2) reduce seepage below Route 5; and 3) reduce
soil pore water pressure in a localized area along Route 5 to enhance the integrity of the proposed
site remedy. The trench is bounded by sheet piling driven to an elevation of approximately 400
feet NGVD. The Route 5 System eliminated all but one seepage area (Seep SW-6) along Route
5 and has effectively removed impacted groundwater from the Site. A small amount of impacted
groundwater currently discharges seasonally to Seep SW-6 on the east side of Route 5. However,
constituents of concern in Seep SW-6 have been reported at concentrations below applicable
storm water standards.
Bedrock groundwater between the landfill and the Connecticut River also contained VOCs,
SVOCs and metals consistent with a release from the landfill. However, concentrations were
significantly lower than in overburden. Arsenic and manganese were the primary contaminants of
concern in bedrock groundwater, which occur naturally in the bedrock fracture fillings, and were
mobilized by a reducing condition attributable to the landfill.
Initial Response
The State of Vermont has regulated the landfill"s operations under the Vermont solid waste
management program since 1968. In 1979, VTDEC collected and analyzed groundwater samples
from six bedrock wells in the vanity of the landfill. Because those samples were found to be
contaminated by the landfill, the VTDEC required DSI to supply nearby residences with bottled
water. In 1980, a new water supply well was installed on DSI property to service the residences
via a water supply line. DSI entered into a water supply agreement with affected property owners
to maintain the water line and provide potable water until VTDEC and EPA determine that
groundwater on the properties is acceptable for use as a water supply (EPA, 1994). In 2014, BFI-
VT/DSI was continuing to supply potable water to the residences and maintain the water line.
A series of Assurance of Discontinuance Agreements between DSI and VTDEC required DSI to
demonstrate that the landfill would not further degrade groundwater or surface water quality in
the vicinity of the landfill. Consequently, beginning in 1979 a series of hydrogeological
investigations were performed to investigate groundwater flow and water quality conditions at
the landfill. In October 1989, the site was included on the EPA National Priorities List (NPL).
During the spring of 1992, DSI and BFI-VT, the two Potentially Responsible Parties (PRPs)
initiated negotiations with EPA to conduct a Remedial Investigation and Feasibility Study
(RI/FS) in accordance with NCP requirements. An Administrative Order (AO), EPA Docket
No. 1-92-1053, for RI/FS activities was executed by the PRPs in July 1992 and became effective
August 8, 1992. Pursuant to the AO, a shallow overburden groundwater collection trench (the
Route 5 Seepage Control and Stabilization System, the "Route 5 System") was constructed in
the fall and winter of 1992.
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As part of the Superfund Accelerated Cleanup Model, EPA initiated a non-time critical removal
action (NTRCA) for the Site in December 1992. In February 1993, EPA required the PRPs to
prepare an engineering evaluation / cost analysis under the existing RI/FS Order to support the
selection of a NTCRA for the Site. EPA signed an Action Memorandum on September 13, 1993
to initiate a NTCRA to install a multi-layer landfill cap and expand the active landfill gas
collection and treatment system.
The landfill cap and landfill gas collection and treatment system designs were completed in June
1994. Construction of the NTCRA was initiated in April 1994 and completed in July 1995.
On September 21, 1994, the EPA issued the Record of Decision (ROD) for the Site describing
remedial actions implemented and the basis for the selected site remedy; no further construction
activities were required under the ROD. The selected site remedy identified in the ROD called for
long-term monitored natural attenuation of surface water and groundwater quality impacts,
maintenance of the multi-layer cap and landfill gas extraction system, and the continued operation
and maintenance of the off-site potable water supply line, lined ash monofill cell leachate
collection system and the Route 5 System. The ROD established IGCLs for bedrock groundwater
based on the cumulative carcinogenic and non-carcinogenic risks posed to individuals drinking
bedrock groundwater. Due to the limited extent and low yield, overburden groundwater was not
considered to be a potential drinking water source or a current or future human exposure pathway;
therefore, IGCLs were not established for overburden groundwater.
The Consent Decree (CD) was executed by EPA on May 22, 1996 which established requirements
related to the operation and maintenance of the components of the site selected remedy, the
framework for the long-term monitoring activities and established interim goals (comparison
levels) for assessing the restoration of bedrock groundwater quality.
Basis for Taking Action
A Remedial Investigation (RI) was performed at the Site from 1992 to 1994 (Balsam 1993 &
1994). The RI identified the landfill as the source of contamination found in bedrock and
overburden groundwater downgradient of the Site. Surface water in the drainages along Route 5
was found to also contain Site- related contaminants. Table A-1 summarizes the contaminants in
groundwater identified during the RI (EPA, 1994)
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Table A-1
Remedial Investigation Groundwater Contamination Summary
Contaminant of
Concern
Interim
Groundwater
Cleanup Level
(IGCL)
Average
Concentration
(ug/L)
Maximum
Concentration
(ug/L)
Frequency of
Detection
2-Butanone
170*
18
370
2/34
Antimony
6
14
28
1/32
Arsenic
50*
49
282
18/32
Barium
1,000*
303
1,850
30/32
Benzene
5
6
17
10/34
Bis (2-
chloroisoproyl) ether
1 *
11
100
1/33
Bis (ethylhexyl)
phthalate
6
8
62
10/33
Chromium
50*
5
81
5/32
Manganese
180*/900* *
1,020
5,830
28/32
Nickel
100
30
102
14/32
Pentachlorophenol
1
3
3
1/34
Tetrachloroethylene
0.7*
5
12
2/34
Xylene, total
400*
82
1,200
11/34
Vinyl chloride
2
4
6
3/34
* Current Federal/State standards (ARARs) have been revised for the contaminants of
concern indicated.
** The cleanup level for manganese is 180 ug/L unless manganese is the only metal above
the cleanup level, then a cleanup level of 900 ug/L is used.
REMEDIAL ACTIONS
Remedy Implementation
No construction activities were required by the ROD. A long-term monitoring plan was
approved by EPA in May 1996. The Institution Controls were completed in June 1996 by a
"Grant of Environmental Restrictions and Right of Access" for seven parcels of land, including
the landfill and adjoining areas.
The deed restrictions affect seven parcels of land, which have been subsequently combined
and/or subdivided into three parcels of land (as listed in Table 1 in the main body of the SYR).
The following is a summary of the IC requirements, with parcel identification numbers updated
per Summit (2012e):
The Capped Area (capped portion of Parcel 4-505-894): In this area, uses are
prevented that disturb the integrity of the landfill cap, the leach ate collection system,
the landfill gas management system, orany or any other structures (e.g. Route 5
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System groundwater collection trench) for maintaining the effectiveness of the
Removal/Remedial Action.
The Groundwater Restriction Area (Parcel 4-107-032. and portions of Parcels 4-
505-890 and 4-505- 894): This area is defined as a portion of the Site where
contaminants were detected above groundwater cleanup levels during the RI. In this
area, use for groundwater as a drinking supply is prohibited.
The Waterline Restriction Area: Alterations or disturbances to the waterline that
supplies potable water to residential properties are prohibited in this area. The
restrictions apply to the water line supply well and all structures and equipment
related to it, as well as the water line itself.
Additional Restrictions (Parcels 4-505-890. 4-505-894 and 4-107-032): Activities and
uses that disturb the Removal Action and Remedial Action, as defined in the ROD,
are prohibited in this area. EPA signed a Preliminary Closeout Report for the entire
Site (NTRCA and Remedial Action) in September 1996 upon completion of the cap,
which confirmed that no additional monitoring wells or other construction activities
were necessary at the Site.
The ROD anticipated that IGCLs would be achieved 15 years after completion of the NTCRA.
Long- term monitoring activities have shown significant improvements in groundwater and
surface water quality following construction the NTCRA. Results from the Fall 2008 Setni-
Annual Long-Term Monitoring Report indicated that the IGCLs had been met at many Site
monitoring wells. However, review ofsample results over time indicated IGCLs for benzene, total
xylenes, tetrachloroethene, methylene chloride, 2- butanone, vinyl chloride, arsenic, manganese,
barium and chromium may not be met for bedrock groundwater at some bedrock compliance
wells located hydraulically downgradient of the landfill within the 15-year restoration estimate
contained in the ROD and a Technical Impracticability (Tl) waiver was considered for the Site
in 2009.
In the spring of 2009, following receipt of the Fall 2008 Semi-Annual Long-Term Monitoring
Report (URS, 2009) results, EPA and BF1-VT entered into discussions regarding the need to
conduct additional investigation to further evaluate the status of the natural restoration component
of the site remedy, in support of an adjustment to the ROD (completion of an ESD). EPA and
BF1-VT concurred that IGCLs would not likely be achieved in the 15-year time frame specified
in the ROD (i.e., by 2010) at some bedrock wells and that meeting arsenic and manganese IGCLs
would be problematic due to the naturally occurring presence of these metals in bedrock fracture
fillings, therefore a Technical Impracticability (Tl) waiver was considered for the Site.
Subsequently, BFI-VTs consultant Summit Environmental Consultants, Inc. (Summit) prepared
a Field Investigation Work Plan (Summit 2009), to support a Tl evaluation. In support of the Tl
evaluation, temporary modifications to the water quality sampling locations and parameters
specified in the LTMP were proposed. The temporary modifications to the LTMP were
subsequently approved by EPA and sampling activities were performed according to a modified
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sampling program during the semi-annual monitoring events in 2009 and 2010.
Subsequent discussions within EPA determined that the TI waiver was not the preferred method
of addressing the 15-year ROD requirement for ground water restoration in bedrock wells.
Subsequently, EPA requested that BF1-VT prepare an Investigation Plan as discussed in Section
V-2 of the SOW. Summit prepared an Investigation Plan (Summit 2012) that included additional
response actions to be undertaken to ensure the continued protection of human health and the
environment. EPA issued an approval of the Investigation Plan in a letter dated February 16,
2012. The additional actions implemented in the plan and subsequent investigation are
summarized below:
The Conceptual Site Model (CSM) to assess water quality trends, changes in Site
conditions and the potential for the Site to meet cleanup goals in the future (Summit
2012c) were updated.
Potential vapor intrusion pathways related to structures located downgradient of the
landfill (Summit 2012d, 2014b) were evaluated. Vapor Intrusion pathways were
assessed based on results from soil vapor/gas and groundwater sampling results from
semi-annual sampling events in 2014 which were reported in 2015.
Binding provisions to supply potable water to the landowners on the properties
downgradient of the landfill until cleanup goals were met (Summit 2014d).
It was confirmed that the water supply system installed to serve off-site residences
meets existing codes for public water lines. It should be noted that although the existing
water supply system does not meet the definition of a Public Water Supply (PWS) and
is therefore not regulated by the State of Vermont.
The State of Vermont expanded the Groundwater Reclassification Zone boundary to
include two additional properties to the north of the existing boundary. VTANR (2013)
amended the existing Class IV reclassification zone and buffer area to included two
additional properties north of the existing boundary based on Summit (2012e).
A review of the groundwater quality monitoring program was done to determine what
monitoring was needed until cleanup criteria are met. Subsequently, an updated long-
term monitoring program was completed after the 2014 Five Year Review and put in
place in 2015 for the next FYR completed as part of this document.
Results of the Investigation Plan, completed under SOW Section V-2, formed the basis for the
EPA Declaration for the Explanation of Significant Differences (ESP) for the Site completed in
September 2014. The ESD was done to address why the bedrock groundwater cleanup at the site
had not met the IGCLs established in the ROD within 15-years. The ESD also revised the IGCLs
for arsenic and lead because of changes in federal and state standards for those chemicals. In
addition, the ESD documented the expanded institutional control of groundwater reclassification
done by the State of Vermont to prevent groundwater use at the site.
Revised Timeframe for the Restoration of Bedrock Groundwater
-------
CEC Project 337-300
Page 10
The timeframe for the restoration of bedrock groundwater was evaluated using long-term
monitoring data (Summit 2014b). This evaluation determined that VOCs concentrations at
bedrock compliance wells have decreased to concentrations at or approaching the IGCLs, such
that they are no longer considered to be a driving factor for predicting the timeframe for the
restoration of bedrock groundwater quality at the Site, and that the naturally occurring metals,
arsenic and manganese, are the principle constituents of concern requiring an extended period of
time to restore bedrock groundwater to the IGCLs established in the ROD. It is noted that similar
challenges in achieving groundwater cleanup goals for arsenic and manganese have been
observed at other landfill/CERCLA sites in New England due to their sensitivity to geochemical
conditions within an aquifer, particularly the oxidation or reduction state.
Data for arsenic and manganese in bedrock groundwater were assessed in 2014 and statistically
significant decreasing trends for manganese at selected wells were used to estimate the timeframe
for bedrock restoration in the ESD. It was noted that no long-term statistically significant trends
were apparent for the arsenic data set; however, as discussed in the CSM Update (Summit 2012c),
the mobility/solubility of arsenic, iron and manganese in groundwater are strongly controlled by
redox sensitive microbial-mediated geochemical processes, and concentrations of redox sensitive
metals will decrease as conditions transition to a more oxidizing environment. Given the
limitations in the arsenic data set and similarity of factors controlling the mobility/solubility of
arsenic and manganese, it is assumed that arsenic concentrations should achieve the IGCL (or
background concentrations) within a similar timeframe as manganese.
Based on the assumptions used in the evaluation for the timeframe predictions, restoration of
bedrock groundwater to the IGCLs established in the ROD will likely be achieved between 2050
and 2070, while the IGCLs established in the ROD for VOCs will likely be achieved by 2025.
Based on the data from the past 5-years, the assumptions and estimates are reasonable and appear
on track with the predictions with the exception of VOCs which will likely not achieve the IGCLs
by 2025.
However, as with all time frame estimations, they are subject to change based on the future
monitoring results, revisions to cleanup standards (e.g., updated IGCLs to current EPA/VTDEC-
standards), limitations in the dataset and limitations of statistical tools.
-------
CEC Project 337-300
Page 11
System Operation/Operation and Maintenance
Operation costs for the previous SYR period 2019-2023 are summarized below.
Table B-l
Annual Operations/O&M Costs
(BFI-VT, 2024, written communication)
Year
System Operation Cost
2023
$204,696
2022
$195,914
2021
$197,226
2020
$381,244
2019
$368,337
The original O&M cost prediction provided in the 1994 ROD for post closure O&M for a period of 5 to
30 years after the completion of the NTCRA ranged from $90,000 to $200,000 per year.
-------
ฆMW-A11
500
> 450-
300 -
SOURCE: BALSAM ENVIRONMENTAL CONSULTANTS,
FROM A PLAN ENTITLED "CONCENTRATION
DISTRIBUTION OF TOTAL IRON IN GROUND WATER.
CROSS SECTION 1-1" DATED 4/18/94.
NOTES:
D
CONCEPTUALIZED STRATIGRAPHY BASED ON
UMITED SUBSURFACE DATA COLLECTED FROM
BORINGS ADVANCED FROM 1977 THROUGH 1992.
IN ADDITION, SEVERAL PRIVATE RESIDENTIAL WELL
LOGS WERE INCLUDED.
2) SURFACE ELEVATION OF REFUSE REFLECTS
CONDITIONS PRIOR TO REGRADE AND CAPPING.
500
250
n i 1 1 1 1 1 1 1 i 1 i 1 1 1 1 : 1 r
0 100 200 300 400 500 BOO 700 800 900 1000 1100 1200 1300 1400 1500 1600 1700 1800 1900
LEGEND
DISTANCE (FEET)
REFUSE
SAND
SILT WITH SAND
(VARVED LACUSTRINE)
CLAYEY SILT
(VARVED LACUSTRINE)
ROCK FRAGMENTS AND
SILT (BASAL TILL)
BEDROCK
SCREENED INTERVAL
PROJECTED MONITORING WELL
DISTANCE > 50 FEET FROM
CROSS SECTION UNE
1" = 100' VERT
0 100 ฃ00 400
1" = 200' HORZ
project in!-: DISPOSAL SPECIALISTS, INC. LANDFILL
MISSING LINK RD (ROUTE 5) - ROCKINGHAM, VERMONT
FIGURE 3
BV: SBM/JNB
D-SCRIP I ION:
CES~
DATE: 2019-07-03
REV DATE:
GEOLOGICAL CROSS SEECTION A-A'
JH: 10338.029
APP30MBY: ^
SSU-
SC4L": AS NOTED
CHiCK-.D BY:
SSUi BAIi;
Engineers Environmental Scientists Surveyors
-------
SOURCE: BALSAM ENVIRONMENTAL CONSULTANTS,
FROM A PLAN ENTITLED "CONCENTRATION
DISTRIBUTION OF TOTAL IRON IN GROUND WATER,
CROSS SECTION 1-1'", DATED 4/18/94.
NOTES:
1)
CONCEPTUALIZED STRATIGRAPHY BASED ON
LIMITED SUBSURFACE DATA COLLECTED FROM
BORINGS ADVANCED FROM 1977 THROUGH 1992.
IN ADDITION, SEVERAL PRIVATE RESIDENTIAL WELL
LOGS WERE INCLUDED.
2) SURFACE ELEVATION OF REFUSE REFLECTS
CONDITIONS PRIOR TO REGRADE AND CAPPING.
LEGEND
REFUSE
SAND
SILT WITH SAND
(VARVED LACUSTRINE)
CLAYEY SILT
RVED LACUSTRINE)
X FRAGMENTS AND
r (BASAL TILL)
200
1R0CK
iEENED INTERVAL
1400
I PROJECTED MONITORING WELL
I DISTANCE > 50 FEET FROM
CROSS SECTION LINE
project in!-: DISPOSAL SPECIALISTS, INC. LANDFILL
MISSING LINK RD (ROUTE 5) - ROCKINGHAM, VERMONT
FIGURE 4
BV: SBM/JNB
D-SCRIP I ION:
CES~
DATE: 2019-07-03
REV DATE:
GEOLOGICAL CROSS SEECTION B-B'
JH: 10338.029
APP30MBY: ^
SSU-
SC4L": AS NOTED
CHiCK-.D BY:
SSUi BAIi;
Engineers Environmental Scientists Surveyors
-------
APPENDIX E
CHRONOLOGY
-------
DATE
SITE-RELATED ACTIVITY
1960s
Site location used as a borrow pit.
1968
DSI landfill begins operation after closure of "Old Springfield Landfill."
1973
BFIVT acquires DSI.
1980
Water supply well installed to serve the facility and adjacent residents.
1986-1989
Municipal incineration ash disposed in a 1.5-acre lined cell at landfill.
1989
DSI landfill is added to National Priorities List as BFI Sanitary Landfill.
1989
BFI installs an active gas collection system to limit migration of landfill gas.
1991
Landfilling activities at the Site cease.
1992
USEPA enters into agreement with DSI and BFI VT to perform Site wide investigation.
1993
USEPA signs first cleanup decision, Action Memorandum, to initiate aN NTCRA to
place a cap on the landfill and expand gas collection and treatment system.
1994
USEPA signed second cleanup decision, ROD, identifying Long-term Monitoring
and Natural Attenuation as the long-term groundwater cleanup approach.
1996
NTCRA certified by USEPA as completed (landfill cap, expanded active gas collection
system, groundwater interceptor trench).
1996
USEPA enters into agreement with DSI and BFI VT to perform long-term monitoring.
1999
USEPA performs first FYR
2004
USEPA performs second FYR.
2008
State of Vermont reclassifies groundwater affected by the DSI Site at Class IV groundwater
to limit groundwater extraction for potable use.
January 2009
The Fall 2008 Semi-annual Long-term Monitoring Report indicates that the cleanup criteria
would not be met for bedrock groundwater at some monitoring points with the 15-year
timeframe specified in the ROD.
-------
DATE
SITE-RELATED ACTIVITY
June
2009
BFIVT proposed a Technical Impracticability (TI) waiver for the Site and submitted an
investigation plan in support of a TI waiver.
September
2009
USEPA performs third FYR.
2009-2010
USEPA approved temporary modifications to LTMP to support a TI waiver.
October 2011
USEPA determines that a TI waiver is not preferred for the DSI Site and request that BFI
VT submit an Additional Investigation Plan as specified in the Statement of Work included
in the 1994 Consent Decree and ROD.
January 2012
BFI VT submits Additional Investigation Plan, which is subsequently approved by USEPA.
August 2012
BFI VT submits Additional Investigation Plan reports: Conceptual Site Model Update and
Vapor Intrusion Evaluation.
2012
BFI VT performs (as part of the Additional Investigation Plan) a regulatory review and
physical evaluation of the water system originally installed in 1980 to serve off-site
residents. Upgrades and improvements are made including an iron and arsenic removal
system, installation of particulate filters and reconfiguration of the conveyance system to
allow better access to Primary and Backup supply wells.
November
2012
BFI VT submits draft petition to the State of Vermont to revise/expand the extent of the
groundwater reclassification area to correct for inaccurate boundaries included in the
original 2008 reclassification petition.
April 2013
BFI VT extends water supply line to serve one additional property (Rumrill) on River Front
Drive because BFI VT proposed that the State of Vermont expand the groundwater
reclassification zone buffer to include the Rumrill property in November 2012 and because
in Spring of 2013, Mr. Rumrill requested that BFI VT extend the water line because his
spring water source (located on BFI VT property outside of the groundwater
reclassification/buffer zone) was not operable.
June 2013
BFI VT submits DSI Missing Link Road Non-Public Water System Operation and
Maintenance Manual (as part of Additional Investigation Plan).
October 2013
BFI VT submits copies of Water Supply Agreements recorded with landowner deeds to
USEPA (as part of the Additional Investigation Plan).
November
2013
State of Vermont revised/expanded the extent of the groundwater reclassification area to
correct for inaccurate boundaries included in the original 2008 reclassification petition
(based on information provided by BFI VT in November 2012). This was done to fulfill
portions of the Additional Investigation Plan.
March 2014
USEPA issues comments on the August 2012 Vapor Intrusion Evaluation and requests a
vapor intrusion investigation work plan be developed, and that a new QAPP be prepared for
sampling activities being conducted in 2014 as part of the FYR sampling requirements and
soil vapor sampling activities.
-------
DATE
SITE-RELATED ACTIVITY
September
2014
USEPA performs fourth FYR.
February 2015
Fall 2014 FYR Semi-annual Monitoring Report prepared to document the results of the
September 2014 Five Year Review sampling event. Report provided a discussion of the
results of environmental monitoring activities completed in 2014.
April
2015
Proposed 2015-2018 LTMP Revision.
August 2015
USEPA issues comments on the 2014 Vapor Intrusion Investigation Summary Report. 2015
Vapor Intrusion Investigation Summary Report to present the results of a vapor intrusion
investigation completed at the DSI Site in 2014 and 2015 including USEPA comments and
a third round of data collected in June 2015.
September
2015
Spring 2015 Semi-annual Monitoring Report prepared to provide the results of the June
2015 sampling event completed at the DSI Site.
March 2016
2015-2018 LTMP Revision approved by USEPA
September
2016
2016 Site Specific QAPP, approved by USEPA.
April
2019
2019 Site Specific QAPP, approved by USEPA.
September
2019
USEPA performs fifth FYR.
October 2019
2019 Site Specific QAPP Minor Revisions, approved by USEPA.
May 2021
2021 Site Specific QAPP Minor Revisions; LTMP Revision.
October 2023
2023 Site Specific QAPP Minor Revisions; LTMP Revision.
April 2024
2024 Site Specific QAPP Minor Revisions; LTMP Revision.
-------
APPENDIX F
PUBLIC NOTICE PRESS RELEASE
-------
An official website of the United States government
Q.
News Releases: Region 01
MENU
CONTACT US
EPA to Review Cleanups at Six
Vermont Superfund Sites this Year
February 1, 2024
Contact Information
James Anderson (anderson.james.r@epa.gov)
(617)918-1401
BOSTON (Feb. 1, 2024) - The U.S. Environmental Protection Agency (EPA) will conduct
comprehensive reviews of completed cleanup work at six National Priorities List (NPL) Superfund
sites in Vermont this year.
Each individual site will undergo a legally required Five-Year Review to ensure that previous
remediation efforts at the sites continue to protect public health and the environment. Once the Five-
Year Review is complete, its findings will be posted to EPA's website in a final report.
"Every step of the process at a Superfund site is critical and reflects a commitment we make with
local communities to be as thorough as possible. Cleaning up hazardous waste sites takes extensive
time and effort, and these Five-Year Reviews allow EPA to ensure our cleanup efforts continue to
protect public health and the environment, while keeping everyone informed and accountable,
especially in those communities that have been overburdened by industrial pollution." said EPA New
England Regional Administrator David W. Cash. "EPA continues to evaluate these cleanups, with
the overarching mission to protect public health and the environment and ensuring that Vermont
communities will continue to be protected."
In 2024 EPA will conduct Five-Year Reviews at the below listed sites. The included web links provide
detailed information on site status as well as past assessment and cleanup activity.
Five-Year Reviews of Superfund sites in Vermont to be completed in 2024:
Parker Sanitary Landfill, Lyndonville
Bennington Municipal Sanitary Landfill, Bennington
-------
Tansitor Electronics, Inc., Bennington
Elizabeth Mine, Strafford
BFI Sanitary Landfill (Rockingham), Rockingham
Pownal Tannery, Pownal
More information:
The Superfund program, a federal program established by Congress in 1980, investigates and cleans
up the most complex, uncontrolled, or abandoned hazardous waste sites in the country and EPA
endeavors to facilitate activities to return them to productive use. In total, there are 123 Superfund
sites across New England.
H Superfund and other cleanup sites in New England (pdf)
(91.4 KB)
EPA'S Superfund program
Contact Us to ask a question, provide feedback, or report a
problem.
LAST UPDATED ON FEBRUARY 1, 2024
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-------
APPENDIX G
INTERVIEW SUMMARY
-------
INTERVIEW RECORD
Site Name: BFI Rockingham Landfill Superfund Site
EPA ID No. VTD980520092
Subject: Sixth Five-Year Review
Time: Date: June 12, 2024
10:45AM
Type: ~ Telephone m Visit ~ Other
Location of Visit: Rockingham. Vermont
~ Incoming ~ Outgoing
CONTACT MADE BY
Name(s): Darriel Swatts
Title(s): CIC
Organization(s): US EPA Region 1
Additional Attendees:
Titles(s):
Organization(s):
INDIVIDUAL CONTACTED:
Name: Annette Deas
Title: 17-year resident
Organization: None
Street Address: 12 Riverfront Drive
City, State: Rockingham. Vermont
SUMMARY OF CONVERSATION
1) What is your familiarity with the Site'.'
Not a lot. Remembers when it was still a dump. Learned through late husband bout the
contamination and contaminated wells.
2) What effects have Site operations had on you and/or your neighbors'.'
Aggravating when there's problems with the water pipes. But knows who to contact.
Hopes that if the water goes out for a prolonged time again that she gets put up in a
hotel so she can at least shower.
3) Are you aw are of any community concerns regarding the Site or its operation and
administration'.'
Not really. People have passed away and others are renters and just pass through.
4) Do you feel well informed about the Site's activities and progress'.'
Feels well informed. Has large stack of EPA documents.
5) Are you aware Republic Services, the Responsible Party for the Site, is responsible for
providing drinking water to your residence and monitoring the quality of the drinking
water supplied'.' Have you had any issues with the water provided'.' Do you know how
to contact Republic or it's contractor in the event any water issue arises'.'
Yes. not really, yes but wants an additional point of contact.
-------
6) Would you like to see anything done differently at the Site'.'
Wants the culvert that comes off the site better maintained as it gets clogged. Her late
husband used to keep it clear and now that he's past, she feels obligated to maintain it
herself.
7) Do you have any comments, suggestions, or recommendations regarding the Site's
management or operation'.'
Wants to know about soil contamination in her yard. She received a letter stating that if
she grew vegetables that they wouldn't be suitable for sale. She wonders why if not
suitable for sale, are they suitable for consumption. Would like to receive a more
comprehensive site update from RPM, as she is just curious.
Has a large filter in her basement water supply, she doesn't know who put it there.
Wants to know who's in charge of changing it out. when it needs to be changed out.
etc.
Plans on eventually selling property and moving now that her husband has passed.
Wants to know what she's legally obligated to convey to a potential purchaser.
-------
INTERVIEW RECORD
Site Name: BFI Rockingham Landfill Superfund Site
EPA ID No. VTD980520092
Subject: Sixth Five-Year Review
Time: 1543 | Date: June 13, 2024
Type: 0 Telephone ~ Visit ~ Other
Location of Visit: NA
0 Incoming ~ Outgoing
CONTACT MADE BY
Name(s): Kevin Heine
Title(s): RPM
Organization(s): US EPA Region 1
Additional Attendees: None
Titles(s):
Organization(s):
INDIVIDUAL CONTACTED:
Title: Past President
Organization: Hit or Miss Club
Street Address: 897 Missing Link Rd. US Rt 5
City, State: Rockingham, Vermont
UMMARY OF CONVERSATION
1) What is your familiarity with the NPL Site'.'
When it was open to the public, actually used the landfill as a Springfield resident.
2) What effects have Site operations had on you and/or you're the Hit or Miss Club'.'
Have not had any problems with the Site or its past or current operations.
3) Are you aw are of any community concerns regarding the Site or its operation'.'
No.
4) Do you feel well informed about the Site's activities and progress there'.'
No one has ever approached Eugene or the Club Secretary regarding water issues at the
Hit or Miss Club.
5) Are you aware Republic Services, the Responsible Party for the Site, is responsible for
periodically monitoring groundwater at the Club'.' Have you had any issues with the
water there'.'
Eugene was not aware of Republic's Services responsibility to monitor water at the Hit
or Miss Club. He docs not recall receiving water results while a board member.
6) Do you have any comments, suggestions, or recommendations regarding the Site'.'
Current President of the Club. Chris koledo. should be provided water results. Fred
Yates, past Club Secretary until 2023, has good knowledge of the Site.
-------
BFI SANITARY LANDFILL SUPERFIJND SITE
FIVE-YEAR REVIEW INTERVIEW FORM
Site Name: BFI Sanitary Landfill
EPA ID: VTD980520092
Interviewer name: Darriel Swatts
Subject name: Scott Pickup
Subject contact information: managerฎ,rockbf.org
Interview date: 12 Jun 2024
Interview location: Town Hall. Bellows Falls. VT
Interview format (circle one): In Person S
Interview category: Local Government
Interviewer affiliation: EPA R1 CIC
Subject affiliation: Rockingham Town Manager
Interview time: 1400
Mail Email Other
Phone
1. Are you aware of the former environmental issues at the Site and the cleanup activities that
have taken place to date9
Only from what was read on the website and in-person meeting today.
2. Do you feel well-informed regarding the Site's activities and remedial progress9 If not, how
might EPA convey site-related information in the future9
Yes. Email is best way to keep in touch.
3. Have there been any problems with unusual or unexpected activities at the Site, such as
emergency response, vandalism, or trespassing9
No
4. Are you aware of any changes to local regulations that might affect the protectiveness of the
Site's remedy9
Town is doing some rezoning and adjusting land use; but doesn't think it will impact the site.
5. Are you aware of any changes in projected land use(s) at the Site9
No
6. Has EPA kept involved parties and surrounding neighbors informed of activities at the Site9
How can EPA best provide site-related information in the future9
Have not heard anything negative from the residents near the site. Town can post information on
the website to echo what EPA is putting out.
-------
7. Do you have any comments, suggestions, or recommendations regarding the project9
No
8. Do you consent to have your name included along with your responses to this questionnaire
in the FYR report9
Yes
-------
APPENDIX H
SITE INSPECTION CHECKLIST
-------
FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST
I. SITE INFORMATION
Site Name: BFI-Rockingham Landfill
Date of Inspection: 06/12/2024
Location and Region: Rockingham, Vermont
EPA ID: VTD980520092
[Region]
Agency, Office or Company Leading the Five-Year
Review: EPA Region 1
Weather/Tcmpcrature: Mostlv sunnv/80*
Remedy Includes: (Check all that apply)
[3 Landfill cover/containment
~ Monitored natural attenuation
[X] Access controls
~ Groundwater containment
[3 Institutional controls
~ Vertical barrier walls
[X] Groundwater pump and off-site treatment
[3 Surface water collection and discharge to CT River basin
|5?| Other: Landfill gas collection and flare
Attachments: O Inspection team roster attached
C] Site map attached
II. INTERVIEWS (check all that apply)
1. O&M Site Manager Anuelo Liciuori
BFI Project Manager 6/12/24
Name
Title Date
Interviewed [X] at site ~ at office Q by phone
Phone:
Problems, suggestions [~~| Report attached:
2. O&M Staff Roger Bellcrose Blue
Site Manager 6/12/24
Granite Environmental
Title Date
Name
Interviewed [X] at site ~ at office ~ by phone
Phone:
Problems/suggestions [~~| Report attached:
3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office,
recorder of deeds, or other city and county offices). Fill in all that apply.
Agencv USEPA
Contact Kevin Heine
Project 6/12/24 617 918-1321
Name
Manager Date
Title
Problems/suggestions ~ Report attached:
Agencv VTDEC
Contact Graham Bradlev
Project 6/12/24 802 622-4129
Name
Manager Phone No.
Title Date
Problems/suggestions ~ Report attached:
Agencv
Contact
Name
Title Date Phone No.
Problems/suggestions ~ Report attached:
Agencv
E-l
-------
Contact
Name Title
Problems/suggestions PI Report attached:
Date
Phone No.
Agencv
Contact
Name Title
Problems/suggestions [~~| Report attached:
Date
Phone No.
4.
Other Interviews (optional) Q Report attached:
III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)
1.
O&M Documents
E3 O&M manual/LTMP 0 Readily available
IK1 Up to date
~ n/a
[x] As-built drawings [X] Readily available
[X] Up to date
~ n/a
[X] Maintenance logs (LF [3 Readily available
gas system)
E3 Up to date
~ n/a
Remarks:
2.
Site-Specific Health and Safety Plan
E3 Readily available
E3 Up to date
~ N/A
~ Contingency plan/emergency response plan
~ Readily available
~ Up to date
~ N/A
Remarks:
3.
O&M and OSHA Training Records
Remarks:
~ Readily available
~ Up to date
~ N/A
4.
Permits and Service Agreements
121 Air discharge permit
13 Readily available
[X] Up to date
~ N/A
~ Effluent discharge
~ Readily available
~ Up to date
~ N/A
~ Waste disposal, POTW
~ Readily available
~ Up to date
~ N/A
n Other permits:
~ Readily available
~ Up to date
~ N/A
Remarks:
5.
Gas Generation Records
Remarks:
[x] Readily available
0 Up to date
~ N/A
6.
Settlement Monument Records
Remarks:
~ Readily available
~ Up to date
E N/A
7.
Groundwater Monitoring Records
Remarks: Maintained offsite
~ Readily available
~ Up to date
~ N/A
8.
Leachate Extraction Records
~ Readily available
~ Up to date
E N/A
E-2
-------
Remarks: No leachate generated
9. Discharge Compliance Records
~ Air ~ Readily available ~ Up to date 0 N/A
~ Water (effluent) ~ Readily available ~ Up to date M N/A
Remarks:
10. Daily Access/Security Logs
~ Readily available ~ Up to date [X] N/A
Remarks:
IV. (M M COSTS
1. O&M Organization
[~l State in-house
~ Contractor for state
1 1 PRP in-house
E3 Contractor for PRP
[~l Federal facility in-house
~ Contractor for Federal facility
n
2. O&M Cost Records
[~l Readily available
~ Up to date
[~l Funding mechanism/agreement
in place ~ Unavailable
Original O&M cost estimate: The original O&M cost estimate provided in the 1994 ROD for post closure
O&M for a period of 5 to 30 years after the completion of the NTCRA raneed from $90,000 to $200,000 per
year. Oireakdown attached
Total annual cost by year for review period if available
From: 2023 To:
$204,696 n Breakdown attached
Date Date
Total cost
From: 2022 To:
$195,914 n Breakdown attached
Date Date
Total cost
From: 2021 To:
$197,226 n Breakdown attached
Date Date
Total cost
From: 2020 To:
$381.244 r~| Breakdown attached
Date Date
Total cost
From: 2019 To:
$368,337 n Breakdown attached
Date Date
Total cost
3. Unanticipated or Unusually High O&M Costs during Review Period
Describe costs and reasons: NA
V. ACCESS AND INSTITUTIONAL CONTROLS ~ Applicable ~ N/A
A. Fencing
1. Fencing Damaged ~ Location shown on site map ^ Gates secured ~ N/A
Remarks: NA
E-3
-------
B. Other Access Restrictions
1. Signs and Other Security Measures ~ Location shown on site map ~ N/A
Remarks: Gate and fence signage in place
C. Institutional Controls (ICs)
1. Implementation and Enforcement
Site conditions imply ICs not properly implemented ~ Yes 0 No ~ N/A
Site conditions imply ICs not being fully enforced ~ Yes 8 No ~ N/A
Type of monitoring (e.g., self-reporting, drive by): Inspections of interceptor trench and LF cap and
drainage systems
Frequency: Monthly
Responsible party/agency: BGE
Contact Roger Bellerose
Name Title
Date
Phone no.
Reporting is up to date
3 Yes
~ No
~n/a
Reports arc verified by the lead agency
~ Yes
El No
~ n/a
Specific requirements in deed or decision documents have been met
~ Yes
~ No
M N/A
Violations have been reported
~ Yes
~ No
K1 N/A
Other problems or suggestions: flReport attached
2.
Adequacy [x] ICs arc adequate ~ ICs arc inadequate
Remarks: VT Groundwater Reclassification completed and in-placc
~ N/A
D.
General
1.
Vandalism/Trespassing ~ Location shown on site map [3 No vandalism evident
Remarks:
2.
Land Use Changes On Site [X] N/A
Remarks:
3.
Land Use Changes Off Site [X] N/A
Remarks:
VI. GENERAL SITE CONDITIONS
A.
Roads [x] Applicable ~ N/A
1.
Roads Damaged ~ Location shown on site map [X] Roads adequate
Remarks:
~ N/A
B.
Other Site Conditions
Remarks:
VII. LANDFILL COVERS [X] Applicable ~ N/A
A.
Landfill Surface
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1.
Settlement (low spots)
0 Location shown on site map
~ Settlement not evident
Area extent:
Depth:
Remarks: ID's in annual LF inspection report
2.
Cracks
l~l Location shown on site map
13 Cracking not evident
Lengths:
Widths:
Depths:
Remarks:
3.
Erosion
l~l Location shown on site map
12 Erosion not evident
Area extent:
Depth:
Remarks:
4.
Holes
~ Location shown on site map
fx] Holes not evident
Area extent:
Depth:
Remarks:
5.
Vegetative Cover
l~l Grass
EI Cover properly established
[~l No signs of stress
[~l Trees/shrubs (indicate si/e and locations on a diagram)
Remarks:
6.
Alternative Cover (e.g., armored rock, concrete)
El N/A
Remarks:
7.
Bulges
~ Location shown on site map
13 Bulges not evident
Area extent:
Height:
Remarks:
8.
Wet Areas/W ater Damage
13 Wet areas/water damage not evident
l~l Wet areas
O Location shown on site map
Area extent:
[~l Ponding
~ Location shown on site map
Area extent:
[~l Seeps
~ Location shown on site map
Area extent:
[~l Soft subgrade
~ Location shown on site map
Area extent:
Remarks:
9.
Slope Instability
~ Slides
~ Location shown on site map
[X] No evidence of slope instability
Area extent:
Remarks:
B.
Benches [>3 Applicable ~ N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in
order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)
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1.
Flows Bypass Bench ~ Location shown on site map
Remarks:
[X] N/A or okay
2.
Bench Breached Q Location shown on site map
Remarks:
[X] N/A or okay
3.
Bench Overtopped Q Location shown on site map
Remarks:
1X1 N/A or okay
C.
Letdown Channels ฃ3 Applicable ~ N/A
(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)
1.
Settlement (Low spots) ~ Location shown on site map
E3 No evidence of settlement
Area extent:
Depth:
Remarks:
2.
Material Degradation ~ Location shown on site map
13 No evidence of degradation
Material tvpe:
Area extent:
Remarks:
3.
Erosion Q Location shown on site map
[>| No evidence of erosion
Area extent:
Depth:
Remarks:
4.
Undercutting ~ Location shown on site map
[X] No evidence of undercutting
Area extent:
Depth:
Remarks:
5.
Obstructions Tvdc:
[~| Location shown on site map Area extent:
Size:
Remarks:
0 No obstructions
6
Excessive Vegetative Growth Type: Growth in perimeter ditches and settlement
basins. Vegetative growth is managed annually.
~ No evidence of excessive growth
[X] Vegetation in channels docs not obstruct flow
~ Location shown on site map Area extent:
Remarks:
D.
Cover Penetrations [x] Applicable ~ N/A
1.
Gas Vents [SI Active
[~l Passive
[~l Properly secured/locked [3 Functioning [X] Routinely sampled [3 Good condition
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[~l Evidence of leakage at penetration ~ Needs maintenance
~ N/A
Remarks:
2.
Gas Monitoring Probes
E3 Properly secured/locked E3 Functioning [X] Routinely sampled
[X] Good condition
l~l Evidence of leakage at penetration Q Needs maintenance
~ n/a
Remarks:
3.
Monitoring Wells (within surface area of landfill)
[~l Properly secured/locked ~ Functioning ~ Routinely sampled
O Good condition
[~l Evidence of leakage at penetration Q Needs maintenance
Bn/a
Remarks:
4.
Extraction Wells Leachate
l~l Properly secured/locked Q Functioning Q Routinely sampled
O Good condition
l~l Evidence of leakage at penetration Q Needs maintenance
Bn/a
Remarks:
5.
Settlement Monuments ~ Located O Routinely surveyed
Remarks:
El N/A
E.
Gas Collection and Treatment Kl Applicable ~ N/A
1.
Gas Treatment Facilities
[3 Flaring ~ Thermal destruction
O Collection for reuse
[~l Good condition ~ Needs maintenance
Remarks:
2.
Gas Collection Wells, Manifolds and Piping
[X] Good condition ~ Needs maintenance
Remarks:
3.
Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
[~l Good condition ~ Needs maintenance [X] N/A
Remarks:
F.
Cover Drainage Layer [2 Applicable ~ N/A
1.
Outlet Pipes Inspected ~ Functioning [X] N/A
Remarks:
2.
Outlet Rock Inspected E3 Functioning ~ N/A
Remarks:
G.
Detention/Sedimentation Ponds 0 Applicable Q N/A
1.
Siltation Area extent: Depth:
O Siltation not evident
El N/A
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Remarks:
2.
Erosion Area extent: Depth:
[X] Erosion not evident
Remarks:
3.
Outlet Works [El Functioning
Remarks:
~ n/a
4.
Dam O Functioning
Remarks:
13 N/A
EL Retaining Walls E3 Applicable ~ N/A
1.
Deformations El Location shown on site map
l~l Deformation not evident
Horizontal displacement: Vertical displacement:
Rotational displacement:
Remarks: Gabion wall monitored monthly for movement and is stable.
2.
Degradation ~ Location shown on site map
Remarks:
13 Degradation not evident
I. Perimeter Ditches/Off-Site Discharge 0 Applicable
~ N/A
1.
Siltation ~ Location shown on site map
[X] Siltation not evident
Area extent:
Depth:
Remarks:
2.
Vegetative Growth ~ Location shown on site map
[X] Vegetation does not impede flow
~ n/a
Area extent:
Type:
Remarks: Seasonal vegetative growth is managed annually.
3.
Erosion ~ Location shown on site map
[X] Erosion not evident
Area extent:
Depth:
Remarks:
4.
Discharge Structure [X] Functioning
Remarks:
~ n/a
VIII. VERTICAL BARRIER WALLS ~ Applicable
งN/A
1.
Settlement Q Location shown on site map
l~l Settlement not evident
Area extent:
Depth:
Remarks:
2.
Performance Monitoring Type of monitoring:
~ Performance not monitored
Frequency:
[~l Evidence of breaching
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Head differential:
Remarks:
IX. GROUNDWATER/SURFACE WATER REMEDIES [2 Applicable ~ N/A
A. Groundwater Extraction Wells, Pumps and Pipelines ~ Applicable ~ N/A
1. Pumps, Wellhead Plumbing and Electrical
[3 Good condition [X] All required wells properly operating ~ Needs maintenance ~ N/A
Remarks:
2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances
[3 Good condition ~ Needs maintenance
Remarks:
3. Spare Parts and Equipment
[X] Readily available [X] Good condition ~ Requires upgrade ~ Needs to be provided
Remarks:
B. Surface Water Collection Structures, Pumps and Pipelines ~ Applicable งN/A
1. Collection Structures, Pumps and Electrical
~ Good condition ~ Needs maintenance
Remarks:
2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances
~ Good condition ~ Needs maintenance
Remarks:
3. Spare Parts and Equipment
~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks:
C. Treatment System ~ Applicable [3 N/A
1. Treatment Train (check components that apply)
~ Metals removal ~ Oil/water separation ~ Bioreinediation
~ Air stripping ~ Carbon adsorbers
~ Filters:
~ Additive (e.g., chelation agent, flocculent):
~ Others:
~ Good condition ~ Needs maintenance
~ Sampling ports properly marked and functional
~ Sampling/maintenance log displayed and up to date
~ Equipment properly identified
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n Quantity of groundwater treated annually:
["I Quantity of surface water treated annually:
Remarks:
2. Electrical Enclosures and Panels (properly rated and functional)
[X] N/A ~ Good condition ~ Needs maintenance
Remarks:
3. Tanks, Vaults, Storage Vessels
[X] N/A ~ Good condition ~ Proper secondary containment
~ Needs maintenance
Remarks:
4. Discharge Structure and Appurtenances
[X] N/A ~ Good condition Q Needs maintenance
Remarks:
5. Treatment BuiMing(s)
[3 N/A ~ Good condition (esp. roof and doorways)
O Needs repair
O Chemicals and equipment properly stored
Remarks:
6. Monitoring Wells (pump and treatment remedy)
~ Properly secured/locked ~ Functioning ~ Routinely sampled
~ Good condition
~ All required wells located ~ Needs maintenance
[XI N/A
Remarks:
D. Monitoring Data
1. Monitoring Data
[X] Is routinely submitted on time [3 Is of acceptable quality
2. Monitoring Data Suggests:
E3 Groundwater plume is effectively contained |x] Contaminant concentrations are declining
E. Monitored Natural Attenuation
1. Monitoring Wells (natural attenuation remedy)
~ Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition
O All required wells located ~ Needs maintenance
Hn/a
Remarks:
X. OTHER REMEDIES
If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical
nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.
NA
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XI. OVERALL OBSERVATIONS
A.
Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant
plume, minimize infiltration and gas emissions).
None observed. Renicdv appears effective and functioning as designed.
B.
Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness of the remedy.
None identified.
C.
Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protcctivcness of the remedy may be compromised
in the future.
None identified.
D.
Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
Landfill gas vents with low landfill gas Yield arc planned to be taken offline later in 2024.
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