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SDMS DocID 495380
Swperfuml Records Center SITE fomngirg f BREAK IJ f OTHER W 0
RESPONSIVE TO QUESTIONS 6(e) amp 7(b)
T gt v -^ -N m i l G C electronics ltd Tel (802) 864-0064 U U r l A bull =c -5 US Sales Office 15 Commerce St m^A^MMj Williston Vt 05495 Twx 510-299-0045
m bull - bull bull K J l f - J l bull - raquo m mdash - mdash raquo - gt
serving the microwave telecom and defence industries in Canada usa and europe bull
August 14 1984
Air and Solid Waste Program State Office Building
Montpelier Vennont 05602 -
ATTENTION Cedrik Sanborn
Dear Sirs
Further to our telephone conversation of today enclosed find copy of proposal from JH Stuart Associates listing the proposed work to be carried out
If this meets with your approval we will go ahead with this work and we can then adVise Ms Meredeth Wright of the Attorney Generals Office th^t you aire satisfied with this proposal
gtur rep
Yours t r u l y
MITEC ELECTRONIC
G Mogi l CONTROLLER
cc g R ^ ^ C r o n i n J H S t u a r t
MITEC 104e 00346
c c c c c c c L L L ^ ^- v WORM n f c ] gt raquo M raquo raquoOT ^ r i raquo t OraKft L iu 0M5O
Page No 1 of - 1 Page PrnpnBal
II
1J
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I1
I
J H STUART ASSOCIATES 120 Lake Street
BURLINGTON VERMONT 05401 (802) 864-0094
PROPOSAL SUBMITTED TO PHONE DATE
MITEC Systems Corporation 864-0064 August 7 1984 STREET JOS NAME
15 Commerce Way So i l and groundwater analyses CITT STATE ANO ZIP CODE JOB LOCATION
Wi l l i s ton Vermont 05495 Ai l ing I n d u s t r i a l Park- W i l l i s t o n ARCHITECT DATE Of PLANS JOB PHONE NA NA
We hereby submit specifications and estimates for
Develop a site plan for location of a small waste disposal site to the rear of the manufacturing facility Said- plan to show where groundwater monitors are to be placed together with themethod of construction Further locations will be identified where soil samples are to be extracted for analyses All of the above information will be presented to the Vermont Agency of Environmental Conshyservation for review arid approval of requisitecorrective actionsThe specific functions to be provided are shy
1 Site plan development 2 Establish groundwater monitors in four (4) locations 3 Collect three (3) soil samples for analyses 4 Collect four(4) watersamples on two occasions with the second
batch occurring 90 days later shy5 Coordinate planning discussions and negotiations with the
Agency to remedy potential violations of State statutes and regulations
The above Includes all labor and equipment (backhoe) time needed to accomplish the tasks indicated by the State Not Included are groundwater sampling beyond the second batch of tests additional soil tests beyond the Initial batch and removal of any soil materials that may be found to be contaminated beyond acshyceptable Federal or State standards
MITEC 104e 00348
S f |JrnpDBP hereby to furnish materJaJ-jfl^Oabor mdash complete in accordance with above specifications for the sum MCTf T O c Q B t C T 7 7 0
dollars (J Payment lo be made as follows
Above work to commence by 81684 completed Alt m a t e r i a l Is guaran teed t o pound M a t tpac l fcad Ai l work t o ba e o m p M f d In a w o r k m a n l i k e m i r u M r a c c o r d l n | t o t t a n d a r d p r a c t i c a l Any laquo n laquo f a t laquo A or dev ia t i on r o m abova tpec i f i ca - Authorized ^ f e ^ M ^ t i o n t I n v o M n g ex t ra c o t t s wiU blaquo alaquocu tad on l y u p o n w r i t t en o rde r a n d w in b e c o m e a n Signature shy
e r t r a c h m raquo over a n d above t h a es t ima te Al l agreement i con t i ngen t u p o n t t r t f ca t acc iden ts o r de lays b e y o n d o u r c o n t r o l O w n t r l o ca r r y raquora t o rnado a n d o tha r necessary i nsu rance TJyi proposal may be lo Our worke rs ara fu l l y covered by Worlwnens Compensa t i on Insu rance withdrawn by not accepted wi th in
K t t t p t a n i P flf ^ m p H S a l - T h e above prices specifications Signature and conditions are satisfactory and are hereby accepted You are authorised
CORRECTIVE ACTION FEASIBILITY INVESTIGATION EPA SITE NUMBER VTD-0983 53545 (LOT 19-11)
January 29 2001
GeoX MITEC 104e Fc l I lS Inc A TETRA TECH COMPANY J L J 02269
6 Lancaster County Road Harvard MA 01451 978-772-7557 FAX 978-772-61 83
CORRECTIVE ACTION FEASIBILITY INVESTIGATION EPA SITE NUMBER VTD-098353545 (LOT 19-11)
J - J C T October 5 2000
GEOTRANS A TETRA TECH COMPANY
6 Lancaster County Road Suite Four Harvard Massachusetts 01451 MITEC 104e
02352
CORRECTIVE ACTION FEASIBILITY INVESTIGATION
EPA SITE NUMBER VTD-098353545 (LOT 19-11)
PREPARED FOR
ALLING INDUSTRIAL PARK
PREPARED BY
HSI GEOTRANS INC
6 LANCASTER COUNTY ROAD
HARVARD MASSACHUSETTS 01451
HSI GEOTRANS PROJECT NO N753-016 OCTOBER 52000
HSI GeoTrans inc
MITEC 104e 02353
TABLE OF CONTENTS
PAGE
1 INTRODUCTION 1-1
2 STUDY AREA CONCEPTUAL MODEL 2-1 21 STUDY AREA LOCATION AND DESCRIPTION 2-1
22 STUDY AREA LAND USE 2-1
23 HYDROGEOLOGIC SETTING 2-1
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION 2-3
3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES 3-1 31 IDENTIFICATION OF ARAR S 3-1
32 REMEDIAL ACTION OBJECTIVES 3-1
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES 3-1
322 GROUNDWATER 3-1
323 SURFACE WATER 3-2
324 INDOOR AIR 3-3
33 INITIAL SCREENING 3-3
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES 3-4
4 DETAILED ANALYSIS OF ALTERNATIVES 4-1 41 ALTERNATIVE 1 NO ACTION 4-1
411 SHORT-TERM EFFECTIVENESS 4-1
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-2
413 LONG-TERM EFFECTIVENESS 4-2
414 COMPLIANCE WITH ARARS 4-3
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 4-4
416 IMPLEMENTABILITY 4-4
417 COSTS 4-5
42 ALTERNATIVE 2 MONITORING INSTITUTIONAL CONTROLS AND
HYDRAULIC CONTAINMENT 4-5 421 SHORT-TERM EFFECTIVENESS 4-8
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-9
423 LONG-TERM EFFECTIVENESS 4-9
424 COMPLIANCE WITH ARAR S 4-10
425 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-11
426 IMPLEMENTABILITY 4-11
427 COSTS 4-12
FOR ALLING INDUSTRIAL PARK MWP_DOCSW5J20OTALlIWFS9-00U0030929wro 11 HSI GSOTrflnS IflC
MITEC 104e 02354
TABLE OF CONTENTS (CONTINUED)
PAGE
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS
AND PERMEABLE REACTIVE BARRIER 4-13
431 SHORT-TERM EFFECTIVENESS 4-15
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-16
433 LONG-TERM EFFECTIVENESS 4-17
434 COMPLIANCE WITH ARARs 4-18 435 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-18
436 IMPLEMENTABILITY 4-19
437 COSTS 4-20
44 ALTERNATIVE 4 MONITORING INSTITUTIONAL CONTROLS
AND NATURAL ATTENUATION 4-20
441 SHORT-TERM EFFECTIVENESS 4-21
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-21
443 LONG-TERM EFFECTIVENESS 4-22
444 COMPLIANCE WITH ARARS 4-23
445 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-23
446 IMPLEMENTABILITY 4-23
447 COSTS 4-24
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION 4-25
451 SHORT-TERM EFFECTIVENESS 4-26
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-27
453 LONG-TERM EFFECTIVENESS 4-27
454 COMPLIANCE WITH ARARS 4-28
455 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-29
456 IMPLEMENTABILITY 4-29
457 COSTS 4-30
FOR ALLING INDUSTRIAL PARK MWPJXgtCSN7532000AUJNOFSlaquo)0I0030929WPD 111 HSI GeOTrSDS ItlC
MITEC 104e 02355
TABLE OF CONTENTS (CONTINUED)
PAGE
5 COMPARATIVE EVALUATION OF ALTERNATIVES 5-1 51 SHORT-TERM EFFECTIVENESS 5-1
52 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT 5 - 3 53 LONG-TERM EFFECTIVENESS 5-4
54 COMPLIANCE WITH ARARS 5-4
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 5-4
56 IMPLEMENTABILITY 5-5
57 COSTS 5-5
6 PREFERRED REMEDY 6-1 61 PREFERRED REMEDY 6-1
62 MONITORING PROGRAM 6-2
REFERENCES 7-1
APPENDIX A TWODAN INPUT FILES
FOR ALLING INDUSTRIAL PARK MWgt_DOCSW7532000WJJNGfS9^)0M00J(raquo9wpo I V H S I G S O T r a H S I n C
MITEC 104e 02356
LIST OF TABLES
PAGE
TABLE 3-1 REMEDIAL ACTION OBJECTIVES 3-7
TABLE 3-2 DESCRIPTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES 3-8
TABLE 3-3 SELECTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES
FOR DETAILED ANALYSIS 3-11
TABLE 41 COST ESTIMATES FOR REMEDIAL ALTERNATIVES 4-31
TABLE 6-1 SAMPLING LOCATIONS 6-5
TABLE 6-2 VOC ANALYTES 6-6
TABLE 6-3 PARAMETERS TO EVALUATE BIODEGRADATION 6-7
FOR ALLING INDUSTRIAL PARK MWP DOCSN7S32000AUJNOFS9-00I0030929 wro HSI GeoTrans inc
MITEC 104e 02357
LIST OF FIGURES
PAGE
FIGURE 1-1 STUDY AREA LOCATION MAP 1-2
FIGURE 1 -2 LATERAL BOUNDARIES OF REGION OF TCE-CONTAMINATED GROUNDWATER 1 -3
FIGURE 4-1 MODELED SITE-EXISTING CONDITIONS 4-33
FIGURE 4-2 MODELED SITE WITH THREE RECOVERY WELLS PUMPING AT 5 GPM 4-34
FIGURE 4-3 MODELED SITE WITH TEN RECOVERY WELLS PUMPING AT 5 GPM 4-35
FIGURE 4-4 ALTERNATIVE 3 PERMEABLE REACTIVE BARRIER 4-36
FIGURE 6-1 PROPOSED MONITORING LOCATIONS 6-8
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUUNOFS9-OOV 10030929 w r o VI HSI GeoTrans inc
MITEC 104e 02358
1 INTRODUCTION
This Corrective Action Feasibility Investigation is submitted on behalf of Mitec Telecom
Inc (Mitec) by HSI GeoTrans The investigation was done to evaluate potential remedial
alternatives for groundwater contaminated by trichloroethylene (TCE) and to a lesser extent
tetrachloroethylene (PCE) and petroleum related compounds (BTEX) at the Ailing Industrial
Park (the Study Area) A recently prepared Site Investigation Report (SIR) (HSI GeoTrans
2000) identified the nature and extent of contaminated groundwater within the Study Area
Figure 1-1 is a map ofthe Study Area and Figure 1-2 is a map that outlines the region of
contaminated groundwater for which potential remedial alternatives were evaluated
The SIR concluded that the TCE contamination was widespread across the Study Area
that residual TCE dense non-aqueous phase liquid (DNAPL) resulting from one or more releases
was a continuing source of contamination to groundwater and that under current conditions the
groundwater contamination does not pose an unacceptable risk to human health and the
environment Current conditions include the continued effective mitigation of indoor air vapors
at the residence at Lot 3-30 no other residences with basements below the water table and no
use of groundwater within the Study Area as a potable supply The SIR also concluded that if
groundwater were to be used as a potable supply a significant health risk would exist as a result
of exposure to groundwater through ingestion dermal contact and inhalation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^X)M0030929WPD 1 - 1 HSI GCOTrdnS ITC
MITEC 104e 02359
I - N -
Former Mitec Hold y
Meters
Explanation
Study Area TITLE
MITEC 104e 02360
Study Area Location Map
LOCATION
Williston Vermont CHECKED MS FIGURE HSI OfVFTED RMK
GEOTRANS RLE f s ~ Expa nd~S(tsdirq 1-1 A T I T M TICK C011irraquoraquoT DATE- 10600 ~
2 STUDY AREA CONCEPTUAL MODEL
The following discussion ofthe Study Area conceptual model is summarized from
information contained in the previously submitted SIR (HSI GeoTrans 2000)
21 STUDY AREA LOCATION AND DESCRIPTION
The Study Area is located at the Ailing Industrial Park and adjacent areas in Chittienden
County Williston VT The VT state plane coordinates for the Study Area are Northing
71210837 (44 27 T north latitude) and Easting 147576375 (73 7 50 west longitude) The
Study area is within the Winooski River watershed and has an elevation ranging from 330 to 350
feet above mean sea level (MSL) The ground surface has little relief and slopes gently to the
southwest A small unnamed brook flows in a southerly direction along the eastern edge of an
industrial park located within the Study Area There is unlimited public pedestrian access to the
Study Area
22 S T U D Y A R E A L A N D U S E
The land in the Study Area is currently zoned for mixed residential commercial and
industrial use The eastern portion ofthe Study area is primarily zoned for commercial use and
the western portion ofthe Study Area is predominantly residential The Study Area includes an
industrial park where there has been light industrial and commercial use since 1946 Three lots
in the industrial park have been previously identified as locations of former manufacturing andor
fabrication operations that resulted in release of contaminants to groundwater (Brinkerd 1996
TRC 1993 Griffin 1995)
23 HYDROGEOLOGIC SETTING
The unconsolidated geologic deposits beneath the Study Area consist of sand silt and
clay which were deposited in the former Champlain Sea overlying till The unconsolidated
deposits occur in four distinct layers The surficial deposits are medium to fine sand which
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000VALUNoFS9^X)10030929wro 2 - 1 H S I G e O T r a f l S J n C
MITEC 104e 02362
generally becomes finer-grained with depth and extend to approximately 20 feet below ground
surface (bgs) Interbedded silts and fine sands are present from approximately 20 to 40 feet bgs
An areally-extensive clay layer underlies the interbedded silt and fine sands at a depth of
approximately 32 to 60 feet bgs Beneath the clay layer is a dense till which extends from about
60 to 100 feet bgs The underlying bedrock is comprised of massive gray limestone gray
dolomite and white marble ofthe Beckman formation This bedrock is of lower Ordovician age
and is part ofthe Hinesburg Synclinorium structure
The aquifer in the Study Area and surrounding regions is primarily the surficial medium
and fine sands although some water is capable of being extracted from the lower silt and fine
sand The residences and businesses within the Study Area are currently serviced by a public
water supply and the aquifer is not used for potable water supply within the Study Area The
hydraulic conductivity ofthe medium to fine sands was determined from a slug test to be about
20 feetday (Johnson 1999) The hydraulic conductivity ofthe interbedded silt and fine sand as
determined from rising and falling head slug tests (HSI GeoTrans 2000) ranged from 1 to 20
ftday with a geometric mean of 38 ftday A pumping test of well NO-1 yielded a hydraulic
conductivity estimate of about 2 to 30 ftday for the combined medium to fine sands and
underlying silt and fine sand There are no hydraulic conductivity data for the underlying clay
and till layers It is believed that the clay and till act as a lower confining layers restricting the
vertical flow of water between the overlying sand and the underlying bedrock
Beneath the Study Area the depth to water generally ranges from 3 to 11 feet below
ground surface In general groundwater flow beneath the Study Area is from the north to the
southeast and southwest There is a groundwater divide in the water table that runs generally
parallel to Commerce Street East ofthe divide groundwater flows toward and discharges to the
unnamed brook West ofthe divide groundwater flows toward Muddy Brook which is located
about 300 meters or 1000 feet west ofthe Study Area Groundwater recharge within the Study
FOR ALLING INDUSTRIAL PARK MAWPJgtOCSN753UOOOWXINOFS9-O0l0030929wro 2-2 HSI GCOTrdnS IDC
MITEC 104e 02363
Area is primarily from infiltration of precipitation Prior to 1986 when a sewer line was
installed groundwater recharge also resulted from discharge to numerous on-site disposal
systems
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION
Figure 1-2 illustrates the 1999 distribution of TCE-contaminated groundwater within the
Study Area The lateral boundaries ofthe region of TCE-contaminated groundwater
approximately represent the lateral boundaries ofthe region of volatile organic compound
(VOC)-contaminated groundwater As discussed in the SIR (HSI GeoTrans 2000) VOCs
present in groundwater include TCE PCE and BTEX The compound detected at the highest
concentrations and over the largest portion ofthe Study Area is TCE PCE is generally detected
in the same area as TCE but at significantly lower concentrations BTEX compounds have been
detected in groundwater primarily in the eastern portion ofthe Study Area and are commingled
with but not coincident with TCE-contaminated groundwater The lateral boundaries shown in
Figure 1-2 approximately represent the lateral extent of groundwater contamination and are not
intended to indicate that all groundwater within those boundaries is contaminated This figure
includes data collected on behalf of Mitec as part ofthe SIR (HSI GeoTrans 2000) and data
collected in 1999 by the Johnson Company (Johnson 1999) Figure 4-2 A ofthe SIR (HSI
GeoTrans 2000) shows all TCE concentration data collected in 1999 as well as some data
collected in 1997 The SIR (HSI GeoTrans 2000) summarized previous investigations that
indicated that at least three properties have contributed to the region of VOC-contaminated
groundwater On Lot 19-11 there were a disposal lagoon and a leach field that resulted in the
release ofthe VOCs TCE and PCE (perhaps as an impurity in the TCE) Lot 19-12 once had
underground storage tanks from which a previous release of BTEX was discovered when the
tanks were removed Lot 19-2 contained a disposal pit and outfall pipe from which TCE was
reportedly released
Figure 1-2 of this report shows in plan view the areal distribution of TCE-contaminated
groundwater Where there were multiple 1999 data values for the same location preference was
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AL1JNOFS9-OOM0030929WPD 2-3 HSI GSOTraHS JHC
MITEC 104e 02364
given to samples collected by low-flow sampling done subsequent to well installation In
addition for those locations which had samples from different depths the sample with the
highest concentration was used Figure 1-2 illustrates that TCE-contaminated groundwater is
widespread beneath the Study Area and that the highest TCE concentrations are detected in
groundwater beneath the eastern portion ofthe Study Area The figure illustrates that TCE-
contaminated groundwater in the eastern portion ofthe Study Area discharges to the unnamed
brook No VOCs including TCE have been detected in groundwater samples collected from
wells on the eastern side of the unnamed brook Based on surface water and groundwater data
that have been collected the unnamed brook appears to limit the southeasterly extent ofthe
region of VOC-contaminated groundwater In the western portion ofthe Study Area the lateral
boundaries of contaminated groundwater were identified through vertical profile sampling at
several locations Figure 1-2 shows the location ofthe vertical profiling borings that define the
lateral extent of TCE-contaminated groundwater The SIR (HSI GeoTrans 2000) recommended
periodic sampling and analysis of wells in the western portion ofthe Study Area for the purpose
of determining whether this region of VOC-contaminated groundwater was stable or expanding
in size
While not evident from Figure 1-2 it was determined that throughout the Study Area the
highest TCE concentrations were detected in samples collected from the interbedded siltclay
layer As shown on Figure 4-2A ofthe SIR the higher TCE concentrations were generally
detected at a depth of about 35 feet below ground surface in the eastern portion ofthe Study
Area and at a depth of about 30 feet below ground surface in the western portion ofthe Study
Area It is believed that the current distribution of TCE contamination resulted from DNAPL
releases at one or more locations within the Study Area One such release area was at Lot 19-11
DNAPL migrated downward through the upper medium to coarse sands under the primary
influence of gravitational forces There would have been some lateral displacement along
preferential pathways provided by sloping unconsolidated deposits but the primary flow would
have been downward Upon encountering the more resistive capillary pressure forces associated
with the water-saturated finer-grained geologic units such as the interbedded silts and sands
FOR ALLING INDUSTRIAL PARK MVWP_DOCSN7532000ALUNCFS9J3010030929wro 2 - 4 H S I G C O T r d n S I r t C
MITEC 104e 02365
which exist beneath the upper medium to coarse sands the DNAPL downward migration would
have stopped The DNAPL would have accumulated on top ofthe capillary pressure barrier layer
and then would have spread laterally following preferential flow paths within the coarser-grained
geologic units above the interbedded silts and sands The amount of lateral spreading of
DNAPL from any release area would have been dependent upon the volume and frequency ofthe
releases As the DNAPL migrated it would have created a region of residual DNAPL This
region of residual DNAPL consists of isolated DNAPL droplets trapped within pore spaces ofthe
unconsolidated deposits The lateral migration ofthe DNAPL would have been affected by the
slope ofthe surface ofthe finer-grained units that halted downward migration ofthe DNAPL
and it would not necessarily have been coincident with the direction of hydraulic gradient or
groundwater flow The region of residual DNAPL is now a continuing source of contamination
to the groundwater which flows past and gradually dissolves the DNAPL The locations ofthe
residual DNAPL zones are not known
There were no direct observations of DNAPL during drilling and well installation but it
is expected that residual DNAPL generally exists within regions of higher concentration detected
in the eastern portion of the Study Area The residual DNAPL is not necessarily continuously
connected within that region Based on the vertical distribution of TCE concentrations it is also
expected that the residual DNAPL exists in a relatively thin zone within the interbedded silt and
clay Limited hydrodynamic dispersion within the interbedded silt and clay has resulted in a
relatively thin zone of relatively high TCE concentrations in groundwater The southeastward
and southwestward divergence of groundwater flow has resulted in a laterally extensive region of
TCE-contaminated groundwater
There has been no indication in any ofthe investigations done within the Study Area
including the SIR (HSI GeoTrans 2000) that there are locations within the Study Area where
DNAPL is present in sufficient volume to be recoverable in the DNAPL phase
FOR ALLING INDUSTRIAL PARK m
MWP_DOCSN7532000VALLINCFS9^IOM0030929WIgto 2-5 HSI GCOTranS tC
MITEC 104e 02366
3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES
31 IDENTIFICATION OF ARARS
Two Applicable or Relevant and Appropriate Requirements (ARARs) were identified in
consultation with Mr Mike Smith ofthe Vermont Department of Environmental Conservation
(VTDEC) The first are the Groundwater Enforcement Standards as outlined in Appendix one of
the Chapter 12 Groundwater Protection Rule (VTDEC 1997) These standards apply to
concentrations of contaminants in groundwater in the Study Area (TCE PCE and BTEX) The
second are the Vermont Water Quality Criteria dated March 142000 (VTDEC 2000) which
specify surface water quality criteria and policy
32 REMEDIAL ACTION OBJECTIVES
The remedial action objectives (RAOs) for the Study Area are summarized in Table 3-1
and further described below
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES
One ofthe RAOs for the Study Area is the remediation of source areas Soil excavation
and removal has already occurred at the known release areas Not withstanding the fact that
previous DNAPL releases are suspected no areas of recoverable DNAPL have been detected in
the Study Area Concentrations of TCE in groundwater indicate it is present in some areas as
residual phase below the water table One purpose of this Corrective Action Feasibility
Investigation is to evaluate options for remediating residual DNAPL in the Study Area
322 GROUNDWATER
Attain VT Groundwater Enforcement Standards The ultimate goal of remediation is to
attain Groundwater Enforcement Standards for VOCs in groundwater This is in accordance
with the VT Groundwater Protection Rule and Strategy (VTDEC 1997) which states that If an
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(MUJNOFS9^)OM0030929WPD 3 - 1 HSI GCOTranS IttC
MITEC 104e 02367
enforcement standard has been reached or exceeded at a compliance point the goal is to take
appropriate action to retum the groundwater quality to below the enforcement standard if
possible
Prevent Expansion ofthe Dissolved Plume A risk assessment (Menzie Cura 2000a and
2000b) was included as part ofthe SIR (HSI GeoTrans 2000) The risk assessment concluded
that under current conditions concentrations of VOCs dissolved in groundwater in the Study Area
do not pose a risk to human health andor the environment The SIR (HSI GeoTrans 2000) also
indicated that the available monitoring data were not sufficient to determine whether the region
of VOC-contaminated groundwater in the southwestern portion ofthe Study Area was stable in
size or expanding This Corrective Action Feasibility Investigation explores options for
monitoring groundwater quality and preventing the region of VOC-contaminated groundwater
from expanding in size
Prevent Potable Use of Groundwater Within the Dissolved Plume Menzie Cura prepared
a June 1 2000 addendum (Menzie Cura 2000b) to the April 2000 risk assessment (Menzie Cura
2000a) The addendum evaluated risk posed by potable use of groundwater at the site The
addendum found there to be a human health risk associated with the use of groundwater at the
site for potable purposes One RAO of this Corrective Action Feasibility Investigation is to
propose institutional controls so that groundwater within the region of contaminated
groundwater would not be used as a potable supply until concentrations are suitable for such use
323 SURFACE WATER
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
under current conditions VOCs dissolved in surface water in the Study Area do not pose arisk to
human health or the environment Currently however surface water concentrations in the
unnamed brook exceed VT Water Quality Criteria (VTDEC 2000) One ofthe RAOs for the
site will be to meet these surface water quality standards in the unnamed brook
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUINOFS9^)010030929WPD 3-2 HSI GeOTfatlS InC
MITEC 104e 02368
324 INDOOR AIR
The VTDEC has conducted air sampling at several residences along Kirby Lane and
South Browneil Road The results have indicated the presence of TCE and PCE in indoor air at
some ofthe South Browneil Road residences (Brinkerd 1996) and unacceptable VOC
concentrations in the basement ofthe residence at Lot 3-30 on South Browneil Road The
presence of VOC vapors in the residence on Lot 3-30 is believed to have resulted from
volatilization of groundwater which infiltrated the basement through a continuously operating
sump pump The sump was vented to the exterior ofthe house as part of a state-sponsored
action and the indoor air concentration ofthe contaminants reduced to an acceptable
concentration Therefore one institutional control for the site will be to maintain the sump
venting as long as necessary to prevent health risks due to inhalation of VOC concentrations in
indoor air Also an institutional control in the form of a zoning restriction should be
implemented to prohibit the construction of new buildings with basements below the water table
in the region of contaminated groundwater The restriction should specify that in cases where it
is unavoidable to place the basement below the water table proper containment and venting of
the sump drainage system is required
33 INITIAL SCREENING
Four general categories of remedial technologies were evaluated The first monitoring
may be used alone or in conjunction with other remedies The second category includes
institutional controls to prevent exposure to contamination in groundwater and indoor air
Institutional controls could also be used alone or in conjunction with other remedies The third
category includes source removal technologies
The fourth category includes contaminated groundwater containment technologies such
as a hydraulic barrier or permeable reactive barrier Containment technologies can be applied in
two different ways Thefirst source control application would entail installing the containment
technology directly downgradient ofthe highest dissolved concentrations in an attempt to contain
the contaminated groundwater nearest the source Over time if new contamination is not
FOR ALLING INDUSTRIAL PARK
M WP_DOCSN753 200 (AALUNOFS9^)0 I0030929WTO 3-3 HSI GCOTranS inC
MITEC 104e 02369
allowed to migrate beyond the source VOC concentrations in the downgradient region of
contaminated groundwater should attenuate
The second application would entail installing the containment technology at the
downgradient edge ofthe region of Contaminated groundwater The containment would protect
downgradient receptors from impacts by the region of contaminated groundwater
Both containment technology approaches were considered for use in the event additional
monitoring data shows that the region of VOC-contaminated groundwater is expanding in size
or if VOC concentrations in groundwater discharging to the unnamed brook are increasing
Table 3-2 identifies the remedial technologies considered and summarizes the results ofthe
initial screening for applicability to addressing the ARARs
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES
The list of potentially viable technologies shown in Table 3-2 was subjected to an initial
screening process The purpose ofthe initial screening was to identify those technologies that are
potentially feasible in the Study Area prior to performing a more detailed technology screening
Many ofthe source removal technologies were removed from further consideration because of
the impracticability of remediating residual DNAPL at the site
As described in the SIR (HSI GeoTrans 2000) DNAPL is likely present in the Study
Area Although present DNAPL has not been directly observed in any location and there has
been no indication that there is recoverable DNAPL present The failure to detect DNAPL
directly is not an uncommon situation at DNAPL sites and commonly results from its
heterogeneous distribution or its presence only at residual saturation (US EPA 1992)
Groundwater extraction and treatment is not an effective technology for remediation of residual
DNAPL due to limitations resulting from the limited solubility of most DNAPL compounds and
the heterogeneous distribution ofthe DNAPL (US EPA 1993) Designing remedial strategies
for DNAPL is made difficult by the inability to accurately locate the DNAPL sources This
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320(XAALlJNoFS9^)010030929wro 3 - 4 H S I G C O T r a n S I n C
MITEC 104e 02370
inability to locate the DNAPL renders the use of targeted source remedies that might be cost
effective for a small readily definable source area ineffective These targeted source remedies
include excavation air sparging chemical oxidation in-situ thermal desorption and chemical
flushing technologies
Subsurface deposits in the Study Area are heterogeneous due to the interbedded nature of
the sands and silts overlying an areally extensive clay The presence of such heterogeneity
creates extremely variable and unpredictable groundwater flow velocities as well as flow paths
for DNAPL migration The contrast in permeability and porosity between different lithologies
results in the development of preferential flow pathways While preferential flow through coarse
sand and gravel zones provides higher than average groundwater flow rates and contaminant
flushing less preferential flow pathways such as silty sands silts and clays remain poorly
flushed even under forced hydraulic gradients created by extraction wells Contaminants
however may have migrated to these areas of less preferential flow as DNAPLs under
gravitational influence or by diffusion over long periods of time The low permeability zones
even if addressed by localized extraction of groundwater will transmit only small quantities of
water and hence contaminant flushing is slow This is compounded by the low solubility of
DNAPL constituents and the tendency for them to become trapped in soils by capillary pressure
forces
Specific source removal technologies which have been screened out as ineffective at this
stage include air sparging groundwater amendments excavation and in-situ thermal desorption
Low permeability zones prevent the migration of soil vapors or sparged air to the near-surface for
recovery due to the preferential flow caused by heterogenieties it is not possible to determine if
amendments which can be added to the groundwater or chemical flushing compounds which
displace the groundwater and help liberate residual DNAPL such as oxidants alcohol polymers
andor surfactant would reach the DNAPL Excavation which has already been used to remove
impacted surface soils in known release areas is not practical for removing residual DNAPL
deep below the water table The in-situ thermal desorption can be useful in some environments
FOR ALLING INDUSTRIAL PARK
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MITEC 104e 02371
but can also induce downward DNAPL migration if hydraulic control ofthe system is not
complete Because the location of residual DNAPL is not known and because hydraulic control
ofthe underlying silt clay and till into which the DNAPL may migrate cannot be assured in-situ
thermal desorption is not feasible for this site
Monitoring and institutional controls are included in each option evaluated except for the
no-action alternative These are required to rule out possible future health risks due to expansion
ofthe region of VOC-contaminated groundwater or the creation of new contaminant exposure
pathways
The technologies remaining after the initial screening are presented in Table 3-3
FOR ALLING INDUSTRIAL PARK
MWP_DOCSN753200OALUNCFS9^XM0030929 WPD 3-6 HSI GCOTranS ItlC
MITEC 104e 02372
Table 3-1 Remedial action objectives
MEDIA REMEDIAL ACTION OBJECTIVE
Groundwater -Remove or control contaminant sources
bullAttain VT Groundwater Enforcement Standards
-Prevent expansion ofthe region of contaminated groundwater
-Prevent use of groundwater within the region of contaminated groundwater as a
potable water supply where contaminant concentrations exceed federal drinking
water standards
Surface Water -Attain VT Water Quality Criteria
Air -Prevent inhalation of concentrations in indoor air derived from groundwater
FOR ALLING INDUSTRIAL PARK MWP DOCSW7520(XMUJNOFS9^XM0030929WPO 3-7 HSI GeoTrans inc
MITEC 104e 02373
-n Table 3-2 Description of potentially viable remediation technologies o w o
i mi m rshym
o n o gt lt
CJ I
00
I W O mOH
gt Z
R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Basement Sump Venting
Restriction on new buildings with basements set below the water table
Restrict Potable Use of Groundwater
Excavation
Natural Gradient Flushing
Air Sparging
RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
PROCESS DESCRIPTION OPTIONS
No Action No Action
Monitor groundwater concentrations to confirm that region of VOC-contaminated groundwater is not expanding in size
Monitor surface water concentrations in unnamed brook to ensure concentrations remain below risk levels
Continue to vent the sumps at Lot 3-30 on South Browneil Road
Restrict construction of any new buildings with basements set below the water table within the area of dissolved VOC contamination and require basement sump venting in those where a below water table basement is unavoidable
Place restrictions on potable use of groundwater at properties overlying the region of VOCshy contaminated groundwater
Excavation and removal of soils containing residual DNAPL
Continued dissolution and natural attenuation of residual DNAPL
Injection of air beneath the water table to volatilize residual DNAPL and dissolved concentrations in groundwater
INITIAL SCREENING C O M M E N T
Used as a baseline for comparison No cost Long remediation time
Can be used in conjunction with other response actions Will be required in the southwest portion ofthe region of contaminated groundwater since existing data are inconclusive regarding this issue
Can be used in conjunction with other response actions
Will be required until data show there is no longer a risk to indoor air from groundwater in the basement
Will be required until data show there is no risk of migration of VOCs to indoor air from groundwater
Will be required at all properties in the area of VOC-contaminated groundwater to prevent a risk to human health
Has been used at the site to remove residual DNAPL in soils in the release areas Impractical to recover residual DNAPL at depth The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Intermediate cost Short time frame to cleanup if all residual source can be removed
Higher permeability zones are preferentially remediated On-going monitoring required No installation or on-going maintenance costs Long time frame to cleanup
Small-scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Intermediate installation and high on-going maintenance costs
MITEC 104e 02374
5 T l O Description of potentially viable remediation technologies (continued) PO
Table 3-2 O
RESPONSE REMEDIAL PROCESS g 5 ACTION TECHNOLOGY OPTIONS 5 m
r-m Source Chemical Ozone m Removal Oxidation Sparging q JO o n o
o
Potassium Permanganate Injection
Fentonss Reagent Injection
i co
Source In-Situ Steam Removal Thermal Stripping
Desorption
Electrical Resistance Heating
I Radio (pound Frequency
O m Heating OH 3) gt Z 0)
DESCRIPTION
Injection of air and encapsulated ozone beneath the water table to oxidize dissolved DNAPL constituents such as TCE
KMn04 is injected below the water table to oxidize dissolved DNAPL constituents
Fentons Reagent is injected below the water table to oxidize dissolved DNAPL constituents
Stream injected below the water table As the groundwater and soil are heated residual DNAPL is mobilized and collected by groundwater and soil vapor extraciion techniques
Low frequency alternating current is applied below the water table to cause resistive heating ofthe soil and groundwater As the groundwater and soil heat residual DNAPL is mobilized Groundwater and soil vapor extraction techniques are used to collect dissolved and vaporized DNAPL constituents
Electromagnetic radiation is applied below the water table As the groundwater and soil heat residual DNAPL is mobilized
INITIAL SCREENING COMMENT
Presence of DNAPL will potentially require large quantities of ozone The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Small scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Ozone is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of KMn04 The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of Fentons Reagent The exact location of the residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Fentons Reagent is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Small scale heterogenieties can result in channeling during steam injection and reduce the recovery efficiency Shallow depth of application may preclude effective steam control The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeneity has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeniety has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult so target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
_ mdash_ mdash _ _
MITEC I04e 02375
bulln Table 3-2 Description of potentially viable remediation technologies (continued) o
R E S P O N S E
A C T I O N
tn Source Removal
Source Containment Plume Management
co bull
o
lt)
o mOH 30 gt Z OJ
REMEDIAL
TECHNOLOGY
Chemical Flushing
Hydraulic Containment
Impermeable Barrier
Permeable Reactive Barrier
Phytoshyremediation
PROCESS
OPTIONS
bull
DESCRIPTION
Injection and recovery of alcohol polymers andor surfactant below the water table to enhance dissolution of residual DNAPL
Pump groundwater in downgradient portion of VOC-contaminated region groundwater to intercept contamination before it reaches a receptor or downgradient ofthe highest concentrations as source containment
Impermeable barrier is installed in the subsurface to contain groundwater and reduce the pumping rate needed for containment Can be installed upgradient of a receptor to prevent exposure or downgradient of the highest concentrations as source containment
Reactive material such as zero valent iron placed in flow path of contaminated groundwater Contaminants are treated as the natural gradient causes groundwater to flow through the barrier
Extracting of contaminated groundwater by evaporation from high water use trees Organic contaminants may also be biodegraded by the root system or may adsorb to living or dead root tissue and become immobilized
INITIAL SCREENING C O M M E N T
Higher permeability zones are preferentially remediated The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Groundwater extraction is required to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent fulfresidual DNAPL removal Very high installation and operation cost
Effective in containing dissolved concentrations Relatively low installation cost moderate on-going maintenance costs
Effective in containing dissolved concentrations Requires groundwater extraction and treatment Moderate installation cost moderate on-going maintenance costs
Moderate installation costs Lifetime of reactive material difficult to predict and reinstallation may become necessary No on-going maintenance costs prior to replacement
Still experimental Hard to confirm water usage rates and prove containment Trees may require ongoing monitoring and replacement Low installation and maintenance costs Only operates during the growing season
MITEC 104e 02376
1 T l Table 3-3 Selection of potentially viable remediation technologies for detailed analysis 1
rt g g g
5
i 8 5
3
CO
o m O H JO gtZW
o3 O tn
spound r m rshymO
M nn o
gt zbulllt
RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Indoor Air Monitoring
Basement Sump Venting
Potable Use of Groundwater
Restrict Basements Below Water Table
Excavation
Natural Gradient Flushing
Air Sparging
Chemical Oxidation
In-Situ Thermal Desorption
Chemical Flushing
PROCESS
OPTIONS
No Action
Ozone Sparging
Potassium Permanganate Injection
Fentonss Reagent Injection
Steam Stripping
Electrical Resistance Heating
Radio Frequency Heating
RETAINED
DISCARDED
Retained
Retained
Retained
Retained
Retained
Retained
Retained
Discarded
Retained
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
RATIONALE
Used as a baseline for comparison
Necessary to evaluate if the region of VOC-contaminated groundwater is expanding in size and if the VOC concentrations in groundwater discharging to the unnamed brook are increasing
Necessary to monitor that concentrations remain below health risk levels
May be required al new residences with basements below the water table built in Browneil Road area
The existing sump vents at Lot 3-30 on South Browneil Road will be required to mitigate indoor air risks
Restriction of potable use of groundwater at properties overlying the region of VOC-contaminated groundwater will be required to prevent dermal ingestion and inhalation exposure
Restriction of construction of new basements below the water table in the area of VOC-contamination will be required to prevent future inhalation risks
Residual DNAPL located too far below ground surface to make excavation feasible The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Excavation of known release areas has occurred
Longer time frame to clean up not a drawback at this site Lower cost is a benefit
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location of the residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL Steam control difficult
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
MITEC 104e 02377
2 Table 3-3 Selection of potentially viable of remediation technologies for detailed analysis (continued) a m RESPONS E R E M E D I A L PROCES S RETAINED RATIONALE
ACTION T E C H N O L O G Y OPTION S DISCARDED
Source Containment Hydraulic Containment Retained Proven effective at containing expansion ofthe region of contaminated groundwater Region of Contaminated
iisect
n n o
Groundwater Management
Impermeable Barrier Retained Proven effective at region of contaminated groundwater containment
Permeable Reactive Retained Proven effective at region of contaminated groundwater containment Barrier
Phyto-remediation Retained Experimental however there are no potential negative consequences in using the technology Low cost is a benefit
co i
IO
I (A O m OH 73 gtZ
MITEC 104e 02378
4 DETAILED ANALYSIS OF ALTERNATIVES
41 ALTERNATIVE 1 NO ACTION
The no-action alternative is included in accordance with EPAs Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA (EPA 1988) The no-action
alternative provides a baseline for comparison and involves taking no additional actions at the
Study Area This remedy assumes no continuing monitoring of dissolved concentrations in
groundwater surface water or concentrations in indoor air This remedy assumes no institutional
controls on basement sump venting at Lot 3-30 on South Browneil Road property no restrictions
on new buildings with basements set below the water table constructed within the area of VOC
concentrations in groundwater and no restrictions groundwater use for potable purposes within
the region of VOC-contaminated groundwater
411 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community The risk assessment completed for the SIR
(HSI GeoTrans 2000) concluded that current conditions at the Study Area do not pose a risk to
human health Current conditions include venting ofthe sump at Lot 3-30 on South Browneil
Road no buildings other than at Lot 3-30 with basements below the water table in VOC-
contaminated areas and no potable-use wells within the region of VOC-contaminated
groundwater Without institutional controls to ensure this there may be future risk The risk
evaluation indicated that concentrations in the unnamed brook resulting from contaminated
groundwater discharge while not above risk-based thresholds were close to levels that could
pose a risk to human health Therefore monitoring is advised to confirm that VOC
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7533000AUJNOFS9^010030929WPD 4 - 1 HSI GGOTrSOS jflC
MITEC 104e 02379
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of VOC-contaminated groundwater could result in health risks not
evaluated in the risk assessment
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative
Time to Achieve Remedial Action Objectives It is estimated that the time frame required
for natural attenuation of contaminants to meet the groundwater cleanup concentrations will
significantly exceed the two-year time frame used to evaluate short-term effectiveness
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment There is no treatment of contaminants under this option
Reduction in Toxicity Mobility or Volume Some reduction of residual DNAPL and
accompanying dissolved concentrations is expected through natural attenuation over time if no
action were pursued at the Study Area However no monitoring data would be available to
confirm the progress
Amount of Material Contained or Treated Natural attenuation may serve to contain the
entirety of the region of groundwater contaminated with dissolved VOCs
413 LONG-TERM EFFECTIVENESS
Residual Risk Therisk assessment completed for the SIR (HSI GeoTrans 2000)
concluded that current conditions at the Study Area do not pose a risk to human health
However the risk evaluation indicated that concentrations in the unnamed brook resulting from
contaminated groundwater discharge while not above risk-based thresholds were close to levels
that could pose a risk to human health Therefore monitoring is advised to confirm that VOC
FOR ALLING INDUSTRIAL PARK
M W P _ D O C S N 7 5 3 2 0 0 0 A L U N O F S W raquo I 0 0 3 0 9 2 9 W P D 4-2 HSI GeOTrdDS IflC
deg2380
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of contaminated groundwater could result in health risks not evaluated in
the risk assessment Without institutional controls to ensure basement sump venting at Lot 3-30
on South Browneil Road restrictions on new buildings with basements set below the water table
within the region of VOC-contaminated groundwater and prevention ofthe installation of wells
for potable supplies within the region of VOC concentrations in groundwater a residualrisk to
human health remains
Adequacy and Reliability of Controls This remedy does not assume the sump in the
basement ofthe residence at Lot 3-30 on South Browneil Road remains sealed and vented to the
outside and that the pump is maintained in operable condition to continue to keep groundwater
out ofthe basement Previous air sampling conducted by the VTDEC has confirmed that this is
necessary to control indoor air impacts to this residence This remedy relies on natural
attenuation to control the region of VOC-contaminated groundwater however there is no
continuing monitoring of dissolved VOC concentrations in groundwater Since monitoring to
date has not confirmed that the region of VOC-contaminated groundwater is not expanding in
size a remedy which has a natural attenuation component but does not include monitoring does
not provide adequate control
Permanence of Remedy In the very long-term natural gradient flushing should reduce
VOC concentrations in groundwater to acceptable levels
414 COMPLIANCE WITH ARARs
Groundwater Protection Rule and Strategy It is expected that natural attenuation would
over time reduce groundwater concentrations to below VT Groundwater Enforcement Standards
However a no-action response would not comply with VT Groundwater Protection Rule and
Strategy (VTDEC 1997) which allows for remediation of sites by natural attenuation if sufficient
monitoring is perfonned to document that expansion ofthe region of contaminated groundwater
is not occurring and that natural attenuation is occurring The no-action alternative would not
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AU1NGFS90010030929wro 4-3 HSI GSOTraFIS IflC
MITEC 104e 02381
allow for continued monitoring and would not meet this requirement
Surface Water Quality Standards It is expected that natural attenuation would over
time reduce surface water concentrations to below VT Water Quality Criteria for the protection
of human health and aquatic organisms (VTDEC 2000)
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
concentrations of VOCs adsorbed to soil and dissolved in groundwater in the Study Area do not
pose a risk to human health andor the environment under current uses There would be arisk if
groundwater within the region of VOC-contamination were used as a potable supply Therefore
if dissolved concentrations were not migrating beyond the limits ofthe region identified in the
SIR (HSI GeoTrans 2000) and groundwater were not used for potable purposes the no action
alternative would be protective of human health and the environment However there are not
sufficient data to determine whether the region of VOC-contaminated groundwater is stable or
decreasing in size If the region of contaminated groundwater were expanding beyond the limits
upon which the risk assessment was based there may be a future risk to human health and the
environment Also restrictions should be placed on properties overlying the region of VOC-
contaminated groundwater to prohibit construction of basements below the water table and the
use of groundwater as a potable supply and the venting ofthe sump at Lot 3-30 should continue
416 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000AlXINGFS900U0030929wro 4-4 HSI GGOTrdRS IflC
MITEC 104e 02382
Technical Feasibility The no-action alternative is technically feasible
bull Ability to Construct the Alternative The no-action alternative requires no
construction
bull Reliability ofthe Technology No technology would be applied under the no-
action alternative
bull Ease of Undertaking Additional Remedial Actions The no-action alternative
would not prevent future remedial actions
Administrative Feasibility The no-action alternative is administratively feasible
Availability of Services and Materials No services or materials are required to carry out
the no-action alternative
417 COSTS
There are no costs associated with the no-action alternative The no-action alternative is
shown on Table 41 for purposes of comparison
4 2 A L T E R N A T I V E 2 M O N I T O R I N G INSTITUTIONAL C O N T R O L S AND
H Y D R A U L I C C O N T A I N M E N T
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull institutional controls would be implemented to restrict construction of any
buildings with basements within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull groundwater extraction and treatment would be done to contain the region of
VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753laquo000WJJNoFS9JXI10030929wro 4 - 5 HSI GSOTraDS JllC
MITEC 104e 02383
Groundwater pumping is an effective technology for hydraulic containment of
contaminated groundwater Hydraulic containment can be used if the region of VOC-
contaminated groundwater is impacting a sensitive receptor or is expanding is size The risk
assessment (Menzie Cura 2000a and 2000b) showed that groundwater was not impacting any
receptors to a degree that would represent a human health risk or risk to the environment There
is not sufficient temporal data however to confirm that the region of VOC-contaminated
groundwater is not expanding is size Therefore an analysis of hydraulic containment has been
included in this Corrective Action Feasibility Investigation in the event that future monitoring
shows the region of VOC-contaminated groundwater is expanding and that containment is
necessary
If monitoring indicates that natural attenuation is not causing the region of VOC-
contaminated groundwater to be stable in size or to shrink then an active containment remedy
may be required Under this scenario a groundwater pump-and-treat system would be installed
and operated in the Study Area to hydraulically contain contaminated groundwater and prevent
expansion ofthe region of VOC-contaminated groundwater Pumping wells would be installed
in the overburden silts and sands to the clay layer Wells would be installed in the downgradient
portions of contaminated groundwater to the southeast and southwest Extracted groundwater
would be treated before discharge to surface water The primary treatment operation will be air
stripping with a low-profile stripper for the removal of VOCs primarily TCE Depending on
treatment efficiencies secondary treatment with granular activated carbon may be required In
addition a particulate filter may be added to remove iron prior to treatment and reduce iron
fouling ofthe air stripper and carbon Extracted and treated groundwater would be discharged to
surface water via an outfall Compliance sampling can be conducted at the outfall or at a
sampling point within the treatment building The outfall should be constructed to minimize
hydraulic impacts on the receiving water body
The number and location of pumping wells that may be required to capture and contain
the region of TCE-contaminated groundwater has been investigated using the two-dimensional
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9JXA10030929WO 4-6 HSI GSOTfanS IdC
MITEC 104e 02384
analytical element simulation code TWODAN (Fitts 1997) TWODAN is a commercially
available copyrighted program The input parameters to the model are based on the values
reported in the SIR (HSI GeoTrans 2000) Input data sets for the analyses contained in this
report are included in Appendix A The bottom elevation ofthe model is 306 ft which is
representative ofthe top ofthe continuous clay layer beneath the site The model represents the
interbedded silts and fine sand layer and the overlying medium to fine sand surficial unit as one
layer The hydraulic conductivity ofthe modeled layer is 184 ftday The estimated areal
recharge for the model is 10 inyr The basement sump at Lot 3-30 on South Browneil Road
pumps groundwater year round The resulting depression ofthe water table is represented by a
constant head of 33128 ft which is approximately 8ft below ground surface at that location
Groundwater elevations used in the model were based on an average ofthe July 1999 and
December 1999 potentiometric surface in wells with screened intervals intersecting the water
table The model representation of current hydrologic conditions at the Study Area is shown in
Figure 4-1 Groundwater elevations are shown in meters on this figure
Two containment scenarios were evaluated The first was a source control application in
which the TWODAN model was used to determine the number of wells and pumping rates
required to contain the 10000 to 20000+ ugL TCE concentration zone as shown in Figure 1-2
In this scenario pumping would contain the contaminated groundwater nearest the source(s)
Over time if new contamination is not allowed to migrate from the source(s) the VOC
concentrations in the rest ofthe region of contaminated groundwater would attenuate The
second scenario was a containment application in which the TWODAN model was used to
determine the number of wells and pumping rate required to contain the 1000 to 10000 (igL
TCE concentration zone as displayed in Figure 1-2 In this scenario pumping occurs in the
downgradient portions ofthe contaminated groundwater
Each recovery well was assumed to be 4 inches in diameter fully screened and have a
pumping rate of 5 gpm The pumping rate was based on the aquifer testing results reported in the
SIR (HSI GeoTrans 2000) applied to a fully screened extraction well The results ofthe model
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000A1XINOFS9JX)10030929WPD 4-7 HSI GSOTraDS IflC
MITEC 104e 02385
analyses indicate that a minimum of three 4-inch diameter recovery wells pumping at 5 gpm are
required to contain the 10000 to 20000+ ugL TCE concentration zone The results of this
model simulation are shown on Figure 4-2 The model analyses also indicated that a minimum
often 4-inch diameter recovery wells pumping at 5 gpm are required to contain the 1000 to
10000 ugL TCE concentration zone Figure 4-3 shows the results of this model simulation
Figures 4-2 and 4-3 also show that groundwater extraction for hydraulic containment may induce
infiltration of surface water in response to pumping thereby reducing the amount of water
flowing in the brook
421 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 2 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with extraction well construction and treatment plant construction Access by
unauthorized personnel would be restricted by fencing temporary barriers andor warning signs
The groundwater treatment building would be locked and secured A health and safety plan
(HASP) would be prepared for the remedial activities In conformance with Occupational Safety
and Health Administration (OSHA) regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative Suitable dust control measures would be implemented during
construction ofthe groundwater treatment system Additionally the treatment process is
expected to be relatively simple with a low potential for exceedance of discharge limitations
Monitoring ofthe treatment process would be performed
Time to Achieve Remedial Action Objectives The time estimated for well installation
system debugging and establishing hydraulic gradient control is three to six months The RAOs
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^XM0030929wro 4-8 HSI GSOTraOS IIIC
MITEC 104e 02386
for groundwater would be achieved when monitoring results indicated that VOC concentrations
had attenuated and groundwater standards had been met It is estimated that attenuation of VOC
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of recovered groundwater would remove some ofthe VOCs from
the aquifer This treatment would generate residuals such as used filters and spent carbon This
process is irreversible
Reduction in Toxicity Mobility or Volume Treatment ofthe extracted groundwater
would reduce its toxicity prior to surface water discharge Contaminants adsorbed to any
secondary carbon would ultimately be destroyed during the process of regenerating the carbon
Contaminants adsorbed to any particulate filters would be landfilled or incinerated along with the
filters The toxicity and volume of contamination in groundwater are nominally reduced by
extraction and treatment but effectiveness is limited as discussed in Section 421 above
Modeling shows that groundwater extraction would be effective in reducing the mobility ofthe
dissolved phase contamination
Amount of Material Contained or Treated The volume of contaminated groundwater
that would be treated on a long-term basis is estimated at about 8 million gallons per year for the
source containment option and about 26 million gallons per year for containment of all dissolved
TCE concentrations greater than 1000 ugl
423 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
FOR ALLING INDUSTRIAL PARK MWPJXXTSN75320(XAAUJNOFS9-OCM0030929WKgt 4-9 HSI GSOTrSDS IDC
MITEC 104e 02387
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Groundwater pumping would control any risks caused by expansion ofthe
region of contaminated groundwater Residual risk to human health would be controlled through
institutional controls
Adequacy and Reliability of Controls Extracted groundwater would be treated on-site to
standards required for discharge to surface water The extraction well pumps and groundwater
treatment equipment would require maintenance on a long-term basis Groundwater monitoring
to ensure that the contamination was being adequately contained by the groundwater extraction
would be necessary on a long-term basis
Permanence of Remedy The groundwater treatment plant would be enclosed and
designed as a modular system and its equipment would be readily replaceable if required The
extraction wells may need to be rehabilitated andor replaced during the life ofthe remedy
424 COMPLIANCE WITH A R A R S
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to return the
remaining groundwater to below Groundwater Enforcement Standards Groundwater extraction
would also eventually return the areas of highest groundwater contamination to below
Groundwater Enforcement Standards
Surface Water Quality Standards Hydraulic control of the groundwater migration would
interrupt and remove contaminates from groundwater thereby preventing discharge to the
unnamed brook resulting in achievement of Water Quality Criteria for the protection of human
health and aquatic organisms (VTDEC 2000)
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200OALUNoFS9^Kgtl0030929wro 4-10 HSI GOOTrSDS IDC
laquoTEC I04e 02388
425 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The hydraulic containment alternative would offer protection to both human health and
the environment if expansion ofthe region of contaminated groundwater were identified Since
the risk assessment (Menzie Cura 2000a) found that under current conditions groundwater and
surface water concentrations are below levels which constitute a risk to human health and since
hydraulic containment would ensure the region of VOC-contaminated groundwater remained in
the current configuration hydraulic containment would be protective of human health and the
environment This alternative assumes institutional controls will be in place to continue sump
venting in the basement at Lot 3-30 on South Browneil Road restrict the installation of
basements below the water table within the region of VOC-contaminated groundwater and
prevent potable use of groundwater within the region of VOC-contaminated groundwater
Protection would be achieved at the end ofthe construction period of three to six months The
residual risks posed by contaminated material remaining within the groundwater would not be
significant because all potential exposure routes would be addressed
426 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction which would present no special problems
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AUB4CFS9^10l0030929wro 4 - 1 1 HSI GGOTrdDS IDC
MITEC 104e 02389
bull Reliability ofthe Technology Hydraulic gradient control is a frequently used
alternative that has proven effective in preventing further expansion of areas with
- contamination in groundwater Filtration air stripping and carbon absorption
have frequently been used and proven effective in treating groundwater in other
applications
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the
gradient control system was inadequate to restrict the expansion ofthe region of
contaminated groundwater implementation of additional resources would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
operate maintain and monitor the well head portions ofthe treatment system Institutional
controls would also be needed to implement institutional controls to continue sump venting in
the basement at Lot 3-30 on South Browneil Road The town must pass zoning restriction which
would prevent construction of basements below the water table and potable use of groundwater
within the region of contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor the groundwater treatment system associated with the hydraulic containment option
are available
427 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 2 The
capital costs would be $207000 for the source control application and $732000 for the
containment option OampM costs include groundwater monitoring and maintenance ofthe
groundwater extraction and treatment system These are $77000 per year for the source control
application and $139000 per year for the containment option The present worth analysis
(calculated at a 7 discount rate interest for 30 years) yields a total of $1085403 for the source
control application and $2287474 for the plume containment option
FOR ALLING INDUSTRIAL PARK MWPJXXSN753U0OOALUNGFS9-tfW0030929wro 4-12 HSI GSOTrailS IRC
MITEC 104e 02390
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS AND
PERMEABLE REACTIVE BARRIER
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull and a permeable reactive barrier would be installed and maintained at a
downgradient location to reduce concentrations of TCE dissolved in groundwater
as it flows under natural gradient flow conditions if groundwater monitoring
shows the region of VOC-contaminated groundwater is expanding in size
PRBs consist of a permeable region of chemically reactive materials constructed to
intercept the path of a dissolved groundwater contaminants Reactive materials may include
bull zero-valent iron for reductive dehalogenation
precipitation agents such as gypsum to create insoluble metal salts
bull sorptive agents such as granular activated carbon to capture and immobilize organics
bull reducing agents such as dithionite and hydrogen sulfide to reduce and insolubilize metals
and
bull biologic electron acceptors such as lactic acid or nitrate to enhance aerobic
biodegradation
FOR ALLING INDUSTRIAL PARK MAWPJX)CSVN7532000AmNOFS9-OOU0030929wpo 4-13 HSI GSOTrSDS IDC
MITEC 104e 02391
Zero-valent iron and granular activated carbon are both applicable for use in the treatment
of TCE in a PRB Granular zero-valent iron has been widely applied in PRB installations and
promotes reductive dehalogenation of TCE to chloride ion ethane and ethene Activated carbon
has been used in a limited number of field and lab studies to simply adsorb dissolved organic
constituents as they pass through thePRB
Because ofthe costs ofthe reactive or adsorptive material PRBs are generally
constructed as a funnel and gate system The funnel portion ofthe PRB is a typical vertical
barrier wall constructed of sheet piles bentonite or other impermeable material which is
designed to direct groundwater flow to the gate portion ofthe PRB containing the reactive or
adsorptive material Funnel and gate sections ofthe PRB are keyed together and generally to a
low permeablility zone located at depth
The use of permeable reactive barriers is not directly applicable to treatment of DNAPL
The mechanism for groundwater remediation using a PRB would include
bull dissolution ofthe DNAPL into groundwater by natural processes
bull downgradient transport ofthe dissolved contaminants to the PRB location
artificial channeling ofthe contaminated groundwater to the reactive material located in
the gate by the barrier funnel and
bull reductive dehalogenation or adsorption of a portion ofthe VOC as is passes through the
gate
A variety of methods are available for emplacement ofthe PRB The most conventional
method includes excavation of a trench and backfill will a soilbentonite slurry for the funnel
portion and granular iron or carbon in the gate section Other methods such as sheet-piling jet
grouting continuous trenching fracturing and others are available For the subject site because
ofthe presence of sand in the formation it is likely that a continuous trenching method would be
the most applicable and cost effective
FOR ALLING INDUSTRIAL PARK MWPJX)CSN7S320O0ALUNGFSraquo-O0U0030929wro 4-14 HSI GGOTfaDS IOC
MITEC 104e 02392
Operation maintenance and monitoring ofthe PRB is relatively simple Groundwater
samples would be periodically collected from locations upgradient and downgradient ofthe gate
section(s) ofthe PRB to monitor its effectiveness Media installed in the gate (iron or carbon)
would require periodic replacement probably on a annual basis for carbon and every 5 to 10
years for iron
The placement depth width and length ofthe PRB would depend on the region of
VOC-contaminated groundwater that was desired to be intercepted the depth to the underlying
low permeability layer and the desired TCE concentration reduction (which determines resident
time required in the gate) As wilh hydraulic containment two scenarios were investigated The
first a source control option would intercept VOC-contaminated groundwater with TCE
concentrations greater than 10000 ugL A PRB of approximately 1200 feet in length would be
required The second a region of contaminated groundwater containment option would
intercept VOC-contaminated groundwater with TCE concentrations in excess of 1000 ugL A
PRB of approximately 2200 feet in length would be required The depth ofthe PRB in both
cases would likely extend from ground surface to about 40 feet below ground surface The PRB
would be installed into the underlying areally-extensive clay layer Figure 4-4 shows the
placement ofthe PRB under each opinion
431 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 3 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with PRB construction since either conventional or continuous trenching methods
would be employed during its construction However exposure hazards during construction
would be considerable since the emplacement requires excavation and handling of a large
volume of potentially contaminated soils During construction access by unauthorized personnel
would be restricted by fencing temporary barriers andor warning signs Following
FOR ALLING INDUSTRIAL PARK
MWP_DOCSN753 2000 AUJNCFS9^10 10030929 WPD 4-15 HSI GSOTrSPS IDC
MITEC 104e 02393
construction little to no hazards should be expected from the long-term operation ofthe PRB A
HASP would be prepared for the construction activities In conformance with OSHA
regulations site workers would be trained required to wear appropriate protective equipment
and as applicable would be enrolled in a medical monitoring program Groundwater monitoring
wells would be sampled to determine changes in VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative with proper controls Suitable dust control vapor monitoring and
stormwater runoff measures would be implemented during construction ofthe PRB
Time to Achieve Remedial Action Objectives The time estimated for PRB emplacement
is four to six months The RAOs for groundwater would be achieved when monitoring results
indicated that the VOC concentrations have attenuated and groundwater standards have been
met It is estimated that attenuation of contaminant concentrations to ARARS will significantly
exceed the two-year time frame for short-term effectiveness This is because the application of a
PRB at the site would not significantly alter groundwater flow or TCE dissolution from within
the source area Therefore it would not increase the rate at which concentrations of residual
DNAPL or dissolved constituents of DNAPL (TCE) were removed from the source area It
would however limit the size ofthe region of VOC-contaminated groundwater
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of groundwater flowing through the permeable sections ofthe PRB
would remove the dissolved TCE as is flows under natural gradient conditions from the source
area
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNGFS9^X)10030929WPO 4-16 HSI G G O T T S O S jflC
MITEC 104e 02394
Reduction in Toxicity Mobility or Volume Treatment ofthe groundwater would reduce
its toxicity Contaminants adsorbed to carbon (if used as the treatment media in the gate sections
ofthe PRB) would be excavated on a periodic basis and ultimately be destroyed during the
process of regenerating the carbon
Amount of Material Contained or Treated The volumetric flux of contaminated
groundwater through the PRB is estimated to be approximately two million gallons per year for
the 10000 (igL source containment option and approximately four million gallons per year for
containment of all dissolved TCE concentrations greater than 1000 ugL
433 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Treatment of groundwater intersecting the PRB would control any risks
caused by expansion ofthe region of contaminated groundwater to the southeast Residual risk
to human health would be controlled through institutional controls
Adequacy and Reliability of Controls Performance of PRBs in reducing concentrations
of chlorinated organics such as TCE using zero-valent iron has been mixed Most ofthe PRB
performance demonstrations indicate that a concentration reduction of 60 to 90 percent can be
expected Some applications however have been much less successful at reducing VOC
concentrations Although little experience is available for PRBs using activated carbon the
removal efficiency should be expected to be greater and more reliable than zero-valent iron but
far more costly Groundwater monitoring would ensure that the contamination was being
adequately contained by the PRB and would be necessary on a long-term basis
Permanence of Remedy Installation of a PRB would be considered a permanent remedy
although periodic maintenance and replacement of reactive material in the gate would be
required for both carbon and iron-based systems
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9^X)l0030929wro 4-17 HSI GGOTfSnS IDC
MITEC 104e 02395
434 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to reduce VOC
concentrations in the remaining groundwater to below Groundwater Enforcement Standards
Natural gradient flushing would also eventually reduce the areas of highest groundwater
contamination to below Groundwater Enforcement Standards
Surface Water Quality Standards VOC concentrations in groundwater discharging to the
unnamed brook would be reduced significantly Thus operation ofthe PRB would result in
achievement of Water Quality Criteria for the protection of human health and aquatic organisms
(VTDEC 2000)
435 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This downgradient containment alternative would offer protection to both human health
and the environment if VOC concentrations in groundwater discharging to the unnamed brook
were to increase or if the region of contaminated groundwater were to expand in size This
alternative assumes institutional controls will be in place to continue sump venting in the
basement at Lot 3-30 on South Browneil Road restrict installation of new basements below the
water table within the region of VOC-contaminated groundwater and prevent potable use of
groundwater within the contaminated region Protection relative to the risks posed by expansion
ofthe region of contaminated groundwater to the unnamed brook would be achieved at the end
ofthe construction period of four to six months The residual risks posed by contaminated
material remaining within the groundwater would not be significant because all potential
exposure routes would be addressed
FOR ALLING INDUSTRIAL PARK MWP JX3CSN753V2000AIXINOFS90Crl0O30929wPD 4-18 HSI GCOTtSHS IRC
MITEC 104e 02396
436 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
bull Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction Removal and handling of contaminated soils
presents potential risks to construction workers during construction which could
be minimized through health and safety controls
bull Reliability of the Technology Although many full-scale applications of this
approach have been conducted they have been relatively recent Long-term
reliability and effectiveness of PRBs has not been established
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the PRB
was inadequate to prevent expansion ofthe region of VOC-contaminated
groundwater implementation of additional resources would not be hampered by
this alternative
Administrative Feasibility Installing and maintaining the PRB will require access to
properties overlying the region of VOC-contaminated groundwater Additionally property
owner cooperation would be needed to operate maintain and monitor wells located upstream
and downstream ofthe gate sections ofthe PRB system Restrictions would also be needed to
implement institutional controls to continue sump venting in the basement at Lot 3-30 on South
Browneil Road restrict the construction of basements below the water table within the region of
VOC-contaminated groundwater and prevent potable use of groundwater within the region of
VOC contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UO(XAAUJNOFS9-O0 10030929 WPO 4-19 HSI GGOTrSMS IDC
MITEC 104e 02397
Availability of Services and Materials The materials equipment and personnel required
to design install and maintain the PRB are readily available
437 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 3 The
capital costs would be $572000 for the source control application and $1022000 for the
containment option OampM costs include groundwater monitoring and periodic replacement of
the permeable barrier These average $64000 per year for the source control application and
$112000 per year for the containment option The present worth analysis calculated at a 7
discount rate over a 30-year duration yields a total of $1277356 for the source control option
and $2248691 for the containment option
4 4 A L T E R N A T I V E 4 M O N I T O R I N G I N S T I T U T I O N A L C O N T R O L S AND
N A T U R A L A T T E N U A T I O N
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water
The chief mechanisms contributing to reduction of contaminant concentrations in
groundwater by natural attenuation include biotransformation dilution dispersion and discharge
through advective flow and volatilization (EPA 1998) Volatilization is not likely a major
mechanism at the Study Area since contaminated groundwater is located at depth below the
FOR ALLING INDUSTRIAL PARK
MWP_DOCSW7S3U000WXINoFS9-001003O929wro 4-20 HSI GGOTfaDS IDC
MITEC 104e 02398
water table A natural attenuation evaluation will be conducted to better identify the mechanisms
contributing to concentration reduction through natural attenuation Monitoring to be completed
for this evaluation is included in Section 62 EPAs Technical Protocol for Evaluating Natural
Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) was used as the basis for the
design ofthe natural attenuation evaluation
441 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community A HASP would be prepared for the remedial
activities In conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Groundwater monitoring wells would be sampled to determine changes in
VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative
Time to Achieve Remedial Action Objectives The RAOs for groundwater would be
achieved when monitoring results indicated that the region of contaminated groundwater had
naturally attenuated and groundwater standards had been met It is estimated that natural
attenuation of contaminants to ARARS will exceed the two-year time frame for short-term
effectiveness
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0ALUNOFS9^X)M0030929wro 4-21 HSI GGOTfaflS jflC
MITEC 104e 02399
Treatment This alternative involves only natural in-situ processes No remediation
wastes would be generated
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area
Amount of Material Contained or Treated Natural attenuation may serve to contain the
region of VOC-contaminated groundwater at the Study Area Treatment may be accomplished
through biotransformation ofthe contaminants to environmentally acceptable compounds
443 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation of VOC-contaminated groundwater at the Study Area
would eventually achieve the ARARs Residual risk to human health would be controlled
through institutional controls Implementing institutional controls to maintain the sump venting
at Lot 3-30 on South Browneil Road restrict the construction of basements below the water table
within the region of VOC-contaminated groundwater and to control the use of groundwater
within the region of VOC-contaminated groundwater for potable purposes would provide
protection against the potential for exposure
Adequacy and Reliability of Controls Monitoring for VOC concentration reductions in
groundwater and institutional controls would be the main controls of this alternative Sump
venting at Lot 3-30 on South Browneil Road would prevent indoor air impacts at this location
and restrictions on construction of basements below the water table would prevent future indoor
air impacts Control ofthe use of groundwater within the region of VOC-contaminated
groundwater for potable purposes would minimize potential use of groundwater with VOCs
above federal and state drinking water standards Groundwater monitoring would ensure that
attenuation of VOC concentrations was proceeding and provide for periodic assessment ofthe
region of VOC-contaminated groundwater in the Study Area
FOR ALLING INDUSTRIAL PARK bull MWPJXXSN7532000AUINOFS9-00I0O30929WPD 4 - 2 2 HSI GGOTPaMS IRC
MITEC 104e 02400
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time
444 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
445 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
446 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK _
M W P _ D O C S N 7 5 3 U O O O A L U N O F S 9 - O O U 0 0 3 0 9 2 9 W P O 4-23 HSI GGOT 13118 IflC
MITEC 104e 02401
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
bull Ability to Construct the Alternative No major construction is included in this
alternative
bull Reliability ofthe Technology Ongoing monitoring and evaluation on would
ensure that natural attenuation was controlling and remediating the contaminated
groundwater
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation was not restricting the size ofthe region of VOC-contaminated
groundwater implementation of additional remedial actions would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
sample and maintain monitoring wells Restrictions would also be needed to implement
institutional controls to continue sump venting in the basement at Lot 3-30 on South Browneil
Road restrict construction of basements below the water table in VOC-contaminated
groundwater and prevent potable use of groundwater within the region of VOC-contaminated
groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor natural attenuation are also available
447 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 4 The
capital costs would be $55000 and include the initial natural attenuation evaluation and the
implementation of institutional controls OampM costs include groundwater monitoring These are
$9000 per year The present worth analysis yields a total of $163083 for this 30-year
alternative
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0AUJNOFS9^X)10030929wro 4-24 HSI GGOTraDS 1110
MTECl04e 02402
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water and
phytoremediation would be used to intercept TCE-contaminated groundwater
where it discharges to the unnamed brook
In this alternative all components of Alternative 4 would be implemented and
phytoremediation would be implemented in the area where TCE- contaminated groundwater
intersects the unnamed brook to intercept the contaminated groundwater and reduce the amount
of VOCs reaching the brook Phytoremediation of VOCs is still an experimental technology
Several field studies have used hybrid poplars (EPA 2000) to extract TCE- contaminated
groundwater It has been shown that TCE is removed along with groundwater by the trees and
metabolized as well as transpired from the leaves The rate of TCE contaminant removal from
the groundwater and its discharge to air by transpiration varies based on site specific conditions
and season Therefore contaminant or groundwater removal rates are impossible to predict at
this time without field studies Trees may be subject to destruction by natural disasters and pests
Their condition must be monitored and they may require replacement
F O R ALLING INDUSTRIAL PARK MWPJXXSN7532OOOWXINGFS9JraquoIOO30929WPO 4 - 2 5 H S I G G O T r S D S IOC
MITEC 104e 02403
In order for interception ofthe region of contaminated groundwater to be effective the
trees must be planted so that the root zone intercepts the contaminated groundwater Due to the
depth ofthe higher VOC concentrations in most areas ofthe site phytoremediation would be
ineffective in containing expansion ofthe region of contaminated groundwater An exception to
this is the area near the unnamed brook According to the SIR (HSI GeoTrans 2000) VOC-
contaminated groundwater appears to be discharging upward in groundwater into the unnamed
brook Trees planted along the border ofthe brook may help to intercept this contaminated
groundwater before it discharges into the brook
451 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 5 are as follows
Protection of Workers and the Community Normal landscaping hazards would be
associated with installation ofthe trees A HASP would be prepared for the remedial activities
In conformance with OSHA regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative Suitable dust control measures would be implemented during
planting of trees
Time to Achieve Remedial Action Objectives The time required for maximum
interception ofthe contaminated groundwater by the trees would depend on site specific
conditions such as root growth rate and tree survival rate The RAOs for groundwater would be
achieved when monitoring results indicated that VOC concentrations had attenuated and
groundwater standards had been met It is estimated that natural attenuation of contaminant
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
FOR ALLING INDUSTRIAL PARK MWP J X 3 C S N 7 5 3 2 0 0 0 A U J N O F S 9 ^ ) 0 1 0 0 3 0 9 2 9 W P D 4-26 HSI G G O T H S I I S IDC
MITEC 104e 02404
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment This alternative involves only in-situ treatment ofthe groundwater Plant
tissue would be analyzed for the presence of VOCs Plant materials can bio-accumulate metals
present in soil and groundwater If concentrations are high enough dead plant matter may have
to be disposed in an appropriate manner
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area Phytoremediation may
metabolize some ofthe VOCs
Amount of Material Contained or Treated Natural attenuation and phytoremediation
may serve to prevent expansion ofthe region of VOC-contaminated groundwater at the Study
Area Treatment is accomplished with biotransformation ofthe contaminants to environmentally
acceptable compounds
453 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation ofthe region of VOC-contaminated groundwater and
phytoremediation at the Study Area would eventually achieve the ARARs Implementing
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil Road
restrictions on construction of basements below the water table in regions of VOC-contaminated
groundwater and to control the use of groundwater for potable purposes within the region of
VOC-contaminated groundwater would provide protection against the potential for exposure
FOR ALLING INDUSTRIAL PARK MWP_IXXSW532000ALL1NOFS9^)0I0030929WTO 4-27 HSI GCOTraDS IflC
M l T E C l 0 4 e 0240S
Therefore despite the fact that an extended time period may be required to reduce VOC
concentrations to an acceptable level the residual risk associated with this alternative would be
minimal Trees planted near the unnamed brook may serve to intercept contaminated
groundwater before it discharges to this receptor
Adequacy and Reliability of Controls Groundwater monitoring for natural attenuation
institutional controls and interception of contaminated groundwater before it reaches the
unnamed brook would be the main controls of this alternative Sump venting at Lot 3-30 on
South Browneil Road would prevent indoor air impacts at this location and restriction on the
construction of new basements below the water table within the region of VOC-contaminated
groundwater would prevent future indoor air impacts at other locations Control ofthe use of
groundwater for potable purposes within the region of VOC-contaminated groundwater would
minimize potential use of groundwater with VOCs above federal and state drinking water
standards Groundwater monitoring would ensure that natural attenuation of contaminants was
proceeding and provide for periodic assessment ofthe region of VOC-contaminated groundwater
in the Study Area Groundwater and surface water monitoring would also be conducted to
monitor success ofthe phytoremediation in intercepting contaminated groundwater before it
reaches the unnamed brook
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time Trees must be monitored and will be replaced in
the event of destruction by severe weather pests or other reasons
454 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUINOFS9-00I0030929WPD 4-28 HSI GGOTraflS IllC
MITEC 104e 02406
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
Phytoremediation at the edge ofthe unnamed brook would further reduce the VOC
concentrations in groundwater discharging to the brook
455 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
456 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
Ability to Construct the Alternative Installation of this alternative requires
landscaping skills which are readily available
bull Reliability ofthe Technology Ongoing monitoring and evaluation would ensure
that natural attenuation was controlling and remediating the contaminated
groundwater Ongoing monitoring ofthe condition ofthe trees would also be
required to ensure they are continuing to grow and do not need replacement
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^)OM0030929WPD 4-29 HSI GGOTfaDS jflC
MITEC 104e 02407
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation and phytoremediation were not restricting the size ofthe region of
VOC-contaminated groundwater implementation of additional resources would
not be hampered by this alternative
Administrative Feasibility Planting trees and if necessary installing and monitoring
additional wells might require access to private property Additionally property owner
cooperation would be needed to sample and maintain monitoring wells Restrictions would also
be needed to implement institutional controls to continue sump venting in the basement at Lot 3shy
30 on South Browneil Road restrict construction of new basements below the water table in
regions of VOC-contaminated groundwater and prevent potable use of groundwater within the
region of VOC-contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to plant the trees and monitor natural attenuation are also available
457 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 5 The
capital costs would be $80000 and include the initial natural attenuation evaluation the
implementation of institutional controls and installation of a phytoremedial barrier of poplars
OampM costs include groundwater monitoring and maintenance ofthe phytoremedial barrier
These are $11000 per year The present worth analysis yields a total of $209397 for this 30shy
year alternative
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000ALLINOFS9^)0I0030929WPD 4-30 HSI GGOTfaDS IPC
MITEC 104e 02408
r TI Table 41 Cost estimates for remedial alternatives i deg 5 70
8 P
QUANTITY UNITS UNIT C O S T CAPITA L C O S T ANNUAL
OampM C O S T
5 n Alternative I No Action 8 O a Q
na na $0 $0 $0 a sect
Total $0 $0
Alternative 2 Monitoring Institutional Controls and Hydraulic Containment
1) Implement Institutional Controls 32 properties $10000 $32000
2) Groundwater Monitoring $9000
3) Pumping System
Option 1 Source Containment
Extraction wellspiping $50000 $15000
Electrical distributioncontrol $25000 $8000
Construction oversight $25000
Groundwater treatment system $75000 $45000
Total Option 1 $207000 $77000
Option 2 region of contaminated
groundwater Containment
Extraction wellspiping $175000 $35000
w Electrical distributioncontrol $50000 $20000
O
o H mO Construction oversight $125000
o n gt Groundwater treatment system $350000 $75000
o z 0) Tolal Option 2 $732000 $139000
i deg QUANTITY UNITS UNI T C O S T
5 so
Alternative 3 Monitoring Institutional Controls and Permeable Barrier
m t - 1) Implement Institutional Controls 32 properties $10000
9 O 2) Groundwater Monitoring
| o 3) Permeable Harrier
Option I Source Containment
Barrier installation 1200 feel $450
Total Option 1
Option 2 region of contaminated
groundwater Containment
Barrier Installation 2200 feet $450
w Total Option 2 NJ
Alternative 4 Monitoring Institutional Controls and Natural Gradient Flushing
1) Implement Institutional Controls 32 properties $10000
2) Groundwater Monitoring
3) Natural Attenuation Evaluation
Total
Alternative 5 Monitoring Institutional Controls Natural Gradient Flushing and Phytoremediation
1) Implement Institutional Controls 32 properties $10000 X (A 2) Groundwater Monitoring
reg 3
o m O H
3) Natural Attenuation Evaluation
4) Phytoremediation
gt z Total (A
Notes na = not applicable
CAPITAL C O S T
$32000
$540000
$572000
$990000
$1022000
$32000
$23000
$55000
$32000
$23000
$25000
$80000
ANNUAL
OampM C O S T
$9000
$55000
$64000 1
$103000
$112000
$9000
$9000
$9000
$2000
$11000
MODEL CALCULATED GROUNDWATER CONTOUR IN FEET ABOVE MEAN SEA LEVEL
APPROXIMATE PROPERTY BOUNDARY
M6-2 raquo EXISTING MONITORING WELL
CP-6 bull EXISTING SOIL BORING
M 8 - 2 raquo MONITORING WELL (RESAMPLED)
bull SMALL DIAMETER BORING - BELOW CLAY
bull BEDROCK MONITORING WELL
A S I - 2 I H S I GEOTRANS WELL CLUSTER LOCATION
U-TRIB-8a SURFACE WATER SAMPLING LOCATION R S - U
a PASSIVE SAMPLER LOCATION
T2-2 PROFILE SAMPLE LOCA1ION (JOHNSON COMPANY 1999)
WELL DESTROYED
TEF Concentrat ions ( u g A l
1000 - 10000
iry IOOOO - 20000
bull 20000 + NOTES AREA WHERE TCE CONCENTRATION IS
M l LOCATIONS APPROXIMATE INTERPOLATED THERE IS NO TCE
BASE PUN DEVELOPED FROM DATA FROM THESE AREAS
1 TOWN OF WUUSION PARCEL BOUNOART MAP (SHIPPED 121597) PROVIDED ST (VS (BURUNCTON VT) IN DXF FORMAT
2 PLAN DEVELOPED BT HEINDEL AND NOTES (BURUNCTON VT) FOR THE BATES PROPER1Y 1NVESIBAT10N AND PROVIDED TO THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION HASTE MANAGEMENT DIVISION 1997
3 ORTHOPHOTO SHEET 100216 VERMONT STATE MAPPING PROJECT 1988
4 TORN OF WIUJSTON ASSESSORS MAP 1997
5 VARIOUS SITE PUVQ CN RLE WITH THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION WASTE HMUGElENr OOVBON
6 DM FROM JOHNSON DD REPORT UNTIED GROUNDWXIER IHVESI1CAH0M ALLWC INDUSTRIAL PARK DATED 7 W FDR THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Modeled Site - Existing Conditions copy H
pound n Williston Vermont o CHECKED MS HSI
DRAFTED RMK GEOTRANS FU fa-Site-mod-ECdwg 4 - 1 A TITIA T t n HBVAIT
DATE 10600
5 COMPARATIVE EVALUATION OF ALTERNATIVES
The purpose of this section is to compare the remedial alternatives on the basis ofthe
evaluation criteria developed and discussed in Section 4 and provide a recommended alternative
These criteria include overall protection of human health and the environment short-term
effectiveness reduction of toxicity mobility or volume long-term effectiveness and
permanence compliance with ARARs implementability and cost
The comparative analysis is conducted to highlight significant differences between
identified alternatives All alternatives for the Study Area groundwater except the no-action
alternative include the following
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater and
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
The no-action alternative is not included in the comparison provided in the following
sections since it would not meet the RAOs All four ofthe remaining alternatives would meet
the RAOs stated in Section 32
51 SHORT-TERM EFFECTIVENESS
Protection of Workers and the Community Groundwater would be monitored under all
scenarios to look for any changes in VOC concentration which might result in increased risk
The containment options in Alternatives 2 3 and 5 would be more protective ofthe community
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320MAUINOFSWWI0030929WPD 5 - 1 HSI GSOTrSflS IflC
MITEC 104e 02415
if the region of VOC-contaminated groundwater were shown to be expanding and presenting
increased risk However in the event that the region of VOC-contaminated groundwater is not
expanding Alternative 4 would be equally protective Under all options a HASP would be
prepared and in conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Alternatives 2 3 and 5 would involve normal construction hazards during
installation of pumping wells piping trenches treatment enclosures permeable reactive barrier
trenches or planting of trees In addition under Alternative 5 release of VOCs to air through
transpiration may need to be measured to prevent creation of a new exposure pathway and health
risk through air
Environmental Impacts Minor additional impacts may occur during installation of
Alternatives 2 3 and 5 due to dust and sediment production Groundwater would need to be
treated to regulatory discharge limits before discharge under Alternative 2 and treatment may be
temporarily hampered in the event of treatment system mechanical failure Because ofthe
experimental nature of phytoremediation greater uncertainty exists that the trees will be effective
in acting as a barrier to expansion ofthe region of contaminated groundwater to the unnamed
brook under Alternative 5 If it is shown that expansion ofthe region of contaminated
groundwater toward the unnamed brook poses a future health risk additional measures may
become necessary to contain the contaminated groundwater
Time to Achieve Remedial Action Objectives None ofthe alternatives has an appreciably
shorter time frame than the others in reducing groundwater concentrations to VT Groundwater
Enforcement Standards and VT Water Quality Criteria This is because while Alternatives 2 3
and 5 rely on engineered remedies to contain the region of contaminated groundwater residual
TCE DNAPL and geologic heterogenieties will cause the contaminant source to persist for an
extended time As discussed in Section 34 active DNAPL removal alternatives were removed
during the preliminary screening DNAPL has never been directly observed at the Study Area
and is assumed to be present based on dissolved concentrations of TCE DNAPL distribution is
FOR ALLING INDUSTRIAL PARK MWP_DOCSW753200OALLINOFS9-00M0O30929wPD 5-2 HSI GGOTr3nS IflC
MITEC 104e 02416
expected to occur heterogeneously at residual saturation and it is infeasible to locate the DNAPL
to treat it directly Because of this each ofthe remedies is expected to exceed the two-year time
frame for short term effectiveness
52 R E D U C T I O N O F T O X I C I T Y M O B I L I T Y O R V O L U M E T H R O U G H
T R E A T M E N T
Treatment All ofthe proposed alternatives would treat the residual DNAPL source of
contamination through dissolution and natural gradient flushing While Alternatives 2 3 and 5
are intended primarily for containment and not groundwater restoration these alternatives would
actively treat some concentrations in groundwater
Reduction in Toxicity Mobility or Volume The containment Alternatives 2 3 and 5
may result in decreased mobility ofthe region of contaminated groundwater However
groundwater monitoring may show that the region of contaminated groundwater is not
expanding under existing conditions If this were the case containment would not result in any
additional decrease in size ofthe region of VOC-contaminated groundwater
Since Alternatives 2 3 and 5 treat concentrations in groundwater without treating the
residual DNAPL source and the amount of contaminants that can be removed from groundwater
by these methods would likely equal the amount added by continued dissolution ofthe DNAPL
sources alternatives 2 3 and 5 would not result in a greater reduction in the total volume of
contaminant than Alternative 4
Amount of Material Contained or Treated As described above the amount of material
contained under Alternatives 2 3 and 5 would not be any greater than under Alternative 4 unless
the size ofthe region of VOC-contaminated groundwater is not presently contained by natural
attenuation If natural attenuation is currently controlling the size ofthe region of VOC-
contaminated groundwater then the amount of contaminants being removed by natural processes
equals the amount added by dissolution of residual DNAPL In this case intercepting and
removing contaminants from the groundwater using one ofthe containment alternatives will not
result in a significant increase in the amount of contaminant treated
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000ALUNOFS9-OOUM30929WPD 5-3 HSI GGOTrdHS jflC
MITEC 104e 02417
53 LONG-TERM EFFECTIVENESS
Residual Risk Implementing institutional controls to maintain the sump venting at Lot 3shy
30 on South Browneil Road to restrict construction of buildings with basements below the water
table within the region of VOC-contaminated groundwater and to control the use of groundwater
for potable purposes within the region of VOC-contaminated groundwater would provide
protection against the potential for exposure to existing concentrations in groundwater
Therefore despite the fact that some ofthe remedial alternatives may be required to operate for
an extended time the residual risk associated with any ofthe alternatives would be minimal
Adequacy and Reliability of Controls Alternative 5 has the least reliable controls
because ofthe difficulty in predicting the effectiveness of phytoremediation The second least
reliable alternative would be Alternative 2 because of its reliance on mechanical equipment to
maintain containment and to meet discharge standards
Permanence of Remedy All ofthe proposed alternatives would rely on permanent
destruction of contaminants through natural attenuation over time If one ofthe containment
technologies are required maintenance and periodic replacement would be necessary to ensure
containment was maintained until expansion ofthe region of VOC-contaminated groundwater
was no longer a threat This maintenance would be straight-forward and easy to continue for any
of the containment alternatives
54 COMPLIANCE WITH ARARs
All ofthe alternatives would eventually reduce contaminant concentrations within the
current region of contaminated groundwater to below VT Groundwater Enforcement Standards
and VT Water Quality Criteria
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Each ofthe alternatives would rely on groundwater monitoring and institutional controls
on venting basement sumps at Lot 3-30 on South Browneil Road restrictions on the construction
of new basements below the water table within the region of VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWPJX3CSN7S3UOOOAUJNGFS9-OOUM30929wro 5-4 HSI GOTr3nS IflC
MITEC 104e 02418
and potable use of groundwater from within the region of VOC-contaminated groundwater to
maintain conditions protective of human health and the environment If monitoring shows that
natural attenuation is not restricting the size ofthe region of VOC-contaminated groundwater
then one ofthe containment alternatives would be more protective than Alternative 4
56 IMPLEMENTABILITY
The most easily implemented alternativewould be Alternative 4 as it would not require
any installation but only groundwater monitoring to gauge the progress of natural attenuation
Alternative 5 requires all the components of Alternative 4 and adds trees along the unnamed
brook Alternatives 2 and 3 are the most difficult to implement as they require disruptive and
invasive installation techniques However the necessary equipment materials workers and
specialists required to implement all the alternatives are available
57 COSTS
The present worth costs range form a low of $163083 for Alternative 4 to a high of
$2287474 for the containment option of Alternative 3 These present worth costs were based on
a 30-year service period and an annual discount rate of seven percent
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALLINOFS9-OOM0030929WPD 5-5 HSI GGOTfaDS IflC
MITEC 104e 02419
6 PREFERRED REMEDY
61 PREFERRED REMEDY
Alternatives 2 34 and 5 are all protective of human health and the environment and rely
on the following technologies
bull groundwater monitoring to evaluate spatial and temporal trends in VOC
concentration
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil
Road
restrictions on the construction of new buildings within the region of VOC-
contaminated groundwater to prevent unacceptable concentrations of volatile
compounds in indoor air and
institutional controls to restrict the use of groundwater for potable purposes within
the region of VOC-contaminated groundwater
All ofthe alternatives rely on dissolution and natural gradient flushing to treat the
residual DNAPL source of groundwater contamination Therefore none ofthe alternatives has
an appreciably shorter time frame than the others in reducing groundwater concentrations to VT
Groundwater Enforcement Standards and VT Water Quality Criteria
Alternative 4 includes remediation by natural attenuation There is no active containment
technology associated with Alternative 4 As such it is simpler less costly and easier to
implement than Alternatives 2 3 and 5 which include some form of active containment ofthe
region of VOC-contaminated groundwater Containment could become necessary under
Alternative 4 if future groundwater quality monitoring indicates the region of VOC-contaminated
groundwater is impacting a sensitive receptor or is expanding in size and not contained by natural
attenuation The SIR (HSI GeoTrans 2000) risk assessment (Menzie Cura 2000a and 2000b)
showed that under current conditions groundwater was not impacting any receptors to a degree
FOR ALLING INDUSTRIAL PARK MWPJXXrSN7532000ALUNcFS9-OOU0030929WO 6 - 1 HSI GSOTraflS jflC
MITEC 104e 02420
that would represent a human health risk or risk to the environment Therefore containment is
not necessary to protect any sensitive receptors currently being impacted by the region of
contaminated groundwater Continued groundwater monitoring is required to demonstrate
whether the region of VOC-contaminated groundwater is stable in size or expanding
Alternative 4 has been selected as the preferred remedy On-going monitoring ofthe
effectiveness of natural attenuation in containing and remediating the region of VOC-
contaminated groundwater is part ofthe remedy Further details on this proposed monitoring are
provided in Section 62 If monitoring shows that size ofthe VOC-contaminated region is not
contained by natural attenuation then one ofthe other technologies could be used to supplement
Alternative 4 based on the nature ofthe expansion ofthe region of contaminated groundwater
If monitoring data indicates that VOC concentrations in the groundwater discharging to the
unnamed brook have increased and pose an unacceptable risk to human health and the
environment then phytoremediation could be considered in this location Phytoremediation
would be less costly than installation of a permeable reactive barrier or active groundwater
extraction system Phytoremediation would be ineffective in containing expansion ofthe region
of contaminated groundwater in the rest ofthe Study Area however because contaminated
groundwater is further below ground surface in these regions and phytoremediation is limited by
the depth ofthe roots ofthe selected plant If monitoring data indicates that the southwestern
portion ofthe region of VOC-contaminated groundwater is expanding then Alternative 4 could
be supplemented with extraction wells or a PRB for hydraulic containment
62 MONITORING PROGRAM
In its guidance document Use of Monitored Natural Attenuation at Superfund RCRA
Corrective Action and Underground Storage Tank Sites (EPA 1999) EPA states that long-term
performance monitoring will be a fundamental component of any remedy which relies on
monitored natural attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000 A1XINOFS9-00 I0030929 WPO 6-2 HSI GSOTrSDS IMC
MITEC 104e 02421
The SIR (HSI GeoTrans 2000) concluded that there were not sufficient temporal data to
determine whether the region of VOC-contaminated groundwater was stable in size or
expanding Continued monitoring for the compounds of concern will be necessary to confirm
that the region of VOC-contaminated groundwater is not expanding Table 6-1 identifies
locations which are proposed to be monitored annually to evaluate spatial and temporal trends in
VOC concentration These locations are shown in Figure 6-1
There are several mechanisms by which natural attenuation occurs These include
dilution of contaminant concentrations sorption ofthe contaminant onto the soil matrix and
biodegradation ofthe contaminant to a less toxic form Further study is necessary to determine
the contribution of each of these mechanisms to overall attenuation ofthe area of VOC
contamination
Evidence of biodegradation can be obtained by collecting three types of data of increasing
complexity (National Research Council 1993)
bull documentation of contaminant loss or transformation in the field
bull the presence of electron donors and acceptors andor alteration of groundwater
chemistry consistent with intrinsic biodegradation processes and
microcosm studies which provide direct microbiological evidence that indigenous
bacteria are capable of mediating the contaminant transformations observed
Microcosm studies are typically not employed unless the contaminant is unique or the
transformation which is being observed is not well documented in the literature For the
transformations anticipated in the Study Area numerous laboratory and field studies have
established that naturally-occurring bacteria are capable of mediating the contaminant
transformations of contaminants of concern For that reason microcosm studies will not be
performed as part of this study
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^)OM0030929 WPO 6-3 HSI GSOTrSHS jflC
MITEC 104e 02422
Of particular concern to the determination of biodegradation is the delineation of aerobic
and anaerobic zones within the contaminant area because these zones dictate the types of
biological degradation that would be expected to occur Oxygen is the primary electron acceptor
during aerobic oxidation Anaerobic processes including denitrification iron-reduction sulfate-
reduction and methanogenesis occur in the absence of oxygen and use nitrate iron (III) sulfate
and carbon dioxide respectively as primary electron acceptors Reductive dehalogenation of
TCE has been observed under iron-reducing sulfate-reducing and methanogenic conditions
although very low redox (ie methanogenic) conditions may be necessary for production of
ethene and ethane
Further sampling and analysis of selected parameters in groundwater will be conducted to
assess the potential for biodegradation in accordance with EPAs Technical Protocol for
Evaluating Natural Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) The
twelve sampling locations shown in Table 6-1 used to monitor ofthe area of VOC contamination
will also be sampled for parameters used to evaluate biodegradation The parameters include
compounds of concern and compounds which are degradation products ofthe compounds of
concern shown in Table 6-2 Table 6-3 lists parameters chosen to evaluate the presence of
electron donors and a groundwater chemical environment conducive to biologic reductive
dechlorination These parameters will be sampled once unless evaluation ofthe data indicates
that further sampling would be beneficial to calculate a rate of attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000ALUNCFS9JraquoM0030929 WPD 6-4 HSI GSOTfaHS IDC
MITEC 104e 02423
Table 6-1 Sampling locations
LOCATION
ID
ASI-32D2
RB-1
ASI-26D2
ASI-I6D2
ASI-13D2
ASI-23D2
ASI-18D2
ASI-12D2
ASI-01D2
ASI-09D2
U-TRIB-5
SW-I
Notes BGS =
SCREENED
INTERVAL
DEPTH BGS
35-40
35-40
35-40
30-35
31-36
25-30
32-37
35-40
31-36
31-36
surface
surface
Below Ground Surface
RATIONALE
Upgradient of region of highest VOC concentrations
Closest to lot 19-11 former lagoon and septic leach field source areas
Within area of highest concentrations
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient ofthe region of VOC concentrations in the southwest direction
Downgradient of source area within region of VOC concentrations in southeast direction
Downgradient of source area within region of VOC concentrations in southeast direction
At downgradient edge of region of VOC concentrations in southeast direction
Stream upgradient of VOC discharge from groundwater
Stream at location of VOC discharge from groundwater
(
FOR ALLING INDUSTRIAL PARK MWP DOCSN7532000ALUNCFS9^X)VI0030929WPO 6-5 HSI GeoTrans inc
MITEC 104e 02424
Table 6-2 VOC analytes
PARAMETER
TCE
PCE
11-DCE
cis 12-DCE
trans 12-DCE
Vinyl Chloride
Benzene
Toluene
Ethylbenzene
Xylenes
ANALYTICAL METHOD
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
8260A
8260A
8260A
8260A
RATIONALE |
Contaminant of Concern
Contaminant of Concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
Notes SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical
Methods SW-846 US EPA 3ri edition 1986
TCE = Trichloroethene
PCE = Tetrachloroethene
11-DCE = 11-Dichloroethene
cis 12-DCE = cis 12-Dichloroethene
trans 12-DCE = trans 1 2-Dichloroethene
FOR ALLING INDUSTRIAL PARK MAWP DOCSN75320laquoMLUNOFS9^XM0030929WPO 6-6 HSI GeoTrans inc
MITEC 104e 02425
Table 6-3 Parameters to evaluate biodegradation
PARAMETER ANALYTICAL METHOD RATIONALE
Field Parameters
Alkalinity as CaCO Hach Alkalinity Test Kit Model ALP Positive correlation between microbial activity and
MG-L alkalinity Measures the buffering capability of
groundwater
Total Ferrous Iron Hach Method 8146 May indicate anerobic degradation
Dissolved Hydrogen Reducing Gas Detector Predicts possibility for reductive dechlorination
Dissolved Oxygen Direct Meter Reading Indicates probability of aerobic vs aerobic
degradation
PH Direct Meter Reading Aerobic and anaerobic biological processes are pH
sensitive
Redox potential (Eh) A2580B An indicator ofthe relative tendency of a solution
to accept or transfer electrons
Specific Conductivity Direct Meter Reading Used to determine when purging of a well for
sampling is complete
Temperature Direct Meter Reading Affects the metabolic activity of bacteria and the
solubility of dissolved gasses
Laboratory Analyses
Dissolved Organic Carbon SW 9060 Carbon and energy source which can drive
dechlorination
Nitrate-N IC Method E300 At higher concentrations may compete with
reductive pathway
Total Manganese EPA 2007 or 2009 To determine if anaerobic biological activity is
solubilizing Mn for the aquifer matrix
Chloride SW 9250 Can be used as a conservative tracer to estimate
biodegredation rates
Sulfate IC Method E300 May be used as an electron acceptor for
biodegradation after dissolved oxygen and nitrate
are depleted
Sulfide IC Method E300 Indicates if reductive pathway is possible
Ethane SW 3810 Modified Daughter product of Ethene
Ethene SW 3810 Modified Daughter product of Vinyl Chloride
Methane SW 3810 Modified Ultimate reductive daughter product
Notes Rationales taken from USEPA 1998
Hach refers to Hach Company Catalogue
A refers to Standard Methods for the Examination of Water and (fostewater 18 edition 1992
E refers to Methods for Chemical Analysis of Water and Wastes US EPA 1983
SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical Methods SW-846 US EPA 31 edition
1986
FOR ALLING INDUSTRIAL PARK | C I nr A^Twmrmr bullbullltlaquo MWP DOCSN7532000ALLINCFS9-0Ol0030929wro 6-7
MITEC 104e 02426
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REFERENCES
Brinkerd 1996 Site Investigation Ailing Industrial Park Williston Vermont April to
September 1996 October 1996
Fitts C R 1997 TWODAN documentation prepared by Dr Charles Fitts Scarborough Maine
Griffin 1995 Monitor Well Log (MW-4) and Analytical Data Bove-Fagan Ice Cream
Distribution Investigation Williston VT Griffin International Inc
HSI GeoTrans Inc 2000 Site Investigation Report June 15 2000
Johnson 1999 Limited Groundwater Investigation N753 July 6 1999
Menzie Cura 2000a Screening Level Risk Characterization April 2000
Menzie Cura 2000b Addendum to Screening Level Risk Characterization June 1 2000
NRC 1993 National Research Council Committee on Bioremediation In Situ Bioremediation
When Does it Work Washington DC National Academy Press 1993
TRC 1993 Site Inspection-Ailing Industrial Park Williston Vermont VTD982748477 Final
Report
US EPA 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies
Under CERCLA OSWER Directive 93553-01
U S EPA 1992 Estimating Potential for Occurrence of DNAPL at Superfund Sites OSWER
Number 93554-07FS 9p
FOR ALLING INDUSTRIAL PARK MWP_DOCSW75JV20(XKALUNOFS9-0(AI0030929WPD 7 - 1 HSI GeOTTSHS irtC
MITEC 104e 02428
US EPA 1993 Guidance for Evaluating the Technical Impractibility of Groundwater
Restoration EPA540-R-93-080
US EPA 1998 Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents
in Ground Water EPA600R-9812~8
US EPA 1999 Use of Monitored Natural Attenuation at Superfund RCRA Corrective Action
and Underground Storage Tank Sites EPA Directive 92004-17P
US EPA 2000 Introduction to Phytoremediation EPA600R-99107
VTDEC 1996 Site Investigation Guidance August 1996
VTDEC 1997 Chapter 12 Groundwater Protection Rule and Strategy October 1997
VTDEC 2000 Vermont Water Quality Standards March 2000
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(AAUJNGFS9^)OM0030929WPD 7-2 HSI GSOTfanS tC
MITEC I04e 02429
APPENDIX A
TWODAN INPUT FILES
FOR ALUNG INDUSTRIAL PARK MWP_DOCSVN7S3200(AALUNOFS9-0(AI0030929WPO HSi GfiOTfanS WC
MITEC 104e 02430
i - i i a a o U 0 t A X H i d t l Z 018J UaiUEAJJLKATia Htj v j pound
50-oo
4 e s y lt lt 4 A M ^ L S m m 9 m mdash t j y m
MITEC 104e 02431
15
6 Lancaster County Road HSI Harvard Massachusetts
GEOTRANS 01451 A TETRA TECH COMPANY 97^772-7557 FAX 978-772-6183
R E C E i ^ D PNN753-001
CUTLER A8TANPIELD Campltf December 11997
Mr Michael Smith Vermont Department of Environmental Conservation Waste Management Division 103 South Main Street Waterbury VT 05671-0404
Subject Proposed Surface Water Sampling MITEC Site Williston VT
Dear Michael
This letter describes the proposed surface water sampling at the MITEC site that we discussed during our meeting of November 201997 Our intention is to complete this work as soon as possible to avoid the complications of colder weather and possible freezing ofthe stream My understanding is that you are prepared to review and approve this plan fairly quickly and also to assist us with obtaining property access and appropriate maps to locate these sampling sites We appreciate this help In future we anticipate that the constraints of weather will not require such an expedited field mobilization process and that we will all have more time to prepare
Purpose and Extent of Sampling
The purpose ofthe surface water sampling is to further assess impacts to the unnamed tributary and to make preliminary inferences regarding the extent ofthe TCE plume currently migrating to the southeast across the Ailing Industrial Park by measuring the effects of its discharge to the stream To this end sampling locations have been chosen to 1) provide better spatial resolution in the area east of Commerce Street toward its southern end (SW-1 SW-2 SW-3 and S W-5) 2) assess the quality of surface water contributed by other tributaries (SW-4 SW-6) and 3) make preliminary estimates ofthe downgradient extent of impacts (SW-7 and SW-8) Samples from previously established sampling locations UTrib-6 7 8 1014 and 18 will also be obtained A total of 14 samples will be collected The proposed sampling locations
L-W7jni20iiooonl
MITEC 104e 02432
Michael Smith 2 December 11997
are indicated on the attached maps which depict the site at two different scales The first is a site map taken from the Binkerd report and shows the previous sampling locations east of Commerce Street as well as proposed new locations SW-1 SW-2 and SW-3 The second map shows the site and the surrounding area including the more downstream locations
Methods
At each proposed location a number of water quality indicators will be measured including temperature pH redox potential dissolved oxygen and conductivity Samples for volatile organic compound (VOC) analysis will be obtained in triplicate using a stainless steel sampling container samples will be transferred immediately to 40 mL glass vials with teflon septa and preserved with hydrochloric acid Each sample will be submitted to a local analytical laboratory for a screening level analysis of VOCs Three selected samples will also be analyzed using EPA Method 8260 The appropriate level of documentation will be generated for these samples such that laboratory analytical results can be validated to EPA Region 1 level Tier II This will require the collection and analysis of a duplicate sample a trip blank a field blank and matrix spikematrix spike duplicate samples
Sincerely
f i t mdash Peter ZeebPhD Senior Hydrogeologist
cc Sandy Feldman Sheila Jones
PZmm
m w MITEC 104e 02433
HSI GEOTRANS
LEGEND O Honrtorog Veil
A GeoProb Sortg
Figure 11 Station location map O Surface Water
Qfor monitoring wells borings and surface water MITEC 104e
02434
HD BINKERD ENVIRONMENTAL
HSI bull bull
GEOTRANS if prsTAOC
6 Cancaster County Road
A TETRA TECH COMPANY
Harvard Massachusetts 01451 faL32 HMETER 3 4 r t
Sheila Jones Esq Cutler and Stanfield 700 Fourteenth Street NW Washington DC 200052010
pound w a r
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Harvard Massachusetts 01451 GEOTRANS
A T E T R A T E C H C O M P A N Y 978-772-7557 FAX 978-772-6183
PN N753-002
May 111999 RECEIVED
MAY t 3 1999 Mr Michael Smith
CUTLER ampSTANrlc-uAgency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Dear Mike
Based on the site walkover and well inventory ofthe existing monitoring well network completed on April 201999 HSI GeoTrans determined that several monitoring wells proposed for sampling and monitoring in the Work Plan are not accessible or are damaged or missing Outlined below are the actions we will undertake to resolve the outstanding issues with the monitoring well network
As ofthe date of this letter access to the Bates well network has not been obtained The Work Plan identified eleven off property well clusters installed by the Bates and two wells installed by the State on the Bates property to be included in the sampling and monitoring activities for the Site Investigation (BW-2 BW-5 BW-7 BW-8 BW-9 BW-11 BW-12 BWshy13 BW-17 BW-18 BW-19) Ten ofthe off property clusters were included in the sampling plan and all eleven were included in the site water level round The wells installed by the State on the Bates property were included in the both sampling and water level rounds Replacement of eight ofthe well clusters slated for groundwater sampling is recommended (BW-5 BW-8 BW-9 BWshy12 BW-13 BW-17 BW-18 BW-19) The remaining Bates wells do not require replacement in order to achieve the goals ofthe Site Investigation Note that two ofthe original well clusters in the Work Plan BW-17 and BW-18 have been destroyed and would require replacement even if access is granted by Bates In addition HSI GeoTrans well clusters had already been proposed adjacent to BW-2 BW-7 and BW-11 and will provide the required data at these locations
It is our understanding that the two monitoring wells installed by the State on the Bates property JB-1 and JB-2 are accessible to the State for sampling and water level monitoring and that the State will sample and monitor these wells to fulfill the goals ofthe Site Investigation IF this is not the case please let me know at your earliest convenience
M WP DOCS NT^VWMiSimbW wpd
MITEC 104e 02438
Mr Michael Smith 2 May 11 1999
Several ofthe remaining wells (BF-1 BF-3 NO-2 and OE-1) were observed to be damaged during the inspection We propose to repair the wells which have been damaged The repairs will involve installation of protective casing or road boxes re-development and reshysurveying of the new measuring points The other wells are missing and presumed destroyed (ARC-2 ARC-3 BF-2 BM-2 MB-1 PO-SOUTH and RB-1) We believe that only monitoring wells MB-1 and MB-1 A require replacement The remaining wells that could not be located during the site inspection do not require replacement in order to achieve the goals ofthe Site Investigation
Based on our telephone conference on May 10 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MWgt_DOCSN753l9Wlaquo310l600raquopd M l 1 XA ~r
02439
HSI GEOTRANS
Mr Michael Smith 3 May 11 1999
bcc Sheila Jones
snwp_DocjN7sni9wcmoi6i)iraquoplti TVflTEC 1046
02440
HSI GEOTRANS
X_l ^ T 6 Lancaster Countv Road
Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-11 i 5
PN N753-002
June 25 1999
Mr Michael Smith Agency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Work Plan Modifications Ailing Industrial Park Site Williston VT
Dear Mike
This letter documents changes to the work plan for the Ailing Industrial Park Site in accordance with a telephone conference between you myself and Peter Zeeb On the results of the Site Investigation to date as well as additional data collection by the DEC we agreed that several revisions to the work plan are warranted The revisions for the work plan include the location and method of installation for the bedrock monitoring wells and the sampling of shallow monitoring wells recently installed Outlined below are the revisions to the specific tasks that we will undertake
Re-location of Bedrock Monitoring Weil BR-1
The DECs Source Area investigative work in the original location of BR-1 identified high levels (100 mgL) of VOCs present at or near the silt clay interface DEC believes that drilling through the clay layer in this location creates an unacceptable risk ofthe migration of contaminants into the underlying units HSI GeoTrans will relocate the bedrock well BR-1 adjacent to ASI-16 as located on the attached site plan
Bedrock Well Installation Method
Geophysical work at the site has refined our estimation of the depth to bedrock Depth to bedrock was initially anticipated to be greater than 150 feet below ground surface We currently anticipate bedrock at 100 to 140 feet below ground surface The shallower depth to Bedrock will
M AWPDOCStfnSIMnWUJIIW mft
MITEC 104e 02441
Mr Michael Smith 2 June 25 1999
enable us to reduce the size ofthe pilot hole needed for the well installation At locations BR-1 and BR-2 drillers will advance and set 4 in casing several feet into the clay unit and chop and wash the annulus ofthe casing All cuttings and wash water will be contained for proper disposal The casing will be refilled with potable water and the hole will be advanced with a 3 in roller bit When telescoping becomes necessary to prevent caving 3 in casing will be installed The 3 in casing will be advanced to the bedrock surface and seated The coring of bedrock will follow the original work plan specifications
Shallow Monitoring Well Sampling
The field GC water quality data obtained during small diameter installation at the site has demonstrated that contaminant concentrations in the upper portion ofthe aquifer to be low (lt 10 MgL) or non-detect in most locations This has led to the revision of our sampling plan Select shallow wells will be sampled to confirm the field GC data If these data are confirmed the low level and none detect shallow wells will not be sampled The shallow wells to be used for confirmation sampling are listed below
ASI-01 ASI-02 ASI-03 ASI-05 ASI-08 ASI-10 ASM 2 ASI-08
Based on our telephone conference on June 24 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MXTECl04e 02442
HSI GEOTRANS
Mr Michael Smith 3 June 25 1999
bcc Sheila Jones
MITEC I04e
02443
HSI GEOTRANS
1 0 T 2 shyCylty
T-TCT 6 Lancaster County Road _ _ _ Harvard Massachusetts
GEOTRANS OH 5 1
A TETRA TECH COMPANY 978-772-7557 FAX 978-772-6183
PN 753-010
July 9 1999
Mr Michael Smith Agency of Natural Resources Vermont Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Bedrock Monitoring Well Installation Ailing Industrial Park Site Williston VT
Dear Michael
On July 8 we became aware that a drill casing was advanced through the sand clay and till strata at the Ailing Industrial Park (site) without being sealed at the sandclay interface Although for the reasons described below we do not believe any vertical migration of contaminates occurred this method of drilling is contrary to the work plan for the site Therefore we are notifying you of this incident
On June 4 shallow direct push monitoring wells were installed at location ASI-06 where a deeper bedrock monitoring well is planned Groundwater quality profiling data from this location is provided on the attached boring log TCE is present in groundwater here at concentrations as high as 2270 ugl at 31 - 36 ft below ground surface (bgs) decreasing to 262 ugL at 41 - 44 ft bgs A soil boring (D-2) was advanced at this location on June 22 Field screening data from soil samples obtained in this boring are also provided on the attached log As apparent from the log fine to medium sand occurs to a depth of approximately 15 ft at this location grading to silt at depth A clay layer is encountered at 40 ft bgs Glacial till is present from 57 to 100 ft bgs where the bedrock surface is located Prior to drilling through the clay and glacial till a direct push well screen was advanced through the clay and into the till to a depth of 58 bgs and no groundwater recharge to the well screen occurred at any of five sampling depths
MWP_DOCSN753 199M7M1600 wpd
MITEC 104e 02444
Mr Michael Smith 2 July 9 1999
Drilling of bedrock monitoring well BR-2 began on June 29 Four inch casing was advanced to a depth of 44 ft and sealed within the clay layer Three inch casing was then advanced through the till layer to the bedrock surface During seating ofthe casing in the bedrock the casing was damaged and was subsequently withdrawn from the borehole
On July 7 a different drill rig was used to continue drilling the same location In accordance with both the drillers proposal to HSI GeoTrans and the work plan for the site investigation the driller was to seat a casing in the clay establish a seal and drill through the clay and till with smaller casing prior to coring bedrock Instead the drilling contractor withdrew the previously installed four inch casing without grouting it changed the drive shoe on the casing to a spin shoe and advanced the four inch casing directly to the bedrock surface Upon arrival at the site to log the coring of bedrock on July 8 HSI GeoTrans ascertained that the borehole had not been sealed at the clay surface prior to drilling deeper as was specified HSI GeoTrans then instructed the drilling contractor to immediately remove the casing and to seal the borehole with grout in the process
It is our intention to have a new drilling contractor complete the installation of BR-2 at an adjacent location in a manner that limits the potential for introducing contaminated unconsolidated deposits groundwater to the bedrock as specified in the work plan for this site investigation Within one week of completing the installation of BR-2 groundwater quality data collected from BR-2 will be evaluated with respect to the potential for contaminant migration along the unsealed borehole that existed at this location for approximately 24 hours As the casing was advanced by spinning providing a relatively good seal between the casing wall and the formation we do not anticipate that vertical migration along the casing was significant
If you have any questions regarding this letter please contact me at (978) 772-7557
Sincerely yours
Peter Zeeb PhD Senior Hydrogeologist
PZcas
MWP OOCSVN7S3M999070ll600wpri
MITEC 104e 02445
HSI GEOTRANS
1 HSI | 9pound9TPpoundSpound SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
LOCATION Williston VT CASING TYPEDIAMETER None
DRILUNG METHOD Drive and Wash Direct Push SCREEN TYPESLOT None
SAMPLING METHOD ss shelbv GRAVEL PACK TYPE None
GROUND ELEVATION GROUT TYPEQUANTITY Bentonite Portland Slurry
TOP OF CASING DEPTH TO WATER
LOGGED BY NSB GROUND WATER ELEVATION
REMARKS This log compiles the results o the all methods used to comolete the borehole over its entire depth
gtshyci IT UJ t o UJ E t shygt z L oi lti LITHOLOGIC DESCRIPTION 3Q O bdquo a UJ lt a ca sect 1a UJ
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A12 7
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Light olive Brown SILT w trace fine sand wet poorly - 1 5 shy graded
O2-SS02 4 7 11 8
A7
6 7
- 2 0 shy Dark greenish Grey SILT wet poorly graded
O2-SS03 2 0 41 1
WOR WOR l
D2-SS04 2 4 2 X - 2 5 shy4
D2 13 1159
3
1 D2-SS05 2 5 39 v
WOR AWOR WOR - 3 0 shyD2-SS06 4 921 WOR
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02-SS07 8 2270 1
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Continued Next Page 1 OF 3 02446
HSI GEOTRANS SOIL BORING LOG BR-02 A T E T R A T E C H C O M P A N Y
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
9 gtshyOC
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UJ gt o ^ r-6 LITHOLOGIC DESCRIPTION
ui
CD U UJ S oc =
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Medium Grey dayey SILT wet poorly graded
D2-SS09 4 S
28 1572
3 6
D2-SS10 WOR 1 18 13
4 6
D2-SS11 3 3 20 NO Medium Grey CLAY wet poorly graded 262
4 5
BR2-SS01 1 2 20 ND Soft Olive Grey CLAY moist laminated coheisive 2 4
BR2-SS02 20 NO
- 5 0 -
BR2-SS03 20 NO - 5 5 -
Dense Light olive Grey sandy GRAVEL w few fines
BR2-SS04 16 19 24
ND
bull60
moist poorly graded
21
Very dense Light olive Grey gravelly SAND w little fines moist well graded angular
BR2-SS05 40 51
13 ND 6 5 shy
60 66
I-7 0 shySO BR2-SS06 11 ND 50 100
5000
MITEC 104e 02447
Continued Next Page PAGE 2 OF 3
HSI GEOTRANS A T E T R A T E C H C O M P A N Y SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
a UJ
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BR2-SS07 81 1004
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BR2-SS08 30 59 68
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BR2-SS09 1005 NO 9 0 shy
BR2-SS10 89 1944
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Limestone
MITEC 104e 02448
PAGE 3 OF 3
Mr Michael Smith 3 July 9 1999
bcc Sheila Jones bcc Jerry Amman
MWPJXXSN753M9MW70J160Owpd
MITEC 104e 02449
6 Lancaster Countv Road HSI Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6 I i 5
PN N753-014
Septembers 1999
Mr Michael Smith Agency of Natural Resource Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in die Site Investigation Ailing Industrial Park Williston IT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and die Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation ore outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste waler lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot IV-11 using small-diameter wells and afield GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
bull perform one day ofwellpoint permeability testing at selected monitoring wells
mwFDocwsiMwwwnoootd MITEC 104e 02450
Mr Michael Smith September 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
M l T ECl04e 02451
U laquo OOCTN791Mtm01IOOOraquofrl
HSI GEOTRANS
HSI GEOTRANS
6 Lancaster County Road Harvard Massachusetts
01451
A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6183
PNN753-014
Septembers 1999 amp y gt
Mr Michael Smith D oJ Agency of Natural Resource Km Jt Department of Environmental Conservation i j f i l Waste Management Division ft y^y( 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park ft Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and the Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation are outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
bull perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste water lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot 19-11 using small-diameter wells and a field GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
MITEC 104e perform one day ofwellpoint permeability testing at selected monitoring wells 02452
000060 MlWP_OOCSN73Iirmraquo01|rngtlaquo|gtl
Mr Michael Smith Septembers 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
MITEC 104e 02453
000061 Mwr_cocS4miinmogtmoltsri
HSI GEOTRANS
T T Q T 6 Lancaster County Road ^ Harvard Massachusetts
GEOTRANS laquolaquo A TETRA TECH-COMPANY 978-772-7557 FAX 978-772-6183
PNN753-014
October 151999
Mr Michael Smith vZ Agency of Natural Resource J Department of Environmental Conservation Waste Management Division I 103 South Main StreetWest Building j Waterbury VT 05671-0404
Re Ailing Industrial Park Source Area Investigation
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants Evaluation of field data has determined the extent ofthe dissolved phase contamination migrating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) HSI GeoTrans will begin a Source Area Investigation on October 181999 to determine the nature and areal extent ofthe suspected contaminant source The investigation will be undertaken to gather the data necessary to complete the Site Investigation Report and the Feasibility Study which was set forth by the Agreement Between Mitec Telecom INC and Vermont Concerning the Ailing Industrial Park (1999) The Source Investigation will focus on the property owned by Beatrice Ailing and former MITEC lease hold (Lot 19-11 Williston plat map) and the area ofthe Ailing Industrial Park which has exhibited elevated contaminant concentrations during Site Investigation activities We are submitting this letter to The Vermont Department of Conservation(VTDEC) as an addendum to the approved Site Investigation Work Plan The addendum Source Investigation Work Plan will outline the tasks and methodologies to be utilized during the investigative work
Jack Guswa and I met with you on September 101999 to present the plans to investigate the suspected source area in the Ailing Industrial Park You agreed with the additional work as presented with the addition of two upgradient wells to be located to the west ofthe suspected source area (Figurel-1 ASI-30 and ASI-31) The VTDEC also agreed during the meeting to arrange access to the property for the Source Area Investigation The VTDEC and HSI GeoTrans were subsequently granted access to the property on September 111999 In addition to the work presented at the meeting it is necessary to preform a 72 hour pump test to characterize the
000054 MwrDOCSW79JimMOUIIOOpd
MITEC 104e 02454
Mr Michael Smith 2 October 151999
hydrologic conditions at the site The additional Source Area Investigation activities to be undertaken are presented below
Site Reconnaissance Ground Penetrating Radar (GPR) Survey Monitoring Well and Soil Boring Installation Low Flow Groundwater Sampling Hydraulic Characterization
The additional field work attributed to the Source Area Investigation will follow the standard operating procedures presented in the approved Site Investigation Work Plan (HSI GeoTrans 1999) The locations ofthe proposed well cluster installations and GPR survey are presented on Figure 1-1 The well cluster locations presented in Figure 1-1 were finalized during the September meeting between HSI GeoTrans and the VTDEC The GPR survey and hydraulic characterization tasks are presented below The Source Area Investigation field work will be completed within two week after its initiation The task specific outlines are presented below
Site Reconnaissance
The monitoring wells to be included in the site reconnaissance are monitoring wells MI-1 MI-2 MI-6 and RB-2 The monitoring wells on Lot 19-11 will be surveyed to a common datum with the existing site wide survey data Well integrity testing consisting of depth to bottom water level and visual inspection ofthe wells will be preformed Groundwater samples will be collected from selected monitoring wells based on the integrity testing Samples will be collected by the Low Flow Protocol set forth in the Site Investigation Work Plan (HSI GeoTrans 1999)
GPR Survey
A GPR survey will be preformed to identify on-site leach field septic tank or cesspool location remnants of waste water lagoon and any other subsurface anomalies We propose to use a 5 foot by 5 foot orthogonal grid survey to detect any near surface anomalies which exist on Lot 19-11 Geophysics GPR International will be performing the survey and will be utilizing a GSSI SR10 ground penetrating radar system with a high resolution 500 MHz antenna and a deep-penetration 100 MHZ antenna Any GPR response which indicate buried metal objects will be investigated with a Fisher TW6 pipe locator to augment the radar data All data will be analyzed in the field by GPR personnel and presented to HSI GeoTrans field personnel to determine the optimal location for well cluster ASI-28 If several anomalies are detected the VTDEC and HSI GeoTrans will evaluate the anomalies and modify the work plan accordingly
Well Installation and Soil Boring Advancement MITEC 104e 02455
The well clustes will consist of a small diameter shallow monitoring well and a deeper conventional well screened across the zone of highest concentration Well cluster installation will be performed in accordance with the Site Investigation Work Plan (HSI GeoTrans 1999) yjth 0 0 5 5
MWP_DOCSK731IW9M OOSIIOOprl
HSI GEOTRANS
Mr Michael Smith 3 October 151999
the exception ofthe deep wells The site conditions observed during previous field work prohibit the use of standard commercially available screen slot sizes The deep wells will be advanced by a large diameter Geoprobereg rod and installed using an outer filter sock to prohibit the infiltration offine sediments in to the well The well cluster installations will be performed jointly by Checkpoint Environmental and Twin State Environmental HSI GeoTrans will be provide oversite ofthe contractors and analysis of groundwater samples using afield Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999) The rationale for the selected well cluster locations is presented below
Monitoring well clusters ASI-25 through ASI-27 are located down gradient ofthe suspected source area The well clusters will be installed to more adequately define the areal extent ofthe concentrated portion ofthe contaminant plume A single soil boring will be advanced at location ASI-26 The soil boring will be screened as it is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-28 will be located after the GPR survey has been completed shyThe cluster will help define the suspected source area and the vertical migration of contaminants in the area The location will be determined in thefield after review ofthe GPR survey is completed The location will be based on any anomalies observed in the GPR data A single soil boring will be advanced at location ASI-28 The soil will be screened with a Flame Ionization Detector as the soil boring is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-29 will be located upgradient ofthe suspected source area The cluster will define the upgradient boundary andor any additional upgradient source areas The ASI-29 well will be paired with the existing shallow monitoring well AL-14
Monitoring well clusters ASI-30 and ASI-31 will be installed to the west cross gradient from the suspected source area to document the areal distribution of dissolved phase contamination emanatingfrom the Ailing Industrial Park The locations selected for these wells should define the northwestern and western extent of contamination
Low Flow Sampling
The additional monitoring well clusters will be sampled in accordance with the approved Site Investigation Work Plan (HSI GeoTrans 1999) Lowflow sampling procedures will be used to sample the newly installed deep wells in their respective clusters ASI-25 through ASI-31
MITEC 104e 02456
000056 MWP_DOCSgtK15JlWMOWllltraquoraquoprl
HSI GEOTRANS
Mr Michael Smith 4 October 151999
Hydraulic Characterization
HSI GeoTrans will conduct a 72 hour pumping test on the deep well at cluster ASM 2 The test is being undertaken to more adequately characterize hydraulic conditions at the site The data from this test will be used in the evaluation of remedial alternatives in the Feasibility Study The pump test will be performed as a step-drawdown test The pumping rates will ultimately be determined in the field from observed conditions Preliminary calculations indicate that pumping rates of 2 5 and 10 gallons per minute will be necessary to achieve the desired drawdown at observation wells The water level data will be recorded at observation wells ASI-06 ASI-13 ASI-25 ASI-26 NO-1 NO-2 and NO-3 The water level data will be recorded using pressure transducers and dataloggers
The effluent water from the pumping test will be treated by liquid phase granular activated carbon filters provided by Carbtrol Inc Two 175 pound carbon filters will be connected in series to treat the pump test effluent The effluent will be discharged to the unnamed brook upon approval from Randy Bean ofthe VTDEC The effluent will be periodically sampled between the carbon units and at the discharge point to detect break through ofthe carbon units The effluent samples will be analyzed utilizing a field Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999)) If the effluent sample between the carbon canisters exceeds 1000 ugL Trichloroethene (TCE) the discharge point sample will be analyzed If concentration of TCE in the discharge point sample exceed 300 ugl the test will be discontinued
We hope that this letter addendum to the Site Investigation Work Plan for the Source Investigation is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJmm MITEC I04e
02457
000057 MWFDOCSN731imu00SI 100 bullpd
HSI GEOTRANS
JHSTUART March 1 1985
Agency of Environmental Conservation D e partment of Water Resources und
E nvironmental Engineering H a z a r d o u s Materials Management Program A t t n John A m i d o n H y d r o g e o l o g i s t M o n t p e l i e r Vermont 05602
R e M I T E C Systems Corp W i l liston
Dear J o h n
During our meeting at MITEC on February 20th you noted that some additional information was needed to c omplete the initial phase of testing as well as the d o c umentation of the activities under takentodate Outline d~ beTow-Ts ~t h e~1 n f o r m a ti o n t h a t y o u r e q u e s t shyed
1 Attac hed here to is the plan used to install the grou ndwat er moni t o r s collection and analysis of the grou ndwa t er samp les for metals and organics and the extr actio n of and testing of soils from the area of the dispo sal site 2 A rev ised sit e pla n has been incl uded refl ecting the new well posi tions and the e leva t ions of t he top of t he mo ni to r s and th e groundwa ter 1e vels as of F e shybr ua ry 0th As note d in our m ost r ecent tel ephone conv i on th e lat ter have r isen 14-15 inc hes as er sa t the It o f th e rec ent thaw Two copie s of the resu plan be f orw ar ded to Winslo w Lad ue as req uested will and pla ns t 0 sur vey all ho uses on Br owne 11 Rd MITEC _tp tain if there are ajiy shallo w wel I sources ltis ce r with e dr aina ge ar ea a f fecte d by the 1agoo n in th 3 ngla nd Ma r ine C o m r a c t o r has been con tacted New E for remo va 1 of th e lagoon soil a nd co ntra c tural the ar ra nts wil 1 be concluded du r ing t he comi ng ngeme week if ic at io n of work comme nceme nt wi II be proshy Not vide your off ice i n advance d to t m Resul t s of th e met als and or genies are expected shor tiy
f rom IEA and will be fo rwarded to your ofshyf ice oon as a va i la ble as s 5 R esul t
s fr om t he pr e vious soi 1 and water sampling have inc 1 ude d bee n
CIVIL 4 EfViROUMEI-L pound l j i t fcHpound P ) OGA lt i f r l h r l h w i l l n-- i i U - iO l i l ) bU i l I
MITEC 104e 02458
s
MITEC Page 2 March 1 1985
If you have any questions please do not hesitate to contact me
Stuart PE
JHSocc
MITEC 104e 02459
MITEC Systems Corporation Williston Vermont
Soil and Water Sampling Program
1 Install groundwater monitors at nine (9) locashytions consisting of two (2) inch inside diameter PJpound with ten (10) feet of factory slotted pipe extending into the groundwater and terminating with a minimum of two (2) feet above ground level and capped
2 Establish elevations of the groundwater monitors for the top of each pipe and the groundwater elevashytion for each for a specific date Due to the shalshylow depth to groundwater from 51-112 inches the level is established by graduated tape and a light Each measurement will be performed a minimum of three times to assure accuracy to within one-eighth inch The location of each well and the established elevations will be represented on a general site plan showing the MITEC property
3 Groundwater samples are to be collected from each well on the same date by pump or baling Prior to - k ~ -~-|1bdquo--bdquobdquo f bdquo k bdquobdquobdquobdquobullbdquo ltv~ 11 1 1 v bdquo bdquo bdquo
acidification for metals preservation to assure ac curacy of the test results All samples are to be analyzed for copper cadmium nickel cyanide pH conductivity total chromium and hexavalent chrome
U Soil samples are to be collected as follows
GWM09 Saturated zone (aaprox 5) Overburden East side lagoon Composite from
two holes 5 apart-at-1 bullbull2 bullbull A below the-sur=mdash face and one in the saturated zone
North wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface 1 into the saturated zone
South wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface I1 into the saturated zone
Bottom of lagoon Composite offour test holes 8 apart one in the unsaturated zone
MITEC 104e 02460
MITEC Sampling Program
All samples are to be analyzed for the same constituents as required of the water testing
5 Collect separate samples of the groundwater after the above referenced purging process for storage in air-tight vials The samples which are to be colshylected from wells A-9 with only 5 and 7 analyzed initially by the GCMS- EPA method 62A If organics are detected in the first samples testing must be performed on 4 and 8 as well
6 All sampling will be performed with a State repshyresentative on-site and results of the testing to be forwarded to the State as soon as available
7 The contaminated soil within the lagoon will be removed by a Vermont certified contractor for disposhysal in an approved wastedepository The top one (1) foot of soil from the flood level and below will be extracted during the process
MITEC 104e 02461
i
o H
ON f J
o
bull I I bull
HA
OOO
x x z
bull
MITEC 104e 02463
WK miui w ci ivnui II i ici ILUI ujiyitb inc iii PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5108
ANALYSIS REPORT
Customer j H S c u a r t Associates Date 26 February 1985
Address P gt 0 gt B o x 3 6 7 Date Samples Received
Ci ty S t a t e Zip Essex Center VT 05A15 20 February^1985
Customer Order Nomber
Attent ion J o h n S t u a r t
Station 9
J
2
3
A
5
6
7
8
9
poundH
5A
58
52
5A
A5
53
53
55
59
j MITEC
Conductivity U mbos ( 25degC)
206
A18
21A
176__
208
230
205
16A
265
GROUNDWATER ANALYSIS
O01 0 OS bull
Cadmium Total Chromium (mRl) (mRl)
0A1 lt0025
006- 270
00A 012
bull005 189
005 023
001 lt0025
lt0C Hexavalent Chromium (mKI)
bull
lt0025
239
005
183
lt0025
lt0025
ampo
Zinc (mKl)
005
0A0
032
015
OU
003
Note Organic analyses to follow in two weeks
cc John Amadon
Signature jJfcrryyS 7lrifrylC
Offices ond loborotones located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02464
if jsznoi U hnvironmentol jiolysts Inc PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5138
ANALYSIS REPORT
Customer J H Stuart Associates Date 21 December 1984
Address PO Box 367 Date Samples Received 14 December 1984
City State Zip Essex Center VT 05451 Customer Order Number
Attention John Stuart
WATER ANALYSIS
PH 52 57 50 53 45 34
Conductivity (pmhos 25degC) 213 420 152 167 202 bull 225
O l Cadmium (mgl) lt001 lt001 001 v 028 bull 005 003
o pound Chromium Total (ng1) lt0025 lt0025 lt0025 lt0025 2-35 v 014 - -bullbull - bull - -bull V 013 bull^Chromium Hexavalent (mgl)1 0 11
gt1p Copper (mgl) lt002 lt002 lt002 lt002 bull 084 004
Q Cyanide (mgl) lt0005 lt0005 lt0005 lt0005 bull -lt0005 lt000E
Z Nickel (mgl) lt0025 lt0025 lt0025 lt0025 bull 010 003
fO 2inc (mgl) 0J1 UU1 0U3 001 038 030
Hexavalent chromium was only analyzed when total chromium was present
Signature fmnigt Mji fnt f VncL 7
Offices and laboratories located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02465
bull i
ANALYSIS REPORT
Customer J H Stuart Associates Date 22 January 1985
Address PO Box 367 Date Samples Received 14 December 1984
Ci ty State Zip Essex Center VT 05415 Customer Order Number
Attent ion John Stuart
bull shy
bull bull mdash bull bull bull bull bull - bull bull bull bull shy SOIL ANALYSIS1
Hexavalent Cyanide Chromium Chromium Cadmium Copper Nickel Zinc
poundH bull (mgl) (mgl) (mq1) bull (mq1) (mq1) (mgl) (bullmgl) -
2 442 lt0005 lt0025 lt0025 lt 001 lt 002 015 006
4 402 lt0005 lt0025 lt0025 lt 001 lt 002 lt002 001
7 504 lt0005 lt0025 lt0025 lt001 lt002 lt002 001
8 486 lt0005 lt0025 lt0025 lt001 lt002 lt002 bull 008
9 441 lt0005 lt0025 lt0025 lt001 lt602 lt002 004
10 444 0005 lt0025 lt0025 lt001 lt002 lt002 006
11 498 lt0005 lt0025 lt0025 lt001 003 lt002 009
30 532 lt0005 lt0025 008 lt001 005 lt002 010
31 544 lt0005 lt0025 lt0025 lt001 002 056 003
32 472 lt0005 lt0025 lt0025 lt001 lt002 024 003
36 536 0008 lt0025 011 lt001 005 lt002 011
37 490 lt0005 lt0025 lt0025 lt001 021 lt002 009
38 391 lt0005 0276 032 lt001 050 lt002 011
41 416 lt0005 0108 018 001 229 lt002 o5i
42 395 lt0005 0399 041 lt001 039 lt002 014
i
Signature Ltrf(7( ni W0 6M Analysis of EP toxicity extract
Offices ond loborotoriei locoted in Essex Junction Vermont Reseorch Triongle Pork North Corolino
MITEC 104e 02466
JHSTUART
A p r i l 2 9 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Hazardous Waste Materials Program Attn Cedric Sanborn Environmental Engineer Montpelier Vermont 05602
Re Mitec Systems Williston
Dear Cedric
I was phoned by David Gee today and informed that a truckload of the contaminated material was removed from the lagoon area as the result of a previous commitment entered into by Mitec Due to conflicting information about Mitecs responsibilities at this juncture I am recommending that any further work cease until a realistic program be agreed to by both parties I base that on the following
1 Following the trial pre-hearing the State was inshystructed to contact Mitec to develop a schedule for further dialogue and actions connected with the reshyhabilitation of the lagoon site To my knowledge there has not been any such attempt made on the part of the State to resolve issues that need clarificashytion
2 On April 18th I forwarded a letter to you outlinshying some new information with recommendations That correspondence has not been addressed yet Mitec has been ordered to continue with the soil removal
3 A letter from John Amadon on April 23rd notes the organic sampling to be invalid due to the time lapse and the method of storing the samples We do not take issue with this position however there is apshyparently some question about the validity of the GCMS method of analysis We have been instructed to re-sample but now there is a question about whether we should employ GC or GCMS
A On numerous occasions we have expressed the deshysire to tailor the soil removal process to a minimum
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 3C7 ESSEX CTR VERMONT 05451 TELEPHONE 802 876 bull 5171
MITEC 104e 02467
L
Mitec Page 2 April 29 1985
2- bull number of truckloads as they are projected to cost about $4000 for each load Mitec being in a startshyup phase of their operation cannot approach this operation with a blank check Chris Stone who was on hand today to represent the State indicated that many more loads may be necessary to effectively rid the site of contamination
Too many questions surround this project for my clishyent to understand his responsibilities and ultimate costs The requirements issued by your office either in writing or verbally on-site have changed repeatshyedly and unless we can mutually agree to a reasonshyable program that is connrifpH rnmdashyr r i ng Mitec has no other option but to let the court decide the isshysue
Again keep in mind there are questions that we feel must be resolved in order to reach a satisfactory conclusion
1 Provided that all Browneil Road houses are connected to the CWD system and thereby reshymoved from any threat of groundwater conshy
- p tamination what level of soil contamination is permissible From this limitation provishyded we concur as to its reasonableness an approximation can be developed as to how many loads of soil must be removed
2 If the soil is to be removed why is it neshyy cessary to conduct organics sampling unless
i t~ i s tne ulterior motive ot the State to direct renovation of the groundwater as well If that is the case the process will now be more expensive than at the outset due to the mobilization of the contaminants
3 If the contaminated soil is to be removed whv is additional groundwater monitoring
pound bull necessary Documentation of the degree of dilution is not considered acceptable
A If organic testing is to be performed y_hich -- method of analysis is to be used
As soon as we can receive a response to the quest-
MITEC 104e 02468
I um laquoi i laquo m mdash n r r j mdash i mdash
Mitec Page 3 April 29 1985
ions at hand then further discussion with the State will dnsue Also please be advised that at the dishyrection of Mitec all future correspondence communishycations requests for information or notification of site vists are to be forwarded to my office We also request that one person in your office be designated to process such information
tuart PE
JHSocc cc Mitec
Robert Cronin Esq
MITEC 104e 02469
jmfMraquoi w i f u m i
A u u raquo laquo F pound raquo laquobull= -
B C f U S t B C INC ENVIRONv i bullbullbull bullbull
5 GREEN MOUNTAIN DRIVE SOUTH BURLINGTON VERMONT 05401 TELEPHONE (802) 658-1074
February 17 1984
I I Mr Cedric Sanborn i
of Environmental Conservationi AgencAgencyy ox ampnvifoiuneniai Lonservdciun I i Dept of Water Resources and
Environmental Engineering Montpelier VT 05602
Dear Mr Sanborn j i
RE Mitec Clean-Up 84011 j
I am writing this letter to inform you of the work that has been completed thus far at Mitec Systems Corp The discharge of i rinsewater into the lagoon has stopped and the rinsewater is being batched and treated at Aquatec as I described in my letter to Stan Corneille dated February 3 1984
Although the chemical reduction and precipatation process works bull bull
very well we have found that the cost for design installation j septic design and installation and permit reviews is far above | Mitecs budget Aquatec has looked at a second alternative for bull the treatment and reduction of rinsewater that being ion exchange J The ion exchange system will be purchased from a vendor and will bull be installed by Aquatec to accomodate Mitecs rinsewater volumes i The rinsewater will be recirculated and will not require any discharge hence there will be no need for subsurface disposal [ permits I will send you specifications on the system and resins j that will be used I
The proposal for the out-door clean up work is enclosed Mr Kucer is currently discussing the cost estimate with his Montreal office I see no reason to intiate this work as soon as I get formal approval from your office and from Mitec
Please feel free to call me if you should have any questions
Sincerely
liytrl Zi [U$) John R Deigo Project Engineer
Enclosure cc Mr Steven Kucer
Hydrographic Studies and Analyses bull Water Quality Studies raquo Analytical Laboratories Ecological Studies bull Aquatic Nuisance Control - Industrial Waste Surveys
MITEC 104e 02472
Recommended Treatment of Rinsewater
Mitec System Corporation
Prepared By
Aquatec Inc
South Burlington Vermont
January 23 1984
MITEC 104e 02473
RE Mitec Groundwater Cleanup - 84011
The treatment of rinsewater will consist of a three stage rinse system with a batch chemical reduction treatment process Parts submersed in chromic acid solutions will be rinsed in a primary rinse bath The primary rinse bath will be a closed system and considered a rough rinse
The secondary rinse bath will also be a closed rinse system The third and final rinse will be a continuous overflow system Effluent from the tertiary system will flow directly into the septic system Tertiary effluent limits must be less than 005 mgl (ppm) before entering an underground septic system
The primary rinse bath will eventually become saturated with chromic acid solutions and require periodic batch treatment When the primary rinse water becomes spent it will be transferred into a 250 gal polyethylene plating tank The rinse water from the secondary rinse bath will be transferred into the primary rinse bath and the secondary bath will be refilled with fresh rinse water
When the tank reaches 80 of its capacity treatment will be initiated The treatment will consist of reducing hexavalent chromium to trivalent chromium by the addition of anhydrous sodium sulfite to a pH of lt2 The amount of sodium sulfite added will depend on the concentration and volume of rinsewater to be treated A portable electric mixer will be attached to the tank to ensure proper mixing The rinsewater in the reduced form will be gravity fed into a second 250 gallon polypropylene plating tank where lime will be added precipatlng out trivalent chromium as well as other heavy metals The mixer should be used to agitate the solution when the lime is added The mixer should be removed and the solids allowed to settle Once the solids have completely settled the treated water will be pumped into the tertiary effluent to allow for further dilution before it is discharged into a septic system
Periodic sampling of effluent waters should be incorporated to ensure that rinsewater discharged does not exceed 005 mgl (ppm)
Sludge will be properly stored and eventually disposed of by a certified hazardous waste carrier
MITEC 104e 02474
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Wildlife and Department of Forests Parks and Recreation Environmental Engineering Department of Water Resources amp Environmental Engineering Natural Resources Conservation Council State Geologist
January 4 1984
3 2ampov~ loo Mr J H Stuart
f i 2 Sm ^
P O Box 3 67 - - l ^ J ^ S M J Essec Center Vt 05451
SUBJECT Mitec Z 0~npJ^
1 o
Dear J o h n
I appreciate your sending me a copy of the recent Mitec water quality results It appears that there remains a detrimenshytal affect of the lagoon on the downgradient groundwater quality This is best demonstrated with the pH and chrome data While it appears that the downgradient well 5 has higher metalic concenshytration then well 6 in the middle of the lagoon I believe the Well 5 results are anamously high due to the turbidity or solids that we saw in the sample In talking with Cathy Cutting of IEA sample 5 was not filtered prior to acid digestion for the AAS analysis ^^
I would suggest that well s 4 5 and 6be resampled and analyzed along with the wells installed on CecT 17 amp 18 We would like to have a representative of our office on site when the sampling is performed so please contact me when a purging and sampling date is set in the near future The groundwater sample from test well 6 that you helped me obtain on December 17 with the teflon bailer was confirmed by our laboratory to contain volatile organics Therefore you must include the volatile orshyganics assay done by JGCMSjas a part of your analysis plan Adshyditionally I would suggest that you review the appropriate protocol for groundwater sampling and obtain the necessary equipshyment A sampling and analysis plan must be submitted for our apshyproval prior to commencing this second round of sampling The plan should be submitted by January 18 1985 with the sampling done within one month of our approval Please feel free to conshytact me with any comments or questions you may have
R f n r mdash i 1 Off ices - BarreEssex J c t P i t t s f o r d N Spr ing f ie ld S t Johnsbury
MITEC 104e 02844
J H Stuart Page 2
I do look forward to reviewing the results of the soils asshysays along with your report outlining the sampling protocol sampling locations data interpretations and projected course of action based on the results
Very truly yours
John F Amadon Hydrogeologist Hazardous Materials Management Program
JFAkp
cc Meredith Wright AG
MITEC 104e 02845
b v
HSTUART ASSOCIATES September 10 1984
Agency of Environmental Conservation Department of Water Resources and Environmental Engineering Air and Solid Waste Programs Attn Cedric Sanborn Air Pollution Control Engineer Montpelier Vermont 05602
Re M I T E C Corporation Williston Vermont
Dear Cedric
As Che result of our conversation on September 7th I am forwarding the information Chat we discussed
The CesCing program format was prepared prior Co our disshycussion and will be altered slightly based on some inforshymation that was collected
A boring was established in the cencer of Che disposal pic and Che wacer Cable as well as che Impeding layer were found to be located at 29 Inches below the surface The shallow depth will allow us co place addicional wells in che area co accuracely depicc Che groundwacer copography
The plan submiCCed herewith provides general information abouc che locaclon of che plane propercy lines and sugshygested positions for Che monitors The final location of che laccer will be decermined in che field once we collect more data on water table elevations
As we are most anxious to proceed with the program your expeditious review and responsewill be most appreciated
SCuart PE
JHSadt
cc David Gee MITEC
CIVIL ENVIRONMENTAL ENGINEERS 120 LAKE STREET BURLINGTON VERMONT 0S401 TELEPHONE 802-8640094
MITEC 104e 02846
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Game and Department of Forests Parks and Recreation
Department of Water Resources amp Environmental Engineering Environmental Engineering Natural Resources Conservation Council
September 19 1984
Mr John H Stuart PE JH Stuart Associates 120 Lake Street Burlington Vermont 05401
RE MITEC Project
Dear Mr Stuart
Chris Stone and I have reviewed the proposed soil sampling and groundwater monitoring plan for Mitec A summary of comments follows
1) The site plan did not show the location of the soil sampling sites Also we felt that additional boringmonitoring sites should be made closer to the facility The map has been re-marked to reflect these additional sites
2) It was not clear as to why the monitoring wells are to be installed 5 feet into the impeding layer However at least one boring should be made into the impeding layer to detershymine its thickness
3) Permeability tests should be performed on at least four of the test holes to determine aquifer characteristics
4) Since the water table is apparently close to the surface we feel that factory slotted pipe would be appropriate for the final monitoring wells
5) All soil1 ft 5 ft
samples 10 ft or
shouldto imp
be eding
takenlayer
at whic
depthshever
of comes
first
MITEC 104e 02847
Mr JH Stuart -2- September 19 1984
6) In addition to the soil sample in the center of the former lagoon four other locations within 2 feet of the edge of the lagoon must be sampled These locations are marked on the enclosed map
7) The State regulations do not address a level below which the metals are no longer hazardous as is done by EPA Toxicity Levels The level of contamination that is acceptable to the State is determined on a case by case basis
8) The analysis for chromium should include both hexavalent and total chromium
If you have any questions regarding our comments do not hesitate to contact us at 828-3395shy
Sincere
Sanborn C h r i s t o p h e r T Stone Environmental Engineer Hydrogeo log i s t Hazardous M a t e r i a l s Hazardous M a t e r i a l s Management Program Management Program
c r s - c t s a d e n c l o s u r e
MITEC 104e 02848
JHSTUART November 9 1984
Agency of Environmencal Conservation Deparcmenc of Wacer Resources and
Environmencal Engineering Hazardous MaCerials Management Program Attn Cedric Sanborn Environmental Engineer Mnotpelier Vermont 05602
Re M I T E C Corporation Williston Vermonc
Dear Cedric
There has been an apparent misunderstanding regarding your letter of September 19 1984 as soil and wacer sampling has been commenced ac che above location A call was placed Co your office on October 30th or 31sc and a message lefc for you indicating that we would begin on November 6ch at 8 AM
In the afternoon of November 6th I telephoned Chris Scone co inform him of our progress On che following morning you notishyfied MITEC that approval to begin had not been granced and chac work musC cease AC chac point we had completed che installashytion of five monitors and had extracted Cwo soil samples from the botcom of che wasce pic
On November 8ch I met with you and Chris to oucline che reshysulCs from our effores I was informed Chat we may have to inshystall one or Cwo additional monitors and Chac all future work muse be performed wich an Agency represenCacive in accendance
LaCe that afternoon Gerry Adams phoned Co notify me chat on short notice he was leaving to begin a large contract in rUasashychusetts and that it was unlikely that he would be back in the area for an extended period Had we been permitted to continue ttith our work on the 7th his portion of the project vould have been concluded
Enclosed you will find an updated version of the site plan orishyginally submitced wich my leCCer of Sepcember lOch A new plan will be developed buc Chis drawing will serve the purpose of locating existing and proposed wells
Whereas I am now withouc a drilling concracCor I would like chu
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05461 TELEPHONE 802 878 5171
MITEC 104e 02849
M I T E C Page 2 November 9 1984
authorization to determine groundwater elevations by auger and then establish one more monitor in a location agreed to by all che parcles I feel chac we have developed sufficient information co date to proceed in this manner
Furcher since Adams will noc be available I would also like Co extract che remaining soil samples wich a bucket auger IC can demonstrated chac che sample collected in chls manner will provide a good represencacion of che soil ac che level desired in Che profile
We are prepared co conclude chls phase of che sice evaluacion Samples from Che groundwacer monitors can be secured in a few days and I would like co follow wich che soil samples using che method described above
Please contact me at 878-5171 if you need additional informashytion
H Stuart PE
JHSadt
cc David Gee MITEC
MITEC 104e 02850
JHSTUART December 19 1984
M I T E C Corporation AtCn David Gee Manager IS Commerce Way Wllliscon Vermonc 05495
Dear David
Under Che Cerms of our agreemenc daced 10584 I wish Co proshyvide you wish an up-daCe of the project status
At the completion of 1219 we will have completed Items 1-4 as specified in the agreement specifically the soils sampling and initial set of water samples will have been collected and submitted for analysis As of chls momenC we still do not know the extent of the problem but will have a better indication once the test results are available in about a week My feelshying Is chac the problem is noc severe
We have compleCed all wells as prescribed however Che State is opting for an additional well Although the contract provides for only six the costs to date are below my target and it does not appear Chac any exCra will be necessary provided ChaC che driller concludes his work coday
The only work remaining afCer chls dace will be che collecCion of che second baCch of waCer samples and discussions wich Che State about any remedial action if necessary
Feel free to contacC me if you have any quescions
Regards
John H Stuart PE
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 878 bull 5171
MITEC 104e 02851
JHSTUART
M I T E C Corporation December 20 1984 ACCn David Gee Manager 15 Commerce Way Willaton VT 05495
Dear David
During our investigations yesterday Che work was completed on the additional monitor well as invoiced as well as drilling to the impeding layer The State decided however that two addishytional wells are required both of which will be Installed toshyday west of the Industrial park boundary line
A major change developed In Che method of testing the soils in the vicinity of the disposal pit that is not covered by our contract Instead of the four peripheral borings and one in Che center of che pic which would have produced flfceen soil samshyples che StaCe representatives decided Co require a different CesC paCCern Chac produced thirty seven samples I have collectshyed all of the samples but have Instructed the Cest lab to hold until authorization Is received Co proceed on Chls change as it Is a subsCanClal cost and will cause Che contract limit to be exceeded
Included is an invoice reflecting the additional wells the cost Co sample the groundwater for those monitors and the additional funds needed to run the soil tests I do not believe that any further surprises are in order
Regards
John H Stuart PE
JHSadt
CIVIL ft ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 06451 TELEPHONE 802 878 5171
MITEC 104e 02852
JHSTUART
December 28 1984
M I T E C Corporation Attn David Gee Manager 15 Commerce Way Williston VT 05495
Dear David
Enclosed are the results from the water quality analyses of the samples submitted to our lab I have noted in the left hand column the allowable limits for each element A copy of this information has been forwarded to John Ami-don per his request
There are several readings that are suspicious according to John The cadmium level in 4 may be an error and Che chromium found in 5 mosc likely Includes che CurbldlCy measured only in ChaC well Both should be resampled to confirm The cadmium and chromium levels in 06 exceed che allowable llmlCs but not excessively so The soil tesCs which have begun will reveal more about the ultimate disshyposition of these elemenCs
On the sewer Issue I spoke wich Frank Ailing again and his plans are Co now develop Che design and receive approval chis wincer for consCrucCion of the required Improvements this spring
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 5171
MITEC 104e 02853
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MITEC 104e 02855
JHSTUART January 28 1985
M I T E C Corporation Attn David Gee Manager 15 Commerce Drive WillistonVermont 05495
Dear David
On January 25th I met with John Amadon and Cedric Sanborn to discuss the contents of my 12385 letshyter The following resulted subject to confirmation by more senior members of the AEC staff
1 The water samples to be collected from wells 45 and 6 are to be checked for cadmium both chromiums and conductivity Wells 1 2 and 3 will be tested for conductivity and pH only
2 Samples will be collected from wells 4-9 for orshyganics but only wells 56 and 9 are to be checked at this time to determine the scope of contaminatshyion
3 The material to be removed from the pit is conshysidered as a hazardous waste and there are not any disposal sites located within Vermont certified to receive it I did obtain a listing of contractors that are approved for handling the material and I will provide this during our next meeting
4 Attached is a copy of the State lab results that address the organics problem
5 Based on the above we will have to amend our ashygreement to include the $1150 additional costs for the testing connected with Items 1 and 2
Call me if you have any questions
John H Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 raquo 878 bull 5171
MITEC 104e 02856
JHSTUART January 30 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Attn John Amadon Hydrogeologist Montpelier Vermont 05602
Re M I T E C
Dear John
I have had several discussions with MITEC relative to our meeting of last Friday In essence they have agreed to the program that you defined but with several provisos
They would like a letter from your office detailing the additional measures to be implemented together wich specific instructions as to what steps must be taken in the process of removing the contaminated soil
Further their acceptance to collect and sample for volatile organics is limited Perchloroethylene as I had indicated is not and has not been used by MITEC The materials stored on the premises as well as the list of suppliers for paints and solvents are available for inspection co corroborate that position MITEC will provide a complete analysis of all organics for the specified wells however fushyture testing for TCE will not be at the expense of MITEC unless its presence can be attributed to their operation
We are prepared to proceed as soon as we receive the requested notification
Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 bull 5171
MITEC 104e 02857
T gt v -^ -N m i l G C electronics ltd Tel (802) 864-0064 U U r l A bull =c -5 US Sales Office 15 Commerce St m^A^MMj Williston Vt 05495 Twx 510-299-0045
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serving the microwave telecom and defence industries in Canada usa and europe bull
August 14 1984
Air and Solid Waste Program State Office Building
Montpelier Vennont 05602 -
ATTENTION Cedrik Sanborn
Dear Sirs
Further to our telephone conversation of today enclosed find copy of proposal from JH Stuart Associates listing the proposed work to be carried out
If this meets with your approval we will go ahead with this work and we can then adVise Ms Meredeth Wright of the Attorney Generals Office th^t you aire satisfied with this proposal
gtur rep
Yours t r u l y
MITEC ELECTRONIC
G Mogi l CONTROLLER
cc g R ^ ^ C r o n i n J H S t u a r t
MITEC 104e 00346
c c c c c c c L L L ^ ^- v WORM n f c ] gt raquo M raquo raquoOT ^ r i raquo t OraKft L iu 0M5O
Page No 1 of - 1 Page PrnpnBal
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J H STUART ASSOCIATES 120 Lake Street
BURLINGTON VERMONT 05401 (802) 864-0094
PROPOSAL SUBMITTED TO PHONE DATE
MITEC Systems Corporation 864-0064 August 7 1984 STREET JOS NAME
15 Commerce Way So i l and groundwater analyses CITT STATE ANO ZIP CODE JOB LOCATION
Wi l l i s ton Vermont 05495 Ai l ing I n d u s t r i a l Park- W i l l i s t o n ARCHITECT DATE Of PLANS JOB PHONE NA NA
We hereby submit specifications and estimates for
Develop a site plan for location of a small waste disposal site to the rear of the manufacturing facility Said- plan to show where groundwater monitors are to be placed together with themethod of construction Further locations will be identified where soil samples are to be extracted for analyses All of the above information will be presented to the Vermont Agency of Environmental Conshyservation for review arid approval of requisitecorrective actionsThe specific functions to be provided are shy
1 Site plan development 2 Establish groundwater monitors in four (4) locations 3 Collect three (3) soil samples for analyses 4 Collect four(4) watersamples on two occasions with the second
batch occurring 90 days later shy5 Coordinate planning discussions and negotiations with the
Agency to remedy potential violations of State statutes and regulations
The above Includes all labor and equipment (backhoe) time needed to accomplish the tasks indicated by the State Not Included are groundwater sampling beyond the second batch of tests additional soil tests beyond the Initial batch and removal of any soil materials that may be found to be contaminated beyond acshyceptable Federal or State standards
MITEC 104e 00348
S f |JrnpDBP hereby to furnish materJaJ-jfl^Oabor mdash complete in accordance with above specifications for the sum MCTf T O c Q B t C T 7 7 0
dollars (J Payment lo be made as follows
Above work to commence by 81684 completed Alt m a t e r i a l Is guaran teed t o pound M a t tpac l fcad Ai l work t o ba e o m p M f d In a w o r k m a n l i k e m i r u M r a c c o r d l n | t o t t a n d a r d p r a c t i c a l Any laquo n laquo f a t laquo A or dev ia t i on r o m abova tpec i f i ca - Authorized ^ f e ^ M ^ t i o n t I n v o M n g ex t ra c o t t s wiU blaquo alaquocu tad on l y u p o n w r i t t en o rde r a n d w in b e c o m e a n Signature shy
e r t r a c h m raquo over a n d above t h a es t ima te Al l agreement i con t i ngen t u p o n t t r t f ca t acc iden ts o r de lays b e y o n d o u r c o n t r o l O w n t r l o ca r r y raquora t o rnado a n d o tha r necessary i nsu rance TJyi proposal may be lo Our worke rs ara fu l l y covered by Worlwnens Compensa t i on Insu rance withdrawn by not accepted wi th in
K t t t p t a n i P flf ^ m p H S a l - T h e above prices specifications Signature and conditions are satisfactory and are hereby accepted You are authorised
CORRECTIVE ACTION FEASIBILITY INVESTIGATION EPA SITE NUMBER VTD-0983 53545 (LOT 19-11)
January 29 2001
GeoX MITEC 104e Fc l I lS Inc A TETRA TECH COMPANY J L J 02269
6 Lancaster County Road Harvard MA 01451 978-772-7557 FAX 978-772-61 83
CORRECTIVE ACTION FEASIBILITY INVESTIGATION EPA SITE NUMBER VTD-098353545 (LOT 19-11)
J - J C T October 5 2000
GEOTRANS A TETRA TECH COMPANY
6 Lancaster County Road Suite Four Harvard Massachusetts 01451 MITEC 104e
02352
CORRECTIVE ACTION FEASIBILITY INVESTIGATION
EPA SITE NUMBER VTD-098353545 (LOT 19-11)
PREPARED FOR
ALLING INDUSTRIAL PARK
PREPARED BY
HSI GEOTRANS INC
6 LANCASTER COUNTY ROAD
HARVARD MASSACHUSETTS 01451
HSI GEOTRANS PROJECT NO N753-016 OCTOBER 52000
HSI GeoTrans inc
MITEC 104e 02353
TABLE OF CONTENTS
PAGE
1 INTRODUCTION 1-1
2 STUDY AREA CONCEPTUAL MODEL 2-1 21 STUDY AREA LOCATION AND DESCRIPTION 2-1
22 STUDY AREA LAND USE 2-1
23 HYDROGEOLOGIC SETTING 2-1
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION 2-3
3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES 3-1 31 IDENTIFICATION OF ARAR S 3-1
32 REMEDIAL ACTION OBJECTIVES 3-1
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES 3-1
322 GROUNDWATER 3-1
323 SURFACE WATER 3-2
324 INDOOR AIR 3-3
33 INITIAL SCREENING 3-3
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES 3-4
4 DETAILED ANALYSIS OF ALTERNATIVES 4-1 41 ALTERNATIVE 1 NO ACTION 4-1
411 SHORT-TERM EFFECTIVENESS 4-1
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-2
413 LONG-TERM EFFECTIVENESS 4-2
414 COMPLIANCE WITH ARARS 4-3
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 4-4
416 IMPLEMENTABILITY 4-4
417 COSTS 4-5
42 ALTERNATIVE 2 MONITORING INSTITUTIONAL CONTROLS AND
HYDRAULIC CONTAINMENT 4-5 421 SHORT-TERM EFFECTIVENESS 4-8
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-9
423 LONG-TERM EFFECTIVENESS 4-9
424 COMPLIANCE WITH ARAR S 4-10
425 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-11
426 IMPLEMENTABILITY 4-11
427 COSTS 4-12
FOR ALLING INDUSTRIAL PARK MWP_DOCSW5J20OTALlIWFS9-00U0030929wro 11 HSI GSOTrflnS IflC
MITEC 104e 02354
TABLE OF CONTENTS (CONTINUED)
PAGE
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS
AND PERMEABLE REACTIVE BARRIER 4-13
431 SHORT-TERM EFFECTIVENESS 4-15
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-16
433 LONG-TERM EFFECTIVENESS 4-17
434 COMPLIANCE WITH ARARs 4-18 435 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-18
436 IMPLEMENTABILITY 4-19
437 COSTS 4-20
44 ALTERNATIVE 4 MONITORING INSTITUTIONAL CONTROLS
AND NATURAL ATTENUATION 4-20
441 SHORT-TERM EFFECTIVENESS 4-21
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-21
443 LONG-TERM EFFECTIVENESS 4-22
444 COMPLIANCE WITH ARARS 4-23
445 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-23
446 IMPLEMENTABILITY 4-23
447 COSTS 4-24
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION 4-25
451 SHORT-TERM EFFECTIVENESS 4-26
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-27
453 LONG-TERM EFFECTIVENESS 4-27
454 COMPLIANCE WITH ARARS 4-28
455 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-29
456 IMPLEMENTABILITY 4-29
457 COSTS 4-30
FOR ALLING INDUSTRIAL PARK MWPJXgtCSN7532000AUJNOFSlaquo)0I0030929WPD 111 HSI GeOTrSDS ItlC
MITEC 104e 02355
TABLE OF CONTENTS (CONTINUED)
PAGE
5 COMPARATIVE EVALUATION OF ALTERNATIVES 5-1 51 SHORT-TERM EFFECTIVENESS 5-1
52 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT 5 - 3 53 LONG-TERM EFFECTIVENESS 5-4
54 COMPLIANCE WITH ARARS 5-4
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 5-4
56 IMPLEMENTABILITY 5-5
57 COSTS 5-5
6 PREFERRED REMEDY 6-1 61 PREFERRED REMEDY 6-1
62 MONITORING PROGRAM 6-2
REFERENCES 7-1
APPENDIX A TWODAN INPUT FILES
FOR ALLING INDUSTRIAL PARK MWgt_DOCSW7532000WJJNGfS9^)0M00J(raquo9wpo I V H S I G S O T r a H S I n C
MITEC 104e 02356
LIST OF TABLES
PAGE
TABLE 3-1 REMEDIAL ACTION OBJECTIVES 3-7
TABLE 3-2 DESCRIPTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES 3-8
TABLE 3-3 SELECTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES
FOR DETAILED ANALYSIS 3-11
TABLE 41 COST ESTIMATES FOR REMEDIAL ALTERNATIVES 4-31
TABLE 6-1 SAMPLING LOCATIONS 6-5
TABLE 6-2 VOC ANALYTES 6-6
TABLE 6-3 PARAMETERS TO EVALUATE BIODEGRADATION 6-7
FOR ALLING INDUSTRIAL PARK MWP DOCSN7S32000AUJNOFS9-00I0030929 wro HSI GeoTrans inc
MITEC 104e 02357
LIST OF FIGURES
PAGE
FIGURE 1-1 STUDY AREA LOCATION MAP 1-2
FIGURE 1 -2 LATERAL BOUNDARIES OF REGION OF TCE-CONTAMINATED GROUNDWATER 1 -3
FIGURE 4-1 MODELED SITE-EXISTING CONDITIONS 4-33
FIGURE 4-2 MODELED SITE WITH THREE RECOVERY WELLS PUMPING AT 5 GPM 4-34
FIGURE 4-3 MODELED SITE WITH TEN RECOVERY WELLS PUMPING AT 5 GPM 4-35
FIGURE 4-4 ALTERNATIVE 3 PERMEABLE REACTIVE BARRIER 4-36
FIGURE 6-1 PROPOSED MONITORING LOCATIONS 6-8
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUUNOFS9-OOV 10030929 w r o VI HSI GeoTrans inc
MITEC 104e 02358
1 INTRODUCTION
This Corrective Action Feasibility Investigation is submitted on behalf of Mitec Telecom
Inc (Mitec) by HSI GeoTrans The investigation was done to evaluate potential remedial
alternatives for groundwater contaminated by trichloroethylene (TCE) and to a lesser extent
tetrachloroethylene (PCE) and petroleum related compounds (BTEX) at the Ailing Industrial
Park (the Study Area) A recently prepared Site Investigation Report (SIR) (HSI GeoTrans
2000) identified the nature and extent of contaminated groundwater within the Study Area
Figure 1-1 is a map ofthe Study Area and Figure 1-2 is a map that outlines the region of
contaminated groundwater for which potential remedial alternatives were evaluated
The SIR concluded that the TCE contamination was widespread across the Study Area
that residual TCE dense non-aqueous phase liquid (DNAPL) resulting from one or more releases
was a continuing source of contamination to groundwater and that under current conditions the
groundwater contamination does not pose an unacceptable risk to human health and the
environment Current conditions include the continued effective mitigation of indoor air vapors
at the residence at Lot 3-30 no other residences with basements below the water table and no
use of groundwater within the Study Area as a potable supply The SIR also concluded that if
groundwater were to be used as a potable supply a significant health risk would exist as a result
of exposure to groundwater through ingestion dermal contact and inhalation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^X)M0030929WPD 1 - 1 HSI GCOTrdnS ITC
MITEC 104e 02359
I - N -
Former Mitec Hold y
Meters
Explanation
Study Area TITLE
MITEC 104e 02360
Study Area Location Map
LOCATION
Williston Vermont CHECKED MS FIGURE HSI OfVFTED RMK
GEOTRANS RLE f s ~ Expa nd~S(tsdirq 1-1 A T I T M TICK C011irraquoraquoT DATE- 10600 ~
2 STUDY AREA CONCEPTUAL MODEL
The following discussion ofthe Study Area conceptual model is summarized from
information contained in the previously submitted SIR (HSI GeoTrans 2000)
21 STUDY AREA LOCATION AND DESCRIPTION
The Study Area is located at the Ailing Industrial Park and adjacent areas in Chittienden
County Williston VT The VT state plane coordinates for the Study Area are Northing
71210837 (44 27 T north latitude) and Easting 147576375 (73 7 50 west longitude) The
Study area is within the Winooski River watershed and has an elevation ranging from 330 to 350
feet above mean sea level (MSL) The ground surface has little relief and slopes gently to the
southwest A small unnamed brook flows in a southerly direction along the eastern edge of an
industrial park located within the Study Area There is unlimited public pedestrian access to the
Study Area
22 S T U D Y A R E A L A N D U S E
The land in the Study Area is currently zoned for mixed residential commercial and
industrial use The eastern portion ofthe Study area is primarily zoned for commercial use and
the western portion ofthe Study Area is predominantly residential The Study Area includes an
industrial park where there has been light industrial and commercial use since 1946 Three lots
in the industrial park have been previously identified as locations of former manufacturing andor
fabrication operations that resulted in release of contaminants to groundwater (Brinkerd 1996
TRC 1993 Griffin 1995)
23 HYDROGEOLOGIC SETTING
The unconsolidated geologic deposits beneath the Study Area consist of sand silt and
clay which were deposited in the former Champlain Sea overlying till The unconsolidated
deposits occur in four distinct layers The surficial deposits are medium to fine sand which
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000VALUNoFS9^X)10030929wro 2 - 1 H S I G e O T r a f l S J n C
MITEC 104e 02362
generally becomes finer-grained with depth and extend to approximately 20 feet below ground
surface (bgs) Interbedded silts and fine sands are present from approximately 20 to 40 feet bgs
An areally-extensive clay layer underlies the interbedded silt and fine sands at a depth of
approximately 32 to 60 feet bgs Beneath the clay layer is a dense till which extends from about
60 to 100 feet bgs The underlying bedrock is comprised of massive gray limestone gray
dolomite and white marble ofthe Beckman formation This bedrock is of lower Ordovician age
and is part ofthe Hinesburg Synclinorium structure
The aquifer in the Study Area and surrounding regions is primarily the surficial medium
and fine sands although some water is capable of being extracted from the lower silt and fine
sand The residences and businesses within the Study Area are currently serviced by a public
water supply and the aquifer is not used for potable water supply within the Study Area The
hydraulic conductivity ofthe medium to fine sands was determined from a slug test to be about
20 feetday (Johnson 1999) The hydraulic conductivity ofthe interbedded silt and fine sand as
determined from rising and falling head slug tests (HSI GeoTrans 2000) ranged from 1 to 20
ftday with a geometric mean of 38 ftday A pumping test of well NO-1 yielded a hydraulic
conductivity estimate of about 2 to 30 ftday for the combined medium to fine sands and
underlying silt and fine sand There are no hydraulic conductivity data for the underlying clay
and till layers It is believed that the clay and till act as a lower confining layers restricting the
vertical flow of water between the overlying sand and the underlying bedrock
Beneath the Study Area the depth to water generally ranges from 3 to 11 feet below
ground surface In general groundwater flow beneath the Study Area is from the north to the
southeast and southwest There is a groundwater divide in the water table that runs generally
parallel to Commerce Street East ofthe divide groundwater flows toward and discharges to the
unnamed brook West ofthe divide groundwater flows toward Muddy Brook which is located
about 300 meters or 1000 feet west ofthe Study Area Groundwater recharge within the Study
FOR ALLING INDUSTRIAL PARK MAWPJgtOCSN753UOOOWXINOFS9-O0l0030929wro 2-2 HSI GCOTrdnS IDC
MITEC 104e 02363
Area is primarily from infiltration of precipitation Prior to 1986 when a sewer line was
installed groundwater recharge also resulted from discharge to numerous on-site disposal
systems
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION
Figure 1-2 illustrates the 1999 distribution of TCE-contaminated groundwater within the
Study Area The lateral boundaries ofthe region of TCE-contaminated groundwater
approximately represent the lateral boundaries ofthe region of volatile organic compound
(VOC)-contaminated groundwater As discussed in the SIR (HSI GeoTrans 2000) VOCs
present in groundwater include TCE PCE and BTEX The compound detected at the highest
concentrations and over the largest portion ofthe Study Area is TCE PCE is generally detected
in the same area as TCE but at significantly lower concentrations BTEX compounds have been
detected in groundwater primarily in the eastern portion ofthe Study Area and are commingled
with but not coincident with TCE-contaminated groundwater The lateral boundaries shown in
Figure 1-2 approximately represent the lateral extent of groundwater contamination and are not
intended to indicate that all groundwater within those boundaries is contaminated This figure
includes data collected on behalf of Mitec as part ofthe SIR (HSI GeoTrans 2000) and data
collected in 1999 by the Johnson Company (Johnson 1999) Figure 4-2 A ofthe SIR (HSI
GeoTrans 2000) shows all TCE concentration data collected in 1999 as well as some data
collected in 1997 The SIR (HSI GeoTrans 2000) summarized previous investigations that
indicated that at least three properties have contributed to the region of VOC-contaminated
groundwater On Lot 19-11 there were a disposal lagoon and a leach field that resulted in the
release ofthe VOCs TCE and PCE (perhaps as an impurity in the TCE) Lot 19-12 once had
underground storage tanks from which a previous release of BTEX was discovered when the
tanks were removed Lot 19-2 contained a disposal pit and outfall pipe from which TCE was
reportedly released
Figure 1-2 of this report shows in plan view the areal distribution of TCE-contaminated
groundwater Where there were multiple 1999 data values for the same location preference was
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AL1JNOFS9-OOM0030929WPD 2-3 HSI GSOTraHS JHC
MITEC 104e 02364
given to samples collected by low-flow sampling done subsequent to well installation In
addition for those locations which had samples from different depths the sample with the
highest concentration was used Figure 1-2 illustrates that TCE-contaminated groundwater is
widespread beneath the Study Area and that the highest TCE concentrations are detected in
groundwater beneath the eastern portion ofthe Study Area The figure illustrates that TCE-
contaminated groundwater in the eastern portion ofthe Study Area discharges to the unnamed
brook No VOCs including TCE have been detected in groundwater samples collected from
wells on the eastern side of the unnamed brook Based on surface water and groundwater data
that have been collected the unnamed brook appears to limit the southeasterly extent ofthe
region of VOC-contaminated groundwater In the western portion ofthe Study Area the lateral
boundaries of contaminated groundwater were identified through vertical profile sampling at
several locations Figure 1-2 shows the location ofthe vertical profiling borings that define the
lateral extent of TCE-contaminated groundwater The SIR (HSI GeoTrans 2000) recommended
periodic sampling and analysis of wells in the western portion ofthe Study Area for the purpose
of determining whether this region of VOC-contaminated groundwater was stable or expanding
in size
While not evident from Figure 1-2 it was determined that throughout the Study Area the
highest TCE concentrations were detected in samples collected from the interbedded siltclay
layer As shown on Figure 4-2A ofthe SIR the higher TCE concentrations were generally
detected at a depth of about 35 feet below ground surface in the eastern portion ofthe Study
Area and at a depth of about 30 feet below ground surface in the western portion ofthe Study
Area It is believed that the current distribution of TCE contamination resulted from DNAPL
releases at one or more locations within the Study Area One such release area was at Lot 19-11
DNAPL migrated downward through the upper medium to coarse sands under the primary
influence of gravitational forces There would have been some lateral displacement along
preferential pathways provided by sloping unconsolidated deposits but the primary flow would
have been downward Upon encountering the more resistive capillary pressure forces associated
with the water-saturated finer-grained geologic units such as the interbedded silts and sands
FOR ALLING INDUSTRIAL PARK MVWP_DOCSN7532000ALUNCFS9J3010030929wro 2 - 4 H S I G C O T r d n S I r t C
MITEC 104e 02365
which exist beneath the upper medium to coarse sands the DNAPL downward migration would
have stopped The DNAPL would have accumulated on top ofthe capillary pressure barrier layer
and then would have spread laterally following preferential flow paths within the coarser-grained
geologic units above the interbedded silts and sands The amount of lateral spreading of
DNAPL from any release area would have been dependent upon the volume and frequency ofthe
releases As the DNAPL migrated it would have created a region of residual DNAPL This
region of residual DNAPL consists of isolated DNAPL droplets trapped within pore spaces ofthe
unconsolidated deposits The lateral migration ofthe DNAPL would have been affected by the
slope ofthe surface ofthe finer-grained units that halted downward migration ofthe DNAPL
and it would not necessarily have been coincident with the direction of hydraulic gradient or
groundwater flow The region of residual DNAPL is now a continuing source of contamination
to the groundwater which flows past and gradually dissolves the DNAPL The locations ofthe
residual DNAPL zones are not known
There were no direct observations of DNAPL during drilling and well installation but it
is expected that residual DNAPL generally exists within regions of higher concentration detected
in the eastern portion of the Study Area The residual DNAPL is not necessarily continuously
connected within that region Based on the vertical distribution of TCE concentrations it is also
expected that the residual DNAPL exists in a relatively thin zone within the interbedded silt and
clay Limited hydrodynamic dispersion within the interbedded silt and clay has resulted in a
relatively thin zone of relatively high TCE concentrations in groundwater The southeastward
and southwestward divergence of groundwater flow has resulted in a laterally extensive region of
TCE-contaminated groundwater
There has been no indication in any ofthe investigations done within the Study Area
including the SIR (HSI GeoTrans 2000) that there are locations within the Study Area where
DNAPL is present in sufficient volume to be recoverable in the DNAPL phase
FOR ALLING INDUSTRIAL PARK m
MWP_DOCSN7532000VALLINCFS9^IOM0030929WIgto 2-5 HSI GCOTranS tC
MITEC 104e 02366
3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES
31 IDENTIFICATION OF ARARS
Two Applicable or Relevant and Appropriate Requirements (ARARs) were identified in
consultation with Mr Mike Smith ofthe Vermont Department of Environmental Conservation
(VTDEC) The first are the Groundwater Enforcement Standards as outlined in Appendix one of
the Chapter 12 Groundwater Protection Rule (VTDEC 1997) These standards apply to
concentrations of contaminants in groundwater in the Study Area (TCE PCE and BTEX) The
second are the Vermont Water Quality Criteria dated March 142000 (VTDEC 2000) which
specify surface water quality criteria and policy
32 REMEDIAL ACTION OBJECTIVES
The remedial action objectives (RAOs) for the Study Area are summarized in Table 3-1
and further described below
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES
One ofthe RAOs for the Study Area is the remediation of source areas Soil excavation
and removal has already occurred at the known release areas Not withstanding the fact that
previous DNAPL releases are suspected no areas of recoverable DNAPL have been detected in
the Study Area Concentrations of TCE in groundwater indicate it is present in some areas as
residual phase below the water table One purpose of this Corrective Action Feasibility
Investigation is to evaluate options for remediating residual DNAPL in the Study Area
322 GROUNDWATER
Attain VT Groundwater Enforcement Standards The ultimate goal of remediation is to
attain Groundwater Enforcement Standards for VOCs in groundwater This is in accordance
with the VT Groundwater Protection Rule and Strategy (VTDEC 1997) which states that If an
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MITEC 104e 02367
enforcement standard has been reached or exceeded at a compliance point the goal is to take
appropriate action to retum the groundwater quality to below the enforcement standard if
possible
Prevent Expansion ofthe Dissolved Plume A risk assessment (Menzie Cura 2000a and
2000b) was included as part ofthe SIR (HSI GeoTrans 2000) The risk assessment concluded
that under current conditions concentrations of VOCs dissolved in groundwater in the Study Area
do not pose a risk to human health andor the environment The SIR (HSI GeoTrans 2000) also
indicated that the available monitoring data were not sufficient to determine whether the region
of VOC-contaminated groundwater in the southwestern portion ofthe Study Area was stable in
size or expanding This Corrective Action Feasibility Investigation explores options for
monitoring groundwater quality and preventing the region of VOC-contaminated groundwater
from expanding in size
Prevent Potable Use of Groundwater Within the Dissolved Plume Menzie Cura prepared
a June 1 2000 addendum (Menzie Cura 2000b) to the April 2000 risk assessment (Menzie Cura
2000a) The addendum evaluated risk posed by potable use of groundwater at the site The
addendum found there to be a human health risk associated with the use of groundwater at the
site for potable purposes One RAO of this Corrective Action Feasibility Investigation is to
propose institutional controls so that groundwater within the region of contaminated
groundwater would not be used as a potable supply until concentrations are suitable for such use
323 SURFACE WATER
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
under current conditions VOCs dissolved in surface water in the Study Area do not pose arisk to
human health or the environment Currently however surface water concentrations in the
unnamed brook exceed VT Water Quality Criteria (VTDEC 2000) One ofthe RAOs for the
site will be to meet these surface water quality standards in the unnamed brook
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MITEC 104e 02368
324 INDOOR AIR
The VTDEC has conducted air sampling at several residences along Kirby Lane and
South Browneil Road The results have indicated the presence of TCE and PCE in indoor air at
some ofthe South Browneil Road residences (Brinkerd 1996) and unacceptable VOC
concentrations in the basement ofthe residence at Lot 3-30 on South Browneil Road The
presence of VOC vapors in the residence on Lot 3-30 is believed to have resulted from
volatilization of groundwater which infiltrated the basement through a continuously operating
sump pump The sump was vented to the exterior ofthe house as part of a state-sponsored
action and the indoor air concentration ofthe contaminants reduced to an acceptable
concentration Therefore one institutional control for the site will be to maintain the sump
venting as long as necessary to prevent health risks due to inhalation of VOC concentrations in
indoor air Also an institutional control in the form of a zoning restriction should be
implemented to prohibit the construction of new buildings with basements below the water table
in the region of contaminated groundwater The restriction should specify that in cases where it
is unavoidable to place the basement below the water table proper containment and venting of
the sump drainage system is required
33 INITIAL SCREENING
Four general categories of remedial technologies were evaluated The first monitoring
may be used alone or in conjunction with other remedies The second category includes
institutional controls to prevent exposure to contamination in groundwater and indoor air
Institutional controls could also be used alone or in conjunction with other remedies The third
category includes source removal technologies
The fourth category includes contaminated groundwater containment technologies such
as a hydraulic barrier or permeable reactive barrier Containment technologies can be applied in
two different ways Thefirst source control application would entail installing the containment
technology directly downgradient ofthe highest dissolved concentrations in an attempt to contain
the contaminated groundwater nearest the source Over time if new contamination is not
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MITEC 104e 02369
allowed to migrate beyond the source VOC concentrations in the downgradient region of
contaminated groundwater should attenuate
The second application would entail installing the containment technology at the
downgradient edge ofthe region of Contaminated groundwater The containment would protect
downgradient receptors from impacts by the region of contaminated groundwater
Both containment technology approaches were considered for use in the event additional
monitoring data shows that the region of VOC-contaminated groundwater is expanding in size
or if VOC concentrations in groundwater discharging to the unnamed brook are increasing
Table 3-2 identifies the remedial technologies considered and summarizes the results ofthe
initial screening for applicability to addressing the ARARs
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES
The list of potentially viable technologies shown in Table 3-2 was subjected to an initial
screening process The purpose ofthe initial screening was to identify those technologies that are
potentially feasible in the Study Area prior to performing a more detailed technology screening
Many ofthe source removal technologies were removed from further consideration because of
the impracticability of remediating residual DNAPL at the site
As described in the SIR (HSI GeoTrans 2000) DNAPL is likely present in the Study
Area Although present DNAPL has not been directly observed in any location and there has
been no indication that there is recoverable DNAPL present The failure to detect DNAPL
directly is not an uncommon situation at DNAPL sites and commonly results from its
heterogeneous distribution or its presence only at residual saturation (US EPA 1992)
Groundwater extraction and treatment is not an effective technology for remediation of residual
DNAPL due to limitations resulting from the limited solubility of most DNAPL compounds and
the heterogeneous distribution ofthe DNAPL (US EPA 1993) Designing remedial strategies
for DNAPL is made difficult by the inability to accurately locate the DNAPL sources This
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MITEC 104e 02370
inability to locate the DNAPL renders the use of targeted source remedies that might be cost
effective for a small readily definable source area ineffective These targeted source remedies
include excavation air sparging chemical oxidation in-situ thermal desorption and chemical
flushing technologies
Subsurface deposits in the Study Area are heterogeneous due to the interbedded nature of
the sands and silts overlying an areally extensive clay The presence of such heterogeneity
creates extremely variable and unpredictable groundwater flow velocities as well as flow paths
for DNAPL migration The contrast in permeability and porosity between different lithologies
results in the development of preferential flow pathways While preferential flow through coarse
sand and gravel zones provides higher than average groundwater flow rates and contaminant
flushing less preferential flow pathways such as silty sands silts and clays remain poorly
flushed even under forced hydraulic gradients created by extraction wells Contaminants
however may have migrated to these areas of less preferential flow as DNAPLs under
gravitational influence or by diffusion over long periods of time The low permeability zones
even if addressed by localized extraction of groundwater will transmit only small quantities of
water and hence contaminant flushing is slow This is compounded by the low solubility of
DNAPL constituents and the tendency for them to become trapped in soils by capillary pressure
forces
Specific source removal technologies which have been screened out as ineffective at this
stage include air sparging groundwater amendments excavation and in-situ thermal desorption
Low permeability zones prevent the migration of soil vapors or sparged air to the near-surface for
recovery due to the preferential flow caused by heterogenieties it is not possible to determine if
amendments which can be added to the groundwater or chemical flushing compounds which
displace the groundwater and help liberate residual DNAPL such as oxidants alcohol polymers
andor surfactant would reach the DNAPL Excavation which has already been used to remove
impacted surface soils in known release areas is not practical for removing residual DNAPL
deep below the water table The in-situ thermal desorption can be useful in some environments
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MITEC 104e 02371
but can also induce downward DNAPL migration if hydraulic control ofthe system is not
complete Because the location of residual DNAPL is not known and because hydraulic control
ofthe underlying silt clay and till into which the DNAPL may migrate cannot be assured in-situ
thermal desorption is not feasible for this site
Monitoring and institutional controls are included in each option evaluated except for the
no-action alternative These are required to rule out possible future health risks due to expansion
ofthe region of VOC-contaminated groundwater or the creation of new contaminant exposure
pathways
The technologies remaining after the initial screening are presented in Table 3-3
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MITEC 104e 02372
Table 3-1 Remedial action objectives
MEDIA REMEDIAL ACTION OBJECTIVE
Groundwater -Remove or control contaminant sources
bullAttain VT Groundwater Enforcement Standards
-Prevent expansion ofthe region of contaminated groundwater
-Prevent use of groundwater within the region of contaminated groundwater as a
potable water supply where contaminant concentrations exceed federal drinking
water standards
Surface Water -Attain VT Water Quality Criteria
Air -Prevent inhalation of concentrations in indoor air derived from groundwater
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MITEC 104e 02373
-n Table 3-2 Description of potentially viable remediation technologies o w o
i mi m rshym
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00
I W O mOH
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R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Basement Sump Venting
Restriction on new buildings with basements set below the water table
Restrict Potable Use of Groundwater
Excavation
Natural Gradient Flushing
Air Sparging
RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
PROCESS DESCRIPTION OPTIONS
No Action No Action
Monitor groundwater concentrations to confirm that region of VOC-contaminated groundwater is not expanding in size
Monitor surface water concentrations in unnamed brook to ensure concentrations remain below risk levels
Continue to vent the sumps at Lot 3-30 on South Browneil Road
Restrict construction of any new buildings with basements set below the water table within the area of dissolved VOC contamination and require basement sump venting in those where a below water table basement is unavoidable
Place restrictions on potable use of groundwater at properties overlying the region of VOCshy contaminated groundwater
Excavation and removal of soils containing residual DNAPL
Continued dissolution and natural attenuation of residual DNAPL
Injection of air beneath the water table to volatilize residual DNAPL and dissolved concentrations in groundwater
INITIAL SCREENING C O M M E N T
Used as a baseline for comparison No cost Long remediation time
Can be used in conjunction with other response actions Will be required in the southwest portion ofthe region of contaminated groundwater since existing data are inconclusive regarding this issue
Can be used in conjunction with other response actions
Will be required until data show there is no longer a risk to indoor air from groundwater in the basement
Will be required until data show there is no risk of migration of VOCs to indoor air from groundwater
Will be required at all properties in the area of VOC-contaminated groundwater to prevent a risk to human health
Has been used at the site to remove residual DNAPL in soils in the release areas Impractical to recover residual DNAPL at depth The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Intermediate cost Short time frame to cleanup if all residual source can be removed
Higher permeability zones are preferentially remediated On-going monitoring required No installation or on-going maintenance costs Long time frame to cleanup
Small-scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Intermediate installation and high on-going maintenance costs
MITEC 104e 02374
5 T l O Description of potentially viable remediation technologies (continued) PO
Table 3-2 O
RESPONSE REMEDIAL PROCESS g 5 ACTION TECHNOLOGY OPTIONS 5 m
r-m Source Chemical Ozone m Removal Oxidation Sparging q JO o n o
o
Potassium Permanganate Injection
Fentonss Reagent Injection
i co
Source In-Situ Steam Removal Thermal Stripping
Desorption
Electrical Resistance Heating
I Radio (pound Frequency
O m Heating OH 3) gt Z 0)
DESCRIPTION
Injection of air and encapsulated ozone beneath the water table to oxidize dissolved DNAPL constituents such as TCE
KMn04 is injected below the water table to oxidize dissolved DNAPL constituents
Fentons Reagent is injected below the water table to oxidize dissolved DNAPL constituents
Stream injected below the water table As the groundwater and soil are heated residual DNAPL is mobilized and collected by groundwater and soil vapor extraciion techniques
Low frequency alternating current is applied below the water table to cause resistive heating ofthe soil and groundwater As the groundwater and soil heat residual DNAPL is mobilized Groundwater and soil vapor extraction techniques are used to collect dissolved and vaporized DNAPL constituents
Electromagnetic radiation is applied below the water table As the groundwater and soil heat residual DNAPL is mobilized
INITIAL SCREENING COMMENT
Presence of DNAPL will potentially require large quantities of ozone The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Small scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Ozone is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of KMn04 The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of Fentons Reagent The exact location of the residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Fentons Reagent is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Small scale heterogenieties can result in channeling during steam injection and reduce the recovery efficiency Shallow depth of application may preclude effective steam control The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeneity has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeniety has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult so target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
_ mdash_ mdash _ _
MITEC I04e 02375
bulln Table 3-2 Description of potentially viable remediation technologies (continued) o
R E S P O N S E
A C T I O N
tn Source Removal
Source Containment Plume Management
co bull
o
lt)
o mOH 30 gt Z OJ
REMEDIAL
TECHNOLOGY
Chemical Flushing
Hydraulic Containment
Impermeable Barrier
Permeable Reactive Barrier
Phytoshyremediation
PROCESS
OPTIONS
bull
DESCRIPTION
Injection and recovery of alcohol polymers andor surfactant below the water table to enhance dissolution of residual DNAPL
Pump groundwater in downgradient portion of VOC-contaminated region groundwater to intercept contamination before it reaches a receptor or downgradient ofthe highest concentrations as source containment
Impermeable barrier is installed in the subsurface to contain groundwater and reduce the pumping rate needed for containment Can be installed upgradient of a receptor to prevent exposure or downgradient of the highest concentrations as source containment
Reactive material such as zero valent iron placed in flow path of contaminated groundwater Contaminants are treated as the natural gradient causes groundwater to flow through the barrier
Extracting of contaminated groundwater by evaporation from high water use trees Organic contaminants may also be biodegraded by the root system or may adsorb to living or dead root tissue and become immobilized
INITIAL SCREENING C O M M E N T
Higher permeability zones are preferentially remediated The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Groundwater extraction is required to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent fulfresidual DNAPL removal Very high installation and operation cost
Effective in containing dissolved concentrations Relatively low installation cost moderate on-going maintenance costs
Effective in containing dissolved concentrations Requires groundwater extraction and treatment Moderate installation cost moderate on-going maintenance costs
Moderate installation costs Lifetime of reactive material difficult to predict and reinstallation may become necessary No on-going maintenance costs prior to replacement
Still experimental Hard to confirm water usage rates and prove containment Trees may require ongoing monitoring and replacement Low installation and maintenance costs Only operates during the growing season
MITEC 104e 02376
1 T l Table 3-3 Selection of potentially viable remediation technologies for detailed analysis 1
rt g g g
5
i 8 5
3
CO
o m O H JO gtZW
o3 O tn
spound r m rshymO
M nn o
gt zbulllt
RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Indoor Air Monitoring
Basement Sump Venting
Potable Use of Groundwater
Restrict Basements Below Water Table
Excavation
Natural Gradient Flushing
Air Sparging
Chemical Oxidation
In-Situ Thermal Desorption
Chemical Flushing
PROCESS
OPTIONS
No Action
Ozone Sparging
Potassium Permanganate Injection
Fentonss Reagent Injection
Steam Stripping
Electrical Resistance Heating
Radio Frequency Heating
RETAINED
DISCARDED
Retained
Retained
Retained
Retained
Retained
Retained
Retained
Discarded
Retained
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
RATIONALE
Used as a baseline for comparison
Necessary to evaluate if the region of VOC-contaminated groundwater is expanding in size and if the VOC concentrations in groundwater discharging to the unnamed brook are increasing
Necessary to monitor that concentrations remain below health risk levels
May be required al new residences with basements below the water table built in Browneil Road area
The existing sump vents at Lot 3-30 on South Browneil Road will be required to mitigate indoor air risks
Restriction of potable use of groundwater at properties overlying the region of VOC-contaminated groundwater will be required to prevent dermal ingestion and inhalation exposure
Restriction of construction of new basements below the water table in the area of VOC-contamination will be required to prevent future inhalation risks
Residual DNAPL located too far below ground surface to make excavation feasible The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Excavation of known release areas has occurred
Longer time frame to clean up not a drawback at this site Lower cost is a benefit
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location of the residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL Steam control difficult
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
MITEC 104e 02377
2 Table 3-3 Selection of potentially viable of remediation technologies for detailed analysis (continued) a m RESPONS E R E M E D I A L PROCES S RETAINED RATIONALE
ACTION T E C H N O L O G Y OPTION S DISCARDED
Source Containment Hydraulic Containment Retained Proven effective at containing expansion ofthe region of contaminated groundwater Region of Contaminated
iisect
n n o
Groundwater Management
Impermeable Barrier Retained Proven effective at region of contaminated groundwater containment
Permeable Reactive Retained Proven effective at region of contaminated groundwater containment Barrier
Phyto-remediation Retained Experimental however there are no potential negative consequences in using the technology Low cost is a benefit
co i
IO
I (A O m OH 73 gtZ
MITEC 104e 02378
4 DETAILED ANALYSIS OF ALTERNATIVES
41 ALTERNATIVE 1 NO ACTION
The no-action alternative is included in accordance with EPAs Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA (EPA 1988) The no-action
alternative provides a baseline for comparison and involves taking no additional actions at the
Study Area This remedy assumes no continuing monitoring of dissolved concentrations in
groundwater surface water or concentrations in indoor air This remedy assumes no institutional
controls on basement sump venting at Lot 3-30 on South Browneil Road property no restrictions
on new buildings with basements set below the water table constructed within the area of VOC
concentrations in groundwater and no restrictions groundwater use for potable purposes within
the region of VOC-contaminated groundwater
411 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community The risk assessment completed for the SIR
(HSI GeoTrans 2000) concluded that current conditions at the Study Area do not pose a risk to
human health Current conditions include venting ofthe sump at Lot 3-30 on South Browneil
Road no buildings other than at Lot 3-30 with basements below the water table in VOC-
contaminated areas and no potable-use wells within the region of VOC-contaminated
groundwater Without institutional controls to ensure this there may be future risk The risk
evaluation indicated that concentrations in the unnamed brook resulting from contaminated
groundwater discharge while not above risk-based thresholds were close to levels that could
pose a risk to human health Therefore monitoring is advised to confirm that VOC
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
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MITEC 104e 02379
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of VOC-contaminated groundwater could result in health risks not
evaluated in the risk assessment
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative
Time to Achieve Remedial Action Objectives It is estimated that the time frame required
for natural attenuation of contaminants to meet the groundwater cleanup concentrations will
significantly exceed the two-year time frame used to evaluate short-term effectiveness
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment There is no treatment of contaminants under this option
Reduction in Toxicity Mobility or Volume Some reduction of residual DNAPL and
accompanying dissolved concentrations is expected through natural attenuation over time if no
action were pursued at the Study Area However no monitoring data would be available to
confirm the progress
Amount of Material Contained or Treated Natural attenuation may serve to contain the
entirety of the region of groundwater contaminated with dissolved VOCs
413 LONG-TERM EFFECTIVENESS
Residual Risk Therisk assessment completed for the SIR (HSI GeoTrans 2000)
concluded that current conditions at the Study Area do not pose a risk to human health
However the risk evaluation indicated that concentrations in the unnamed brook resulting from
contaminated groundwater discharge while not above risk-based thresholds were close to levels
that could pose a risk to human health Therefore monitoring is advised to confirm that VOC
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deg2380
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of contaminated groundwater could result in health risks not evaluated in
the risk assessment Without institutional controls to ensure basement sump venting at Lot 3-30
on South Browneil Road restrictions on new buildings with basements set below the water table
within the region of VOC-contaminated groundwater and prevention ofthe installation of wells
for potable supplies within the region of VOC concentrations in groundwater a residualrisk to
human health remains
Adequacy and Reliability of Controls This remedy does not assume the sump in the
basement ofthe residence at Lot 3-30 on South Browneil Road remains sealed and vented to the
outside and that the pump is maintained in operable condition to continue to keep groundwater
out ofthe basement Previous air sampling conducted by the VTDEC has confirmed that this is
necessary to control indoor air impacts to this residence This remedy relies on natural
attenuation to control the region of VOC-contaminated groundwater however there is no
continuing monitoring of dissolved VOC concentrations in groundwater Since monitoring to
date has not confirmed that the region of VOC-contaminated groundwater is not expanding in
size a remedy which has a natural attenuation component but does not include monitoring does
not provide adequate control
Permanence of Remedy In the very long-term natural gradient flushing should reduce
VOC concentrations in groundwater to acceptable levels
414 COMPLIANCE WITH ARARs
Groundwater Protection Rule and Strategy It is expected that natural attenuation would
over time reduce groundwater concentrations to below VT Groundwater Enforcement Standards
However a no-action response would not comply with VT Groundwater Protection Rule and
Strategy (VTDEC 1997) which allows for remediation of sites by natural attenuation if sufficient
monitoring is perfonned to document that expansion ofthe region of contaminated groundwater
is not occurring and that natural attenuation is occurring The no-action alternative would not
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AU1NGFS90010030929wro 4-3 HSI GSOTraFIS IflC
MITEC 104e 02381
allow for continued monitoring and would not meet this requirement
Surface Water Quality Standards It is expected that natural attenuation would over
time reduce surface water concentrations to below VT Water Quality Criteria for the protection
of human health and aquatic organisms (VTDEC 2000)
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
concentrations of VOCs adsorbed to soil and dissolved in groundwater in the Study Area do not
pose a risk to human health andor the environment under current uses There would be arisk if
groundwater within the region of VOC-contamination were used as a potable supply Therefore
if dissolved concentrations were not migrating beyond the limits ofthe region identified in the
SIR (HSI GeoTrans 2000) and groundwater were not used for potable purposes the no action
alternative would be protective of human health and the environment However there are not
sufficient data to determine whether the region of VOC-contaminated groundwater is stable or
decreasing in size If the region of contaminated groundwater were expanding beyond the limits
upon which the risk assessment was based there may be a future risk to human health and the
environment Also restrictions should be placed on properties overlying the region of VOC-
contaminated groundwater to prohibit construction of basements below the water table and the
use of groundwater as a potable supply and the venting ofthe sump at Lot 3-30 should continue
416 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
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MITEC 104e 02382
Technical Feasibility The no-action alternative is technically feasible
bull Ability to Construct the Alternative The no-action alternative requires no
construction
bull Reliability ofthe Technology No technology would be applied under the no-
action alternative
bull Ease of Undertaking Additional Remedial Actions The no-action alternative
would not prevent future remedial actions
Administrative Feasibility The no-action alternative is administratively feasible
Availability of Services and Materials No services or materials are required to carry out
the no-action alternative
417 COSTS
There are no costs associated with the no-action alternative The no-action alternative is
shown on Table 41 for purposes of comparison
4 2 A L T E R N A T I V E 2 M O N I T O R I N G INSTITUTIONAL C O N T R O L S AND
H Y D R A U L I C C O N T A I N M E N T
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull institutional controls would be implemented to restrict construction of any
buildings with basements within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull groundwater extraction and treatment would be done to contain the region of
VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753laquo000WJJNoFS9JXI10030929wro 4 - 5 HSI GSOTraDS JllC
MITEC 104e 02383
Groundwater pumping is an effective technology for hydraulic containment of
contaminated groundwater Hydraulic containment can be used if the region of VOC-
contaminated groundwater is impacting a sensitive receptor or is expanding is size The risk
assessment (Menzie Cura 2000a and 2000b) showed that groundwater was not impacting any
receptors to a degree that would represent a human health risk or risk to the environment There
is not sufficient temporal data however to confirm that the region of VOC-contaminated
groundwater is not expanding is size Therefore an analysis of hydraulic containment has been
included in this Corrective Action Feasibility Investigation in the event that future monitoring
shows the region of VOC-contaminated groundwater is expanding and that containment is
necessary
If monitoring indicates that natural attenuation is not causing the region of VOC-
contaminated groundwater to be stable in size or to shrink then an active containment remedy
may be required Under this scenario a groundwater pump-and-treat system would be installed
and operated in the Study Area to hydraulically contain contaminated groundwater and prevent
expansion ofthe region of VOC-contaminated groundwater Pumping wells would be installed
in the overburden silts and sands to the clay layer Wells would be installed in the downgradient
portions of contaminated groundwater to the southeast and southwest Extracted groundwater
would be treated before discharge to surface water The primary treatment operation will be air
stripping with a low-profile stripper for the removal of VOCs primarily TCE Depending on
treatment efficiencies secondary treatment with granular activated carbon may be required In
addition a particulate filter may be added to remove iron prior to treatment and reduce iron
fouling ofthe air stripper and carbon Extracted and treated groundwater would be discharged to
surface water via an outfall Compliance sampling can be conducted at the outfall or at a
sampling point within the treatment building The outfall should be constructed to minimize
hydraulic impacts on the receiving water body
The number and location of pumping wells that may be required to capture and contain
the region of TCE-contaminated groundwater has been investigated using the two-dimensional
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9JXA10030929WO 4-6 HSI GSOTfanS IdC
MITEC 104e 02384
analytical element simulation code TWODAN (Fitts 1997) TWODAN is a commercially
available copyrighted program The input parameters to the model are based on the values
reported in the SIR (HSI GeoTrans 2000) Input data sets for the analyses contained in this
report are included in Appendix A The bottom elevation ofthe model is 306 ft which is
representative ofthe top ofthe continuous clay layer beneath the site The model represents the
interbedded silts and fine sand layer and the overlying medium to fine sand surficial unit as one
layer The hydraulic conductivity ofthe modeled layer is 184 ftday The estimated areal
recharge for the model is 10 inyr The basement sump at Lot 3-30 on South Browneil Road
pumps groundwater year round The resulting depression ofthe water table is represented by a
constant head of 33128 ft which is approximately 8ft below ground surface at that location
Groundwater elevations used in the model were based on an average ofthe July 1999 and
December 1999 potentiometric surface in wells with screened intervals intersecting the water
table The model representation of current hydrologic conditions at the Study Area is shown in
Figure 4-1 Groundwater elevations are shown in meters on this figure
Two containment scenarios were evaluated The first was a source control application in
which the TWODAN model was used to determine the number of wells and pumping rates
required to contain the 10000 to 20000+ ugL TCE concentration zone as shown in Figure 1-2
In this scenario pumping would contain the contaminated groundwater nearest the source(s)
Over time if new contamination is not allowed to migrate from the source(s) the VOC
concentrations in the rest ofthe region of contaminated groundwater would attenuate The
second scenario was a containment application in which the TWODAN model was used to
determine the number of wells and pumping rate required to contain the 1000 to 10000 (igL
TCE concentration zone as displayed in Figure 1-2 In this scenario pumping occurs in the
downgradient portions ofthe contaminated groundwater
Each recovery well was assumed to be 4 inches in diameter fully screened and have a
pumping rate of 5 gpm The pumping rate was based on the aquifer testing results reported in the
SIR (HSI GeoTrans 2000) applied to a fully screened extraction well The results ofthe model
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000A1XINOFS9JX)10030929WPD 4-7 HSI GSOTraDS IflC
MITEC 104e 02385
analyses indicate that a minimum of three 4-inch diameter recovery wells pumping at 5 gpm are
required to contain the 10000 to 20000+ ugL TCE concentration zone The results of this
model simulation are shown on Figure 4-2 The model analyses also indicated that a minimum
often 4-inch diameter recovery wells pumping at 5 gpm are required to contain the 1000 to
10000 ugL TCE concentration zone Figure 4-3 shows the results of this model simulation
Figures 4-2 and 4-3 also show that groundwater extraction for hydraulic containment may induce
infiltration of surface water in response to pumping thereby reducing the amount of water
flowing in the brook
421 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 2 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with extraction well construction and treatment plant construction Access by
unauthorized personnel would be restricted by fencing temporary barriers andor warning signs
The groundwater treatment building would be locked and secured A health and safety plan
(HASP) would be prepared for the remedial activities In conformance with Occupational Safety
and Health Administration (OSHA) regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative Suitable dust control measures would be implemented during
construction ofthe groundwater treatment system Additionally the treatment process is
expected to be relatively simple with a low potential for exceedance of discharge limitations
Monitoring ofthe treatment process would be performed
Time to Achieve Remedial Action Objectives The time estimated for well installation
system debugging and establishing hydraulic gradient control is three to six months The RAOs
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^XM0030929wro 4-8 HSI GSOTraOS IIIC
MITEC 104e 02386
for groundwater would be achieved when monitoring results indicated that VOC concentrations
had attenuated and groundwater standards had been met It is estimated that attenuation of VOC
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of recovered groundwater would remove some ofthe VOCs from
the aquifer This treatment would generate residuals such as used filters and spent carbon This
process is irreversible
Reduction in Toxicity Mobility or Volume Treatment ofthe extracted groundwater
would reduce its toxicity prior to surface water discharge Contaminants adsorbed to any
secondary carbon would ultimately be destroyed during the process of regenerating the carbon
Contaminants adsorbed to any particulate filters would be landfilled or incinerated along with the
filters The toxicity and volume of contamination in groundwater are nominally reduced by
extraction and treatment but effectiveness is limited as discussed in Section 421 above
Modeling shows that groundwater extraction would be effective in reducing the mobility ofthe
dissolved phase contamination
Amount of Material Contained or Treated The volume of contaminated groundwater
that would be treated on a long-term basis is estimated at about 8 million gallons per year for the
source containment option and about 26 million gallons per year for containment of all dissolved
TCE concentrations greater than 1000 ugl
423 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
FOR ALLING INDUSTRIAL PARK MWPJXXTSN75320(XAAUJNOFS9-OCM0030929WKgt 4-9 HSI GSOTrSDS IDC
MITEC 104e 02387
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Groundwater pumping would control any risks caused by expansion ofthe
region of contaminated groundwater Residual risk to human health would be controlled through
institutional controls
Adequacy and Reliability of Controls Extracted groundwater would be treated on-site to
standards required for discharge to surface water The extraction well pumps and groundwater
treatment equipment would require maintenance on a long-term basis Groundwater monitoring
to ensure that the contamination was being adequately contained by the groundwater extraction
would be necessary on a long-term basis
Permanence of Remedy The groundwater treatment plant would be enclosed and
designed as a modular system and its equipment would be readily replaceable if required The
extraction wells may need to be rehabilitated andor replaced during the life ofthe remedy
424 COMPLIANCE WITH A R A R S
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to return the
remaining groundwater to below Groundwater Enforcement Standards Groundwater extraction
would also eventually return the areas of highest groundwater contamination to below
Groundwater Enforcement Standards
Surface Water Quality Standards Hydraulic control of the groundwater migration would
interrupt and remove contaminates from groundwater thereby preventing discharge to the
unnamed brook resulting in achievement of Water Quality Criteria for the protection of human
health and aquatic organisms (VTDEC 2000)
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200OALUNoFS9^Kgtl0030929wro 4-10 HSI GOOTrSDS IDC
laquoTEC I04e 02388
425 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The hydraulic containment alternative would offer protection to both human health and
the environment if expansion ofthe region of contaminated groundwater were identified Since
the risk assessment (Menzie Cura 2000a) found that under current conditions groundwater and
surface water concentrations are below levels which constitute a risk to human health and since
hydraulic containment would ensure the region of VOC-contaminated groundwater remained in
the current configuration hydraulic containment would be protective of human health and the
environment This alternative assumes institutional controls will be in place to continue sump
venting in the basement at Lot 3-30 on South Browneil Road restrict the installation of
basements below the water table within the region of VOC-contaminated groundwater and
prevent potable use of groundwater within the region of VOC-contaminated groundwater
Protection would be achieved at the end ofthe construction period of three to six months The
residual risks posed by contaminated material remaining within the groundwater would not be
significant because all potential exposure routes would be addressed
426 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction which would present no special problems
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AUB4CFS9^10l0030929wro 4 - 1 1 HSI GGOTrdDS IDC
MITEC 104e 02389
bull Reliability ofthe Technology Hydraulic gradient control is a frequently used
alternative that has proven effective in preventing further expansion of areas with
- contamination in groundwater Filtration air stripping and carbon absorption
have frequently been used and proven effective in treating groundwater in other
applications
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the
gradient control system was inadequate to restrict the expansion ofthe region of
contaminated groundwater implementation of additional resources would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
operate maintain and monitor the well head portions ofthe treatment system Institutional
controls would also be needed to implement institutional controls to continue sump venting in
the basement at Lot 3-30 on South Browneil Road The town must pass zoning restriction which
would prevent construction of basements below the water table and potable use of groundwater
within the region of contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor the groundwater treatment system associated with the hydraulic containment option
are available
427 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 2 The
capital costs would be $207000 for the source control application and $732000 for the
containment option OampM costs include groundwater monitoring and maintenance ofthe
groundwater extraction and treatment system These are $77000 per year for the source control
application and $139000 per year for the containment option The present worth analysis
(calculated at a 7 discount rate interest for 30 years) yields a total of $1085403 for the source
control application and $2287474 for the plume containment option
FOR ALLING INDUSTRIAL PARK MWPJXXSN753U0OOALUNGFS9-tfW0030929wro 4-12 HSI GSOTrailS IRC
MITEC 104e 02390
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS AND
PERMEABLE REACTIVE BARRIER
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull and a permeable reactive barrier would be installed and maintained at a
downgradient location to reduce concentrations of TCE dissolved in groundwater
as it flows under natural gradient flow conditions if groundwater monitoring
shows the region of VOC-contaminated groundwater is expanding in size
PRBs consist of a permeable region of chemically reactive materials constructed to
intercept the path of a dissolved groundwater contaminants Reactive materials may include
bull zero-valent iron for reductive dehalogenation
precipitation agents such as gypsum to create insoluble metal salts
bull sorptive agents such as granular activated carbon to capture and immobilize organics
bull reducing agents such as dithionite and hydrogen sulfide to reduce and insolubilize metals
and
bull biologic electron acceptors such as lactic acid or nitrate to enhance aerobic
biodegradation
FOR ALLING INDUSTRIAL PARK MAWPJX)CSVN7532000AmNOFS9-OOU0030929wpo 4-13 HSI GSOTrSDS IDC
MITEC 104e 02391
Zero-valent iron and granular activated carbon are both applicable for use in the treatment
of TCE in a PRB Granular zero-valent iron has been widely applied in PRB installations and
promotes reductive dehalogenation of TCE to chloride ion ethane and ethene Activated carbon
has been used in a limited number of field and lab studies to simply adsorb dissolved organic
constituents as they pass through thePRB
Because ofthe costs ofthe reactive or adsorptive material PRBs are generally
constructed as a funnel and gate system The funnel portion ofthe PRB is a typical vertical
barrier wall constructed of sheet piles bentonite or other impermeable material which is
designed to direct groundwater flow to the gate portion ofthe PRB containing the reactive or
adsorptive material Funnel and gate sections ofthe PRB are keyed together and generally to a
low permeablility zone located at depth
The use of permeable reactive barriers is not directly applicable to treatment of DNAPL
The mechanism for groundwater remediation using a PRB would include
bull dissolution ofthe DNAPL into groundwater by natural processes
bull downgradient transport ofthe dissolved contaminants to the PRB location
artificial channeling ofthe contaminated groundwater to the reactive material located in
the gate by the barrier funnel and
bull reductive dehalogenation or adsorption of a portion ofthe VOC as is passes through the
gate
A variety of methods are available for emplacement ofthe PRB The most conventional
method includes excavation of a trench and backfill will a soilbentonite slurry for the funnel
portion and granular iron or carbon in the gate section Other methods such as sheet-piling jet
grouting continuous trenching fracturing and others are available For the subject site because
ofthe presence of sand in the formation it is likely that a continuous trenching method would be
the most applicable and cost effective
FOR ALLING INDUSTRIAL PARK MWPJX)CSN7S320O0ALUNGFSraquo-O0U0030929wro 4-14 HSI GGOTfaDS IOC
MITEC 104e 02392
Operation maintenance and monitoring ofthe PRB is relatively simple Groundwater
samples would be periodically collected from locations upgradient and downgradient ofthe gate
section(s) ofthe PRB to monitor its effectiveness Media installed in the gate (iron or carbon)
would require periodic replacement probably on a annual basis for carbon and every 5 to 10
years for iron
The placement depth width and length ofthe PRB would depend on the region of
VOC-contaminated groundwater that was desired to be intercepted the depth to the underlying
low permeability layer and the desired TCE concentration reduction (which determines resident
time required in the gate) As wilh hydraulic containment two scenarios were investigated The
first a source control option would intercept VOC-contaminated groundwater with TCE
concentrations greater than 10000 ugL A PRB of approximately 1200 feet in length would be
required The second a region of contaminated groundwater containment option would
intercept VOC-contaminated groundwater with TCE concentrations in excess of 1000 ugL A
PRB of approximately 2200 feet in length would be required The depth ofthe PRB in both
cases would likely extend from ground surface to about 40 feet below ground surface The PRB
would be installed into the underlying areally-extensive clay layer Figure 4-4 shows the
placement ofthe PRB under each opinion
431 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 3 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with PRB construction since either conventional or continuous trenching methods
would be employed during its construction However exposure hazards during construction
would be considerable since the emplacement requires excavation and handling of a large
volume of potentially contaminated soils During construction access by unauthorized personnel
would be restricted by fencing temporary barriers andor warning signs Following
FOR ALLING INDUSTRIAL PARK
MWP_DOCSN753 2000 AUJNCFS9^10 10030929 WPD 4-15 HSI GSOTrSPS IDC
MITEC 104e 02393
construction little to no hazards should be expected from the long-term operation ofthe PRB A
HASP would be prepared for the construction activities In conformance with OSHA
regulations site workers would be trained required to wear appropriate protective equipment
and as applicable would be enrolled in a medical monitoring program Groundwater monitoring
wells would be sampled to determine changes in VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative with proper controls Suitable dust control vapor monitoring and
stormwater runoff measures would be implemented during construction ofthe PRB
Time to Achieve Remedial Action Objectives The time estimated for PRB emplacement
is four to six months The RAOs for groundwater would be achieved when monitoring results
indicated that the VOC concentrations have attenuated and groundwater standards have been
met It is estimated that attenuation of contaminant concentrations to ARARS will significantly
exceed the two-year time frame for short-term effectiveness This is because the application of a
PRB at the site would not significantly alter groundwater flow or TCE dissolution from within
the source area Therefore it would not increase the rate at which concentrations of residual
DNAPL or dissolved constituents of DNAPL (TCE) were removed from the source area It
would however limit the size ofthe region of VOC-contaminated groundwater
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of groundwater flowing through the permeable sections ofthe PRB
would remove the dissolved TCE as is flows under natural gradient conditions from the source
area
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNGFS9^X)10030929WPO 4-16 HSI G G O T T S O S jflC
MITEC 104e 02394
Reduction in Toxicity Mobility or Volume Treatment ofthe groundwater would reduce
its toxicity Contaminants adsorbed to carbon (if used as the treatment media in the gate sections
ofthe PRB) would be excavated on a periodic basis and ultimately be destroyed during the
process of regenerating the carbon
Amount of Material Contained or Treated The volumetric flux of contaminated
groundwater through the PRB is estimated to be approximately two million gallons per year for
the 10000 (igL source containment option and approximately four million gallons per year for
containment of all dissolved TCE concentrations greater than 1000 ugL
433 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Treatment of groundwater intersecting the PRB would control any risks
caused by expansion ofthe region of contaminated groundwater to the southeast Residual risk
to human health would be controlled through institutional controls
Adequacy and Reliability of Controls Performance of PRBs in reducing concentrations
of chlorinated organics such as TCE using zero-valent iron has been mixed Most ofthe PRB
performance demonstrations indicate that a concentration reduction of 60 to 90 percent can be
expected Some applications however have been much less successful at reducing VOC
concentrations Although little experience is available for PRBs using activated carbon the
removal efficiency should be expected to be greater and more reliable than zero-valent iron but
far more costly Groundwater monitoring would ensure that the contamination was being
adequately contained by the PRB and would be necessary on a long-term basis
Permanence of Remedy Installation of a PRB would be considered a permanent remedy
although periodic maintenance and replacement of reactive material in the gate would be
required for both carbon and iron-based systems
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9^X)l0030929wro 4-17 HSI GGOTfSnS IDC
MITEC 104e 02395
434 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to reduce VOC
concentrations in the remaining groundwater to below Groundwater Enforcement Standards
Natural gradient flushing would also eventually reduce the areas of highest groundwater
contamination to below Groundwater Enforcement Standards
Surface Water Quality Standards VOC concentrations in groundwater discharging to the
unnamed brook would be reduced significantly Thus operation ofthe PRB would result in
achievement of Water Quality Criteria for the protection of human health and aquatic organisms
(VTDEC 2000)
435 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This downgradient containment alternative would offer protection to both human health
and the environment if VOC concentrations in groundwater discharging to the unnamed brook
were to increase or if the region of contaminated groundwater were to expand in size This
alternative assumes institutional controls will be in place to continue sump venting in the
basement at Lot 3-30 on South Browneil Road restrict installation of new basements below the
water table within the region of VOC-contaminated groundwater and prevent potable use of
groundwater within the contaminated region Protection relative to the risks posed by expansion
ofthe region of contaminated groundwater to the unnamed brook would be achieved at the end
ofthe construction period of four to six months The residual risks posed by contaminated
material remaining within the groundwater would not be significant because all potential
exposure routes would be addressed
FOR ALLING INDUSTRIAL PARK MWP JX3CSN753V2000AIXINOFS90Crl0O30929wPD 4-18 HSI GCOTtSHS IRC
MITEC 104e 02396
436 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
bull Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction Removal and handling of contaminated soils
presents potential risks to construction workers during construction which could
be minimized through health and safety controls
bull Reliability of the Technology Although many full-scale applications of this
approach have been conducted they have been relatively recent Long-term
reliability and effectiveness of PRBs has not been established
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the PRB
was inadequate to prevent expansion ofthe region of VOC-contaminated
groundwater implementation of additional resources would not be hampered by
this alternative
Administrative Feasibility Installing and maintaining the PRB will require access to
properties overlying the region of VOC-contaminated groundwater Additionally property
owner cooperation would be needed to operate maintain and monitor wells located upstream
and downstream ofthe gate sections ofthe PRB system Restrictions would also be needed to
implement institutional controls to continue sump venting in the basement at Lot 3-30 on South
Browneil Road restrict the construction of basements below the water table within the region of
VOC-contaminated groundwater and prevent potable use of groundwater within the region of
VOC contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UO(XAAUJNOFS9-O0 10030929 WPO 4-19 HSI GGOTrSMS IDC
MITEC 104e 02397
Availability of Services and Materials The materials equipment and personnel required
to design install and maintain the PRB are readily available
437 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 3 The
capital costs would be $572000 for the source control application and $1022000 for the
containment option OampM costs include groundwater monitoring and periodic replacement of
the permeable barrier These average $64000 per year for the source control application and
$112000 per year for the containment option The present worth analysis calculated at a 7
discount rate over a 30-year duration yields a total of $1277356 for the source control option
and $2248691 for the containment option
4 4 A L T E R N A T I V E 4 M O N I T O R I N G I N S T I T U T I O N A L C O N T R O L S AND
N A T U R A L A T T E N U A T I O N
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water
The chief mechanisms contributing to reduction of contaminant concentrations in
groundwater by natural attenuation include biotransformation dilution dispersion and discharge
through advective flow and volatilization (EPA 1998) Volatilization is not likely a major
mechanism at the Study Area since contaminated groundwater is located at depth below the
FOR ALLING INDUSTRIAL PARK
MWP_DOCSW7S3U000WXINoFS9-001003O929wro 4-20 HSI GGOTfaDS IDC
MITEC 104e 02398
water table A natural attenuation evaluation will be conducted to better identify the mechanisms
contributing to concentration reduction through natural attenuation Monitoring to be completed
for this evaluation is included in Section 62 EPAs Technical Protocol for Evaluating Natural
Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) was used as the basis for the
design ofthe natural attenuation evaluation
441 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community A HASP would be prepared for the remedial
activities In conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Groundwater monitoring wells would be sampled to determine changes in
VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative
Time to Achieve Remedial Action Objectives The RAOs for groundwater would be
achieved when monitoring results indicated that the region of contaminated groundwater had
naturally attenuated and groundwater standards had been met It is estimated that natural
attenuation of contaminants to ARARS will exceed the two-year time frame for short-term
effectiveness
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0ALUNOFS9^X)M0030929wro 4-21 HSI GGOTfaflS jflC
MITEC 104e 02399
Treatment This alternative involves only natural in-situ processes No remediation
wastes would be generated
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area
Amount of Material Contained or Treated Natural attenuation may serve to contain the
region of VOC-contaminated groundwater at the Study Area Treatment may be accomplished
through biotransformation ofthe contaminants to environmentally acceptable compounds
443 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation of VOC-contaminated groundwater at the Study Area
would eventually achieve the ARARs Residual risk to human health would be controlled
through institutional controls Implementing institutional controls to maintain the sump venting
at Lot 3-30 on South Browneil Road restrict the construction of basements below the water table
within the region of VOC-contaminated groundwater and to control the use of groundwater
within the region of VOC-contaminated groundwater for potable purposes would provide
protection against the potential for exposure
Adequacy and Reliability of Controls Monitoring for VOC concentration reductions in
groundwater and institutional controls would be the main controls of this alternative Sump
venting at Lot 3-30 on South Browneil Road would prevent indoor air impacts at this location
and restrictions on construction of basements below the water table would prevent future indoor
air impacts Control ofthe use of groundwater within the region of VOC-contaminated
groundwater for potable purposes would minimize potential use of groundwater with VOCs
above federal and state drinking water standards Groundwater monitoring would ensure that
attenuation of VOC concentrations was proceeding and provide for periodic assessment ofthe
region of VOC-contaminated groundwater in the Study Area
FOR ALLING INDUSTRIAL PARK bull MWPJXXSN7532000AUINOFS9-00I0O30929WPD 4 - 2 2 HSI GGOTPaMS IRC
MITEC 104e 02400
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time
444 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
445 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
446 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK _
M W P _ D O C S N 7 5 3 U O O O A L U N O F S 9 - O O U 0 0 3 0 9 2 9 W P O 4-23 HSI GGOT 13118 IflC
MITEC 104e 02401
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
bull Ability to Construct the Alternative No major construction is included in this
alternative
bull Reliability ofthe Technology Ongoing monitoring and evaluation on would
ensure that natural attenuation was controlling and remediating the contaminated
groundwater
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation was not restricting the size ofthe region of VOC-contaminated
groundwater implementation of additional remedial actions would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
sample and maintain monitoring wells Restrictions would also be needed to implement
institutional controls to continue sump venting in the basement at Lot 3-30 on South Browneil
Road restrict construction of basements below the water table in VOC-contaminated
groundwater and prevent potable use of groundwater within the region of VOC-contaminated
groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor natural attenuation are also available
447 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 4 The
capital costs would be $55000 and include the initial natural attenuation evaluation and the
implementation of institutional controls OampM costs include groundwater monitoring These are
$9000 per year The present worth analysis yields a total of $163083 for this 30-year
alternative
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0AUJNOFS9^X)10030929wro 4-24 HSI GGOTraDS 1110
MTECl04e 02402
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water and
phytoremediation would be used to intercept TCE-contaminated groundwater
where it discharges to the unnamed brook
In this alternative all components of Alternative 4 would be implemented and
phytoremediation would be implemented in the area where TCE- contaminated groundwater
intersects the unnamed brook to intercept the contaminated groundwater and reduce the amount
of VOCs reaching the brook Phytoremediation of VOCs is still an experimental technology
Several field studies have used hybrid poplars (EPA 2000) to extract TCE- contaminated
groundwater It has been shown that TCE is removed along with groundwater by the trees and
metabolized as well as transpired from the leaves The rate of TCE contaminant removal from
the groundwater and its discharge to air by transpiration varies based on site specific conditions
and season Therefore contaminant or groundwater removal rates are impossible to predict at
this time without field studies Trees may be subject to destruction by natural disasters and pests
Their condition must be monitored and they may require replacement
F O R ALLING INDUSTRIAL PARK MWPJXXSN7532OOOWXINGFS9JraquoIOO30929WPO 4 - 2 5 H S I G G O T r S D S IOC
MITEC 104e 02403
In order for interception ofthe region of contaminated groundwater to be effective the
trees must be planted so that the root zone intercepts the contaminated groundwater Due to the
depth ofthe higher VOC concentrations in most areas ofthe site phytoremediation would be
ineffective in containing expansion ofthe region of contaminated groundwater An exception to
this is the area near the unnamed brook According to the SIR (HSI GeoTrans 2000) VOC-
contaminated groundwater appears to be discharging upward in groundwater into the unnamed
brook Trees planted along the border ofthe brook may help to intercept this contaminated
groundwater before it discharges into the brook
451 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 5 are as follows
Protection of Workers and the Community Normal landscaping hazards would be
associated with installation ofthe trees A HASP would be prepared for the remedial activities
In conformance with OSHA regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative Suitable dust control measures would be implemented during
planting of trees
Time to Achieve Remedial Action Objectives The time required for maximum
interception ofthe contaminated groundwater by the trees would depend on site specific
conditions such as root growth rate and tree survival rate The RAOs for groundwater would be
achieved when monitoring results indicated that VOC concentrations had attenuated and
groundwater standards had been met It is estimated that natural attenuation of contaminant
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
FOR ALLING INDUSTRIAL PARK MWP J X 3 C S N 7 5 3 2 0 0 0 A U J N O F S 9 ^ ) 0 1 0 0 3 0 9 2 9 W P D 4-26 HSI G G O T H S I I S IDC
MITEC 104e 02404
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment This alternative involves only in-situ treatment ofthe groundwater Plant
tissue would be analyzed for the presence of VOCs Plant materials can bio-accumulate metals
present in soil and groundwater If concentrations are high enough dead plant matter may have
to be disposed in an appropriate manner
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area Phytoremediation may
metabolize some ofthe VOCs
Amount of Material Contained or Treated Natural attenuation and phytoremediation
may serve to prevent expansion ofthe region of VOC-contaminated groundwater at the Study
Area Treatment is accomplished with biotransformation ofthe contaminants to environmentally
acceptable compounds
453 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation ofthe region of VOC-contaminated groundwater and
phytoremediation at the Study Area would eventually achieve the ARARs Implementing
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil Road
restrictions on construction of basements below the water table in regions of VOC-contaminated
groundwater and to control the use of groundwater for potable purposes within the region of
VOC-contaminated groundwater would provide protection against the potential for exposure
FOR ALLING INDUSTRIAL PARK MWP_IXXSW532000ALL1NOFS9^)0I0030929WTO 4-27 HSI GCOTraDS IflC
M l T E C l 0 4 e 0240S
Therefore despite the fact that an extended time period may be required to reduce VOC
concentrations to an acceptable level the residual risk associated with this alternative would be
minimal Trees planted near the unnamed brook may serve to intercept contaminated
groundwater before it discharges to this receptor
Adequacy and Reliability of Controls Groundwater monitoring for natural attenuation
institutional controls and interception of contaminated groundwater before it reaches the
unnamed brook would be the main controls of this alternative Sump venting at Lot 3-30 on
South Browneil Road would prevent indoor air impacts at this location and restriction on the
construction of new basements below the water table within the region of VOC-contaminated
groundwater would prevent future indoor air impacts at other locations Control ofthe use of
groundwater for potable purposes within the region of VOC-contaminated groundwater would
minimize potential use of groundwater with VOCs above federal and state drinking water
standards Groundwater monitoring would ensure that natural attenuation of contaminants was
proceeding and provide for periodic assessment ofthe region of VOC-contaminated groundwater
in the Study Area Groundwater and surface water monitoring would also be conducted to
monitor success ofthe phytoremediation in intercepting contaminated groundwater before it
reaches the unnamed brook
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time Trees must be monitored and will be replaced in
the event of destruction by severe weather pests or other reasons
454 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUINOFS9-00I0030929WPD 4-28 HSI GGOTraflS IllC
MITEC 104e 02406
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
Phytoremediation at the edge ofthe unnamed brook would further reduce the VOC
concentrations in groundwater discharging to the brook
455 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
456 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
Ability to Construct the Alternative Installation of this alternative requires
landscaping skills which are readily available
bull Reliability ofthe Technology Ongoing monitoring and evaluation would ensure
that natural attenuation was controlling and remediating the contaminated
groundwater Ongoing monitoring ofthe condition ofthe trees would also be
required to ensure they are continuing to grow and do not need replacement
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^)OM0030929WPD 4-29 HSI GGOTfaDS jflC
MITEC 104e 02407
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation and phytoremediation were not restricting the size ofthe region of
VOC-contaminated groundwater implementation of additional resources would
not be hampered by this alternative
Administrative Feasibility Planting trees and if necessary installing and monitoring
additional wells might require access to private property Additionally property owner
cooperation would be needed to sample and maintain monitoring wells Restrictions would also
be needed to implement institutional controls to continue sump venting in the basement at Lot 3shy
30 on South Browneil Road restrict construction of new basements below the water table in
regions of VOC-contaminated groundwater and prevent potable use of groundwater within the
region of VOC-contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to plant the trees and monitor natural attenuation are also available
457 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 5 The
capital costs would be $80000 and include the initial natural attenuation evaluation the
implementation of institutional controls and installation of a phytoremedial barrier of poplars
OampM costs include groundwater monitoring and maintenance ofthe phytoremedial barrier
These are $11000 per year The present worth analysis yields a total of $209397 for this 30shy
year alternative
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000ALLINOFS9^)0I0030929WPD 4-30 HSI GGOTfaDS IPC
MITEC 104e 02408
r TI Table 41 Cost estimates for remedial alternatives i deg 5 70
8 P
QUANTITY UNITS UNIT C O S T CAPITA L C O S T ANNUAL
OampM C O S T
5 n Alternative I No Action 8 O a Q
na na $0 $0 $0 a sect
Total $0 $0
Alternative 2 Monitoring Institutional Controls and Hydraulic Containment
1) Implement Institutional Controls 32 properties $10000 $32000
2) Groundwater Monitoring $9000
3) Pumping System
Option 1 Source Containment
Extraction wellspiping $50000 $15000
Electrical distributioncontrol $25000 $8000
Construction oversight $25000
Groundwater treatment system $75000 $45000
Total Option 1 $207000 $77000
Option 2 region of contaminated
groundwater Containment
Extraction wellspiping $175000 $35000
w Electrical distributioncontrol $50000 $20000
O
o H mO Construction oversight $125000
o n gt Groundwater treatment system $350000 $75000
o z 0) Tolal Option 2 $732000 $139000
i deg QUANTITY UNITS UNI T C O S T
5 so
Alternative 3 Monitoring Institutional Controls and Permeable Barrier
m t - 1) Implement Institutional Controls 32 properties $10000
9 O 2) Groundwater Monitoring
| o 3) Permeable Harrier
Option I Source Containment
Barrier installation 1200 feel $450
Total Option 1
Option 2 region of contaminated
groundwater Containment
Barrier Installation 2200 feet $450
w Total Option 2 NJ
Alternative 4 Monitoring Institutional Controls and Natural Gradient Flushing
1) Implement Institutional Controls 32 properties $10000
2) Groundwater Monitoring
3) Natural Attenuation Evaluation
Total
Alternative 5 Monitoring Institutional Controls Natural Gradient Flushing and Phytoremediation
1) Implement Institutional Controls 32 properties $10000 X (A 2) Groundwater Monitoring
reg 3
o m O H
3) Natural Attenuation Evaluation
4) Phytoremediation
gt z Total (A
Notes na = not applicable
CAPITAL C O S T
$32000
$540000
$572000
$990000
$1022000
$32000
$23000
$55000
$32000
$23000
$25000
$80000
ANNUAL
OampM C O S T
$9000
$55000
$64000 1
$103000
$112000
$9000
$9000
$9000
$2000
$11000
MODEL CALCULATED GROUNDWATER CONTOUR IN FEET ABOVE MEAN SEA LEVEL
APPROXIMATE PROPERTY BOUNDARY
M6-2 raquo EXISTING MONITORING WELL
CP-6 bull EXISTING SOIL BORING
M 8 - 2 raquo MONITORING WELL (RESAMPLED)
bull SMALL DIAMETER BORING - BELOW CLAY
bull BEDROCK MONITORING WELL
A S I - 2 I H S I GEOTRANS WELL CLUSTER LOCATION
U-TRIB-8a SURFACE WATER SAMPLING LOCATION R S - U
a PASSIVE SAMPLER LOCATION
T2-2 PROFILE SAMPLE LOCA1ION (JOHNSON COMPANY 1999)
WELL DESTROYED
TEF Concentrat ions ( u g A l
1000 - 10000
iry IOOOO - 20000
bull 20000 + NOTES AREA WHERE TCE CONCENTRATION IS
M l LOCATIONS APPROXIMATE INTERPOLATED THERE IS NO TCE
BASE PUN DEVELOPED FROM DATA FROM THESE AREAS
1 TOWN OF WUUSION PARCEL BOUNOART MAP (SHIPPED 121597) PROVIDED ST (VS (BURUNCTON VT) IN DXF FORMAT
2 PLAN DEVELOPED BT HEINDEL AND NOTES (BURUNCTON VT) FOR THE BATES PROPER1Y 1NVESIBAT10N AND PROVIDED TO THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION HASTE MANAGEMENT DIVISION 1997
3 ORTHOPHOTO SHEET 100216 VERMONT STATE MAPPING PROJECT 1988
4 TORN OF WIUJSTON ASSESSORS MAP 1997
5 VARIOUS SITE PUVQ CN RLE WITH THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION WASTE HMUGElENr OOVBON
6 DM FROM JOHNSON DD REPORT UNTIED GROUNDWXIER IHVESI1CAH0M ALLWC INDUSTRIAL PARK DATED 7 W FDR THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Modeled Site - Existing Conditions copy H
pound n Williston Vermont o CHECKED MS HSI
DRAFTED RMK GEOTRANS FU fa-Site-mod-ECdwg 4 - 1 A TITIA T t n HBVAIT
DATE 10600
5 COMPARATIVE EVALUATION OF ALTERNATIVES
The purpose of this section is to compare the remedial alternatives on the basis ofthe
evaluation criteria developed and discussed in Section 4 and provide a recommended alternative
These criteria include overall protection of human health and the environment short-term
effectiveness reduction of toxicity mobility or volume long-term effectiveness and
permanence compliance with ARARs implementability and cost
The comparative analysis is conducted to highlight significant differences between
identified alternatives All alternatives for the Study Area groundwater except the no-action
alternative include the following
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater and
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
The no-action alternative is not included in the comparison provided in the following
sections since it would not meet the RAOs All four ofthe remaining alternatives would meet
the RAOs stated in Section 32
51 SHORT-TERM EFFECTIVENESS
Protection of Workers and the Community Groundwater would be monitored under all
scenarios to look for any changes in VOC concentration which might result in increased risk
The containment options in Alternatives 2 3 and 5 would be more protective ofthe community
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320MAUINOFSWWI0030929WPD 5 - 1 HSI GSOTrSflS IflC
MITEC 104e 02415
if the region of VOC-contaminated groundwater were shown to be expanding and presenting
increased risk However in the event that the region of VOC-contaminated groundwater is not
expanding Alternative 4 would be equally protective Under all options a HASP would be
prepared and in conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Alternatives 2 3 and 5 would involve normal construction hazards during
installation of pumping wells piping trenches treatment enclosures permeable reactive barrier
trenches or planting of trees In addition under Alternative 5 release of VOCs to air through
transpiration may need to be measured to prevent creation of a new exposure pathway and health
risk through air
Environmental Impacts Minor additional impacts may occur during installation of
Alternatives 2 3 and 5 due to dust and sediment production Groundwater would need to be
treated to regulatory discharge limits before discharge under Alternative 2 and treatment may be
temporarily hampered in the event of treatment system mechanical failure Because ofthe
experimental nature of phytoremediation greater uncertainty exists that the trees will be effective
in acting as a barrier to expansion ofthe region of contaminated groundwater to the unnamed
brook under Alternative 5 If it is shown that expansion ofthe region of contaminated
groundwater toward the unnamed brook poses a future health risk additional measures may
become necessary to contain the contaminated groundwater
Time to Achieve Remedial Action Objectives None ofthe alternatives has an appreciably
shorter time frame than the others in reducing groundwater concentrations to VT Groundwater
Enforcement Standards and VT Water Quality Criteria This is because while Alternatives 2 3
and 5 rely on engineered remedies to contain the region of contaminated groundwater residual
TCE DNAPL and geologic heterogenieties will cause the contaminant source to persist for an
extended time As discussed in Section 34 active DNAPL removal alternatives were removed
during the preliminary screening DNAPL has never been directly observed at the Study Area
and is assumed to be present based on dissolved concentrations of TCE DNAPL distribution is
FOR ALLING INDUSTRIAL PARK MWP_DOCSW753200OALLINOFS9-00M0O30929wPD 5-2 HSI GGOTr3nS IflC
MITEC 104e 02416
expected to occur heterogeneously at residual saturation and it is infeasible to locate the DNAPL
to treat it directly Because of this each ofthe remedies is expected to exceed the two-year time
frame for short term effectiveness
52 R E D U C T I O N O F T O X I C I T Y M O B I L I T Y O R V O L U M E T H R O U G H
T R E A T M E N T
Treatment All ofthe proposed alternatives would treat the residual DNAPL source of
contamination through dissolution and natural gradient flushing While Alternatives 2 3 and 5
are intended primarily for containment and not groundwater restoration these alternatives would
actively treat some concentrations in groundwater
Reduction in Toxicity Mobility or Volume The containment Alternatives 2 3 and 5
may result in decreased mobility ofthe region of contaminated groundwater However
groundwater monitoring may show that the region of contaminated groundwater is not
expanding under existing conditions If this were the case containment would not result in any
additional decrease in size ofthe region of VOC-contaminated groundwater
Since Alternatives 2 3 and 5 treat concentrations in groundwater without treating the
residual DNAPL source and the amount of contaminants that can be removed from groundwater
by these methods would likely equal the amount added by continued dissolution ofthe DNAPL
sources alternatives 2 3 and 5 would not result in a greater reduction in the total volume of
contaminant than Alternative 4
Amount of Material Contained or Treated As described above the amount of material
contained under Alternatives 2 3 and 5 would not be any greater than under Alternative 4 unless
the size ofthe region of VOC-contaminated groundwater is not presently contained by natural
attenuation If natural attenuation is currently controlling the size ofthe region of VOC-
contaminated groundwater then the amount of contaminants being removed by natural processes
equals the amount added by dissolution of residual DNAPL In this case intercepting and
removing contaminants from the groundwater using one ofthe containment alternatives will not
result in a significant increase in the amount of contaminant treated
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000ALUNOFS9-OOUM30929WPD 5-3 HSI GGOTrdHS jflC
MITEC 104e 02417
53 LONG-TERM EFFECTIVENESS
Residual Risk Implementing institutional controls to maintain the sump venting at Lot 3shy
30 on South Browneil Road to restrict construction of buildings with basements below the water
table within the region of VOC-contaminated groundwater and to control the use of groundwater
for potable purposes within the region of VOC-contaminated groundwater would provide
protection against the potential for exposure to existing concentrations in groundwater
Therefore despite the fact that some ofthe remedial alternatives may be required to operate for
an extended time the residual risk associated with any ofthe alternatives would be minimal
Adequacy and Reliability of Controls Alternative 5 has the least reliable controls
because ofthe difficulty in predicting the effectiveness of phytoremediation The second least
reliable alternative would be Alternative 2 because of its reliance on mechanical equipment to
maintain containment and to meet discharge standards
Permanence of Remedy All ofthe proposed alternatives would rely on permanent
destruction of contaminants through natural attenuation over time If one ofthe containment
technologies are required maintenance and periodic replacement would be necessary to ensure
containment was maintained until expansion ofthe region of VOC-contaminated groundwater
was no longer a threat This maintenance would be straight-forward and easy to continue for any
of the containment alternatives
54 COMPLIANCE WITH ARARs
All ofthe alternatives would eventually reduce contaminant concentrations within the
current region of contaminated groundwater to below VT Groundwater Enforcement Standards
and VT Water Quality Criteria
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Each ofthe alternatives would rely on groundwater monitoring and institutional controls
on venting basement sumps at Lot 3-30 on South Browneil Road restrictions on the construction
of new basements below the water table within the region of VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWPJX3CSN7S3UOOOAUJNGFS9-OOUM30929wro 5-4 HSI GOTr3nS IflC
MITEC 104e 02418
and potable use of groundwater from within the region of VOC-contaminated groundwater to
maintain conditions protective of human health and the environment If monitoring shows that
natural attenuation is not restricting the size ofthe region of VOC-contaminated groundwater
then one ofthe containment alternatives would be more protective than Alternative 4
56 IMPLEMENTABILITY
The most easily implemented alternativewould be Alternative 4 as it would not require
any installation but only groundwater monitoring to gauge the progress of natural attenuation
Alternative 5 requires all the components of Alternative 4 and adds trees along the unnamed
brook Alternatives 2 and 3 are the most difficult to implement as they require disruptive and
invasive installation techniques However the necessary equipment materials workers and
specialists required to implement all the alternatives are available
57 COSTS
The present worth costs range form a low of $163083 for Alternative 4 to a high of
$2287474 for the containment option of Alternative 3 These present worth costs were based on
a 30-year service period and an annual discount rate of seven percent
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALLINOFS9-OOM0030929WPD 5-5 HSI GGOTfaDS IflC
MITEC 104e 02419
6 PREFERRED REMEDY
61 PREFERRED REMEDY
Alternatives 2 34 and 5 are all protective of human health and the environment and rely
on the following technologies
bull groundwater monitoring to evaluate spatial and temporal trends in VOC
concentration
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil
Road
restrictions on the construction of new buildings within the region of VOC-
contaminated groundwater to prevent unacceptable concentrations of volatile
compounds in indoor air and
institutional controls to restrict the use of groundwater for potable purposes within
the region of VOC-contaminated groundwater
All ofthe alternatives rely on dissolution and natural gradient flushing to treat the
residual DNAPL source of groundwater contamination Therefore none ofthe alternatives has
an appreciably shorter time frame than the others in reducing groundwater concentrations to VT
Groundwater Enforcement Standards and VT Water Quality Criteria
Alternative 4 includes remediation by natural attenuation There is no active containment
technology associated with Alternative 4 As such it is simpler less costly and easier to
implement than Alternatives 2 3 and 5 which include some form of active containment ofthe
region of VOC-contaminated groundwater Containment could become necessary under
Alternative 4 if future groundwater quality monitoring indicates the region of VOC-contaminated
groundwater is impacting a sensitive receptor or is expanding in size and not contained by natural
attenuation The SIR (HSI GeoTrans 2000) risk assessment (Menzie Cura 2000a and 2000b)
showed that under current conditions groundwater was not impacting any receptors to a degree
FOR ALLING INDUSTRIAL PARK MWPJXXrSN7532000ALUNcFS9-OOU0030929WO 6 - 1 HSI GSOTraflS jflC
MITEC 104e 02420
that would represent a human health risk or risk to the environment Therefore containment is
not necessary to protect any sensitive receptors currently being impacted by the region of
contaminated groundwater Continued groundwater monitoring is required to demonstrate
whether the region of VOC-contaminated groundwater is stable in size or expanding
Alternative 4 has been selected as the preferred remedy On-going monitoring ofthe
effectiveness of natural attenuation in containing and remediating the region of VOC-
contaminated groundwater is part ofthe remedy Further details on this proposed monitoring are
provided in Section 62 If monitoring shows that size ofthe VOC-contaminated region is not
contained by natural attenuation then one ofthe other technologies could be used to supplement
Alternative 4 based on the nature ofthe expansion ofthe region of contaminated groundwater
If monitoring data indicates that VOC concentrations in the groundwater discharging to the
unnamed brook have increased and pose an unacceptable risk to human health and the
environment then phytoremediation could be considered in this location Phytoremediation
would be less costly than installation of a permeable reactive barrier or active groundwater
extraction system Phytoremediation would be ineffective in containing expansion ofthe region
of contaminated groundwater in the rest ofthe Study Area however because contaminated
groundwater is further below ground surface in these regions and phytoremediation is limited by
the depth ofthe roots ofthe selected plant If monitoring data indicates that the southwestern
portion ofthe region of VOC-contaminated groundwater is expanding then Alternative 4 could
be supplemented with extraction wells or a PRB for hydraulic containment
62 MONITORING PROGRAM
In its guidance document Use of Monitored Natural Attenuation at Superfund RCRA
Corrective Action and Underground Storage Tank Sites (EPA 1999) EPA states that long-term
performance monitoring will be a fundamental component of any remedy which relies on
monitored natural attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000 A1XINOFS9-00 I0030929 WPO 6-2 HSI GSOTrSDS IMC
MITEC 104e 02421
The SIR (HSI GeoTrans 2000) concluded that there were not sufficient temporal data to
determine whether the region of VOC-contaminated groundwater was stable in size or
expanding Continued monitoring for the compounds of concern will be necessary to confirm
that the region of VOC-contaminated groundwater is not expanding Table 6-1 identifies
locations which are proposed to be monitored annually to evaluate spatial and temporal trends in
VOC concentration These locations are shown in Figure 6-1
There are several mechanisms by which natural attenuation occurs These include
dilution of contaminant concentrations sorption ofthe contaminant onto the soil matrix and
biodegradation ofthe contaminant to a less toxic form Further study is necessary to determine
the contribution of each of these mechanisms to overall attenuation ofthe area of VOC
contamination
Evidence of biodegradation can be obtained by collecting three types of data of increasing
complexity (National Research Council 1993)
bull documentation of contaminant loss or transformation in the field
bull the presence of electron donors and acceptors andor alteration of groundwater
chemistry consistent with intrinsic biodegradation processes and
microcosm studies which provide direct microbiological evidence that indigenous
bacteria are capable of mediating the contaminant transformations observed
Microcosm studies are typically not employed unless the contaminant is unique or the
transformation which is being observed is not well documented in the literature For the
transformations anticipated in the Study Area numerous laboratory and field studies have
established that naturally-occurring bacteria are capable of mediating the contaminant
transformations of contaminants of concern For that reason microcosm studies will not be
performed as part of this study
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^)OM0030929 WPO 6-3 HSI GSOTrSHS jflC
MITEC 104e 02422
Of particular concern to the determination of biodegradation is the delineation of aerobic
and anaerobic zones within the contaminant area because these zones dictate the types of
biological degradation that would be expected to occur Oxygen is the primary electron acceptor
during aerobic oxidation Anaerobic processes including denitrification iron-reduction sulfate-
reduction and methanogenesis occur in the absence of oxygen and use nitrate iron (III) sulfate
and carbon dioxide respectively as primary electron acceptors Reductive dehalogenation of
TCE has been observed under iron-reducing sulfate-reducing and methanogenic conditions
although very low redox (ie methanogenic) conditions may be necessary for production of
ethene and ethane
Further sampling and analysis of selected parameters in groundwater will be conducted to
assess the potential for biodegradation in accordance with EPAs Technical Protocol for
Evaluating Natural Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) The
twelve sampling locations shown in Table 6-1 used to monitor ofthe area of VOC contamination
will also be sampled for parameters used to evaluate biodegradation The parameters include
compounds of concern and compounds which are degradation products ofthe compounds of
concern shown in Table 6-2 Table 6-3 lists parameters chosen to evaluate the presence of
electron donors and a groundwater chemical environment conducive to biologic reductive
dechlorination These parameters will be sampled once unless evaluation ofthe data indicates
that further sampling would be beneficial to calculate a rate of attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000ALUNCFS9JraquoM0030929 WPD 6-4 HSI GSOTfaHS IDC
MITEC 104e 02423
Table 6-1 Sampling locations
LOCATION
ID
ASI-32D2
RB-1
ASI-26D2
ASI-I6D2
ASI-13D2
ASI-23D2
ASI-18D2
ASI-12D2
ASI-01D2
ASI-09D2
U-TRIB-5
SW-I
Notes BGS =
SCREENED
INTERVAL
DEPTH BGS
35-40
35-40
35-40
30-35
31-36
25-30
32-37
35-40
31-36
31-36
surface
surface
Below Ground Surface
RATIONALE
Upgradient of region of highest VOC concentrations
Closest to lot 19-11 former lagoon and septic leach field source areas
Within area of highest concentrations
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient ofthe region of VOC concentrations in the southwest direction
Downgradient of source area within region of VOC concentrations in southeast direction
Downgradient of source area within region of VOC concentrations in southeast direction
At downgradient edge of region of VOC concentrations in southeast direction
Stream upgradient of VOC discharge from groundwater
Stream at location of VOC discharge from groundwater
(
FOR ALLING INDUSTRIAL PARK MWP DOCSN7532000ALUNCFS9^X)VI0030929WPO 6-5 HSI GeoTrans inc
MITEC 104e 02424
Table 6-2 VOC analytes
PARAMETER
TCE
PCE
11-DCE
cis 12-DCE
trans 12-DCE
Vinyl Chloride
Benzene
Toluene
Ethylbenzene
Xylenes
ANALYTICAL METHOD
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
8260A
8260A
8260A
8260A
RATIONALE |
Contaminant of Concern
Contaminant of Concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
Notes SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical
Methods SW-846 US EPA 3ri edition 1986
TCE = Trichloroethene
PCE = Tetrachloroethene
11-DCE = 11-Dichloroethene
cis 12-DCE = cis 12-Dichloroethene
trans 12-DCE = trans 1 2-Dichloroethene
FOR ALLING INDUSTRIAL PARK MAWP DOCSN75320laquoMLUNOFS9^XM0030929WPO 6-6 HSI GeoTrans inc
MITEC 104e 02425
Table 6-3 Parameters to evaluate biodegradation
PARAMETER ANALYTICAL METHOD RATIONALE
Field Parameters
Alkalinity as CaCO Hach Alkalinity Test Kit Model ALP Positive correlation between microbial activity and
MG-L alkalinity Measures the buffering capability of
groundwater
Total Ferrous Iron Hach Method 8146 May indicate anerobic degradation
Dissolved Hydrogen Reducing Gas Detector Predicts possibility for reductive dechlorination
Dissolved Oxygen Direct Meter Reading Indicates probability of aerobic vs aerobic
degradation
PH Direct Meter Reading Aerobic and anaerobic biological processes are pH
sensitive
Redox potential (Eh) A2580B An indicator ofthe relative tendency of a solution
to accept or transfer electrons
Specific Conductivity Direct Meter Reading Used to determine when purging of a well for
sampling is complete
Temperature Direct Meter Reading Affects the metabolic activity of bacteria and the
solubility of dissolved gasses
Laboratory Analyses
Dissolved Organic Carbon SW 9060 Carbon and energy source which can drive
dechlorination
Nitrate-N IC Method E300 At higher concentrations may compete with
reductive pathway
Total Manganese EPA 2007 or 2009 To determine if anaerobic biological activity is
solubilizing Mn for the aquifer matrix
Chloride SW 9250 Can be used as a conservative tracer to estimate
biodegredation rates
Sulfate IC Method E300 May be used as an electron acceptor for
biodegradation after dissolved oxygen and nitrate
are depleted
Sulfide IC Method E300 Indicates if reductive pathway is possible
Ethane SW 3810 Modified Daughter product of Ethene
Ethene SW 3810 Modified Daughter product of Vinyl Chloride
Methane SW 3810 Modified Ultimate reductive daughter product
Notes Rationales taken from USEPA 1998
Hach refers to Hach Company Catalogue
A refers to Standard Methods for the Examination of Water and (fostewater 18 edition 1992
E refers to Methods for Chemical Analysis of Water and Wastes US EPA 1983
SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical Methods SW-846 US EPA 31 edition
1986
FOR ALLING INDUSTRIAL PARK | C I nr A^Twmrmr bullbullltlaquo MWP DOCSN7532000ALLINCFS9-0Ol0030929wro 6-7
MITEC 104e 02426
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REFERENCES
Brinkerd 1996 Site Investigation Ailing Industrial Park Williston Vermont April to
September 1996 October 1996
Fitts C R 1997 TWODAN documentation prepared by Dr Charles Fitts Scarborough Maine
Griffin 1995 Monitor Well Log (MW-4) and Analytical Data Bove-Fagan Ice Cream
Distribution Investigation Williston VT Griffin International Inc
HSI GeoTrans Inc 2000 Site Investigation Report June 15 2000
Johnson 1999 Limited Groundwater Investigation N753 July 6 1999
Menzie Cura 2000a Screening Level Risk Characterization April 2000
Menzie Cura 2000b Addendum to Screening Level Risk Characterization June 1 2000
NRC 1993 National Research Council Committee on Bioremediation In Situ Bioremediation
When Does it Work Washington DC National Academy Press 1993
TRC 1993 Site Inspection-Ailing Industrial Park Williston Vermont VTD982748477 Final
Report
US EPA 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies
Under CERCLA OSWER Directive 93553-01
U S EPA 1992 Estimating Potential for Occurrence of DNAPL at Superfund Sites OSWER
Number 93554-07FS 9p
FOR ALLING INDUSTRIAL PARK MWP_DOCSW75JV20(XKALUNOFS9-0(AI0030929WPD 7 - 1 HSI GeOTTSHS irtC
MITEC 104e 02428
US EPA 1993 Guidance for Evaluating the Technical Impractibility of Groundwater
Restoration EPA540-R-93-080
US EPA 1998 Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents
in Ground Water EPA600R-9812~8
US EPA 1999 Use of Monitored Natural Attenuation at Superfund RCRA Corrective Action
and Underground Storage Tank Sites EPA Directive 92004-17P
US EPA 2000 Introduction to Phytoremediation EPA600R-99107
VTDEC 1996 Site Investigation Guidance August 1996
VTDEC 1997 Chapter 12 Groundwater Protection Rule and Strategy October 1997
VTDEC 2000 Vermont Water Quality Standards March 2000
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(AAUJNGFS9^)OM0030929WPD 7-2 HSI GSOTfanS tC
MITEC I04e 02429
APPENDIX A
TWODAN INPUT FILES
FOR ALUNG INDUSTRIAL PARK MWP_DOCSVN7S3200(AALUNOFS9-0(AI0030929WPO HSi GfiOTfanS WC
MITEC 104e 02430
i - i i a a o U 0 t A X H i d t l Z 018J UaiUEAJJLKATia Htj v j pound
50-oo
4 e s y lt lt 4 A M ^ L S m m 9 m mdash t j y m
MITEC 104e 02431
15
6 Lancaster County Road HSI Harvard Massachusetts
GEOTRANS 01451 A TETRA TECH COMPANY 97^772-7557 FAX 978-772-6183
R E C E i ^ D PNN753-001
CUTLER A8TANPIELD Campltf December 11997
Mr Michael Smith Vermont Department of Environmental Conservation Waste Management Division 103 South Main Street Waterbury VT 05671-0404
Subject Proposed Surface Water Sampling MITEC Site Williston VT
Dear Michael
This letter describes the proposed surface water sampling at the MITEC site that we discussed during our meeting of November 201997 Our intention is to complete this work as soon as possible to avoid the complications of colder weather and possible freezing ofthe stream My understanding is that you are prepared to review and approve this plan fairly quickly and also to assist us with obtaining property access and appropriate maps to locate these sampling sites We appreciate this help In future we anticipate that the constraints of weather will not require such an expedited field mobilization process and that we will all have more time to prepare
Purpose and Extent of Sampling
The purpose ofthe surface water sampling is to further assess impacts to the unnamed tributary and to make preliminary inferences regarding the extent ofthe TCE plume currently migrating to the southeast across the Ailing Industrial Park by measuring the effects of its discharge to the stream To this end sampling locations have been chosen to 1) provide better spatial resolution in the area east of Commerce Street toward its southern end (SW-1 SW-2 SW-3 and S W-5) 2) assess the quality of surface water contributed by other tributaries (SW-4 SW-6) and 3) make preliminary estimates ofthe downgradient extent of impacts (SW-7 and SW-8) Samples from previously established sampling locations UTrib-6 7 8 1014 and 18 will also be obtained A total of 14 samples will be collected The proposed sampling locations
L-W7jni20iiooonl
MITEC 104e 02432
Michael Smith 2 December 11997
are indicated on the attached maps which depict the site at two different scales The first is a site map taken from the Binkerd report and shows the previous sampling locations east of Commerce Street as well as proposed new locations SW-1 SW-2 and SW-3 The second map shows the site and the surrounding area including the more downstream locations
Methods
At each proposed location a number of water quality indicators will be measured including temperature pH redox potential dissolved oxygen and conductivity Samples for volatile organic compound (VOC) analysis will be obtained in triplicate using a stainless steel sampling container samples will be transferred immediately to 40 mL glass vials with teflon septa and preserved with hydrochloric acid Each sample will be submitted to a local analytical laboratory for a screening level analysis of VOCs Three selected samples will also be analyzed using EPA Method 8260 The appropriate level of documentation will be generated for these samples such that laboratory analytical results can be validated to EPA Region 1 level Tier II This will require the collection and analysis of a duplicate sample a trip blank a field blank and matrix spikematrix spike duplicate samples
Sincerely
f i t mdash Peter ZeebPhD Senior Hydrogeologist
cc Sandy Feldman Sheila Jones
PZmm
m w MITEC 104e 02433
HSI GEOTRANS
LEGEND O Honrtorog Veil
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Figure 11 Station location map O Surface Water
Qfor monitoring wells borings and surface water MITEC 104e
02434
HD BINKERD ENVIRONMENTAL
HSI bull bull
GEOTRANS if prsTAOC
6 Cancaster County Road
A TETRA TECH COMPANY
Harvard Massachusetts 01451 faL32 HMETER 3 4 r t
Sheila Jones Esq Cutler and Stanfield 700 Fourteenth Street NW Washington DC 200052010
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Harvard Massachusetts 01451 GEOTRANS
A T E T R A T E C H C O M P A N Y 978-772-7557 FAX 978-772-6183
PN N753-002
May 111999 RECEIVED
MAY t 3 1999 Mr Michael Smith
CUTLER ampSTANrlc-uAgency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Dear Mike
Based on the site walkover and well inventory ofthe existing monitoring well network completed on April 201999 HSI GeoTrans determined that several monitoring wells proposed for sampling and monitoring in the Work Plan are not accessible or are damaged or missing Outlined below are the actions we will undertake to resolve the outstanding issues with the monitoring well network
As ofthe date of this letter access to the Bates well network has not been obtained The Work Plan identified eleven off property well clusters installed by the Bates and two wells installed by the State on the Bates property to be included in the sampling and monitoring activities for the Site Investigation (BW-2 BW-5 BW-7 BW-8 BW-9 BW-11 BW-12 BWshy13 BW-17 BW-18 BW-19) Ten ofthe off property clusters were included in the sampling plan and all eleven were included in the site water level round The wells installed by the State on the Bates property were included in the both sampling and water level rounds Replacement of eight ofthe well clusters slated for groundwater sampling is recommended (BW-5 BW-8 BW-9 BWshy12 BW-13 BW-17 BW-18 BW-19) The remaining Bates wells do not require replacement in order to achieve the goals ofthe Site Investigation Note that two ofthe original well clusters in the Work Plan BW-17 and BW-18 have been destroyed and would require replacement even if access is granted by Bates In addition HSI GeoTrans well clusters had already been proposed adjacent to BW-2 BW-7 and BW-11 and will provide the required data at these locations
It is our understanding that the two monitoring wells installed by the State on the Bates property JB-1 and JB-2 are accessible to the State for sampling and water level monitoring and that the State will sample and monitor these wells to fulfill the goals ofthe Site Investigation IF this is not the case please let me know at your earliest convenience
M WP DOCS NT^VWMiSimbW wpd
MITEC 104e 02438
Mr Michael Smith 2 May 11 1999
Several ofthe remaining wells (BF-1 BF-3 NO-2 and OE-1) were observed to be damaged during the inspection We propose to repair the wells which have been damaged The repairs will involve installation of protective casing or road boxes re-development and reshysurveying of the new measuring points The other wells are missing and presumed destroyed (ARC-2 ARC-3 BF-2 BM-2 MB-1 PO-SOUTH and RB-1) We believe that only monitoring wells MB-1 and MB-1 A require replacement The remaining wells that could not be located during the site inspection do not require replacement in order to achieve the goals ofthe Site Investigation
Based on our telephone conference on May 10 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MWgt_DOCSN753l9Wlaquo310l600raquopd M l 1 XA ~r
02439
HSI GEOTRANS
Mr Michael Smith 3 May 11 1999
bcc Sheila Jones
snwp_DocjN7sni9wcmoi6i)iraquoplti TVflTEC 1046
02440
HSI GEOTRANS
X_l ^ T 6 Lancaster Countv Road
Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-11 i 5
PN N753-002
June 25 1999
Mr Michael Smith Agency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Work Plan Modifications Ailing Industrial Park Site Williston VT
Dear Mike
This letter documents changes to the work plan for the Ailing Industrial Park Site in accordance with a telephone conference between you myself and Peter Zeeb On the results of the Site Investigation to date as well as additional data collection by the DEC we agreed that several revisions to the work plan are warranted The revisions for the work plan include the location and method of installation for the bedrock monitoring wells and the sampling of shallow monitoring wells recently installed Outlined below are the revisions to the specific tasks that we will undertake
Re-location of Bedrock Monitoring Weil BR-1
The DECs Source Area investigative work in the original location of BR-1 identified high levels (100 mgL) of VOCs present at or near the silt clay interface DEC believes that drilling through the clay layer in this location creates an unacceptable risk ofthe migration of contaminants into the underlying units HSI GeoTrans will relocate the bedrock well BR-1 adjacent to ASI-16 as located on the attached site plan
Bedrock Well Installation Method
Geophysical work at the site has refined our estimation of the depth to bedrock Depth to bedrock was initially anticipated to be greater than 150 feet below ground surface We currently anticipate bedrock at 100 to 140 feet below ground surface The shallower depth to Bedrock will
M AWPDOCStfnSIMnWUJIIW mft
MITEC 104e 02441
Mr Michael Smith 2 June 25 1999
enable us to reduce the size ofthe pilot hole needed for the well installation At locations BR-1 and BR-2 drillers will advance and set 4 in casing several feet into the clay unit and chop and wash the annulus ofthe casing All cuttings and wash water will be contained for proper disposal The casing will be refilled with potable water and the hole will be advanced with a 3 in roller bit When telescoping becomes necessary to prevent caving 3 in casing will be installed The 3 in casing will be advanced to the bedrock surface and seated The coring of bedrock will follow the original work plan specifications
Shallow Monitoring Well Sampling
The field GC water quality data obtained during small diameter installation at the site has demonstrated that contaminant concentrations in the upper portion ofthe aquifer to be low (lt 10 MgL) or non-detect in most locations This has led to the revision of our sampling plan Select shallow wells will be sampled to confirm the field GC data If these data are confirmed the low level and none detect shallow wells will not be sampled The shallow wells to be used for confirmation sampling are listed below
ASI-01 ASI-02 ASI-03 ASI-05 ASI-08 ASI-10 ASM 2 ASI-08
Based on our telephone conference on June 24 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MXTECl04e 02442
HSI GEOTRANS
Mr Michael Smith 3 June 25 1999
bcc Sheila Jones
MITEC I04e
02443
HSI GEOTRANS
1 0 T 2 shyCylty
T-TCT 6 Lancaster County Road _ _ _ Harvard Massachusetts
GEOTRANS OH 5 1
A TETRA TECH COMPANY 978-772-7557 FAX 978-772-6183
PN 753-010
July 9 1999
Mr Michael Smith Agency of Natural Resources Vermont Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Bedrock Monitoring Well Installation Ailing Industrial Park Site Williston VT
Dear Michael
On July 8 we became aware that a drill casing was advanced through the sand clay and till strata at the Ailing Industrial Park (site) without being sealed at the sandclay interface Although for the reasons described below we do not believe any vertical migration of contaminates occurred this method of drilling is contrary to the work plan for the site Therefore we are notifying you of this incident
On June 4 shallow direct push monitoring wells were installed at location ASI-06 where a deeper bedrock monitoring well is planned Groundwater quality profiling data from this location is provided on the attached boring log TCE is present in groundwater here at concentrations as high as 2270 ugl at 31 - 36 ft below ground surface (bgs) decreasing to 262 ugL at 41 - 44 ft bgs A soil boring (D-2) was advanced at this location on June 22 Field screening data from soil samples obtained in this boring are also provided on the attached log As apparent from the log fine to medium sand occurs to a depth of approximately 15 ft at this location grading to silt at depth A clay layer is encountered at 40 ft bgs Glacial till is present from 57 to 100 ft bgs where the bedrock surface is located Prior to drilling through the clay and glacial till a direct push well screen was advanced through the clay and into the till to a depth of 58 bgs and no groundwater recharge to the well screen occurred at any of five sampling depths
MWP_DOCSN753 199M7M1600 wpd
MITEC 104e 02444
Mr Michael Smith 2 July 9 1999
Drilling of bedrock monitoring well BR-2 began on June 29 Four inch casing was advanced to a depth of 44 ft and sealed within the clay layer Three inch casing was then advanced through the till layer to the bedrock surface During seating ofthe casing in the bedrock the casing was damaged and was subsequently withdrawn from the borehole
On July 7 a different drill rig was used to continue drilling the same location In accordance with both the drillers proposal to HSI GeoTrans and the work plan for the site investigation the driller was to seat a casing in the clay establish a seal and drill through the clay and till with smaller casing prior to coring bedrock Instead the drilling contractor withdrew the previously installed four inch casing without grouting it changed the drive shoe on the casing to a spin shoe and advanced the four inch casing directly to the bedrock surface Upon arrival at the site to log the coring of bedrock on July 8 HSI GeoTrans ascertained that the borehole had not been sealed at the clay surface prior to drilling deeper as was specified HSI GeoTrans then instructed the drilling contractor to immediately remove the casing and to seal the borehole with grout in the process
It is our intention to have a new drilling contractor complete the installation of BR-2 at an adjacent location in a manner that limits the potential for introducing contaminated unconsolidated deposits groundwater to the bedrock as specified in the work plan for this site investigation Within one week of completing the installation of BR-2 groundwater quality data collected from BR-2 will be evaluated with respect to the potential for contaminant migration along the unsealed borehole that existed at this location for approximately 24 hours As the casing was advanced by spinning providing a relatively good seal between the casing wall and the formation we do not anticipate that vertical migration along the casing was significant
If you have any questions regarding this letter please contact me at (978) 772-7557
Sincerely yours
Peter Zeeb PhD Senior Hydrogeologist
PZcas
MWP OOCSVN7S3M999070ll600wpri
MITEC 104e 02445
HSI GEOTRANS
1 HSI | 9pound9TPpoundSpound SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
LOCATION Williston VT CASING TYPEDIAMETER None
DRILUNG METHOD Drive and Wash Direct Push SCREEN TYPESLOT None
SAMPLING METHOD ss shelbv GRAVEL PACK TYPE None
GROUND ELEVATION GROUT TYPEQUANTITY Bentonite Portland Slurry
TOP OF CASING DEPTH TO WATER
LOGGED BY NSB GROUND WATER ELEVATION
REMARKS This log compiles the results o the all methods used to comolete the borehole over its entire depth
gtshyci IT UJ t o UJ E t shygt z L oi lti LITHOLOGIC DESCRIPTION 3Q O bdquo a UJ lt a ca sect 1a UJ
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Light olive Brown SILT w trace fine sand wet poorly - 1 5 shy graded
O2-SS02 4 7 11 8
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- 2 0 shy Dark greenish Grey SILT wet poorly graded
O2-SS03 2 0 41 1
WOR WOR l
D2-SS04 2 4 2 X - 2 5 shy4
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WOR AWOR WOR - 3 0 shyD2-SS06 4 921 WOR
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02-SS07 8 2270 1
X1 2 3
Continued Next Page 1 OF 3 02446
HSI GEOTRANS SOIL BORING LOG BR-02 A T E T R A T E C H C O M P A N Y
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
9 gtshyOC
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UJ gt o ^ r-6 LITHOLOGIC DESCRIPTION
ui
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Medium Grey dayey SILT wet poorly graded
D2-SS09 4 S
28 1572
3 6
D2-SS10 WOR 1 18 13
4 6
D2-SS11 3 3 20 NO Medium Grey CLAY wet poorly graded 262
4 5
BR2-SS01 1 2 20 ND Soft Olive Grey CLAY moist laminated coheisive 2 4
BR2-SS02 20 NO
- 5 0 -
BR2-SS03 20 NO - 5 5 -
Dense Light olive Grey sandy GRAVEL w few fines
BR2-SS04 16 19 24
ND
bull60
moist poorly graded
21
Very dense Light olive Grey gravelly SAND w little fines moist well graded angular
BR2-SS05 40 51
13 ND 6 5 shy
60 66
I-7 0 shySO BR2-SS06 11 ND 50 100
5000
MITEC 104e 02447
Continued Next Page PAGE 2 OF 3
HSI GEOTRANS A T E T R A T E C H C O M P A N Y SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
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BR2-SS10 89 1944
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MITEC 104e 02448
PAGE 3 OF 3
Mr Michael Smith 3 July 9 1999
bcc Sheila Jones bcc Jerry Amman
MWPJXXSN753M9MW70J160Owpd
MITEC 104e 02449
6 Lancaster Countv Road HSI Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6 I i 5
PN N753-014
Septembers 1999
Mr Michael Smith Agency of Natural Resource Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in die Site Investigation Ailing Industrial Park Williston IT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and die Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation ore outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste waler lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot IV-11 using small-diameter wells and afield GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
bull perform one day ofwellpoint permeability testing at selected monitoring wells
mwFDocwsiMwwwnoootd MITEC 104e 02450
Mr Michael Smith September 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
M l T ECl04e 02451
U laquo OOCTN791Mtm01IOOOraquofrl
HSI GEOTRANS
HSI GEOTRANS
6 Lancaster County Road Harvard Massachusetts
01451
A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6183
PNN753-014
Septembers 1999 amp y gt
Mr Michael Smith D oJ Agency of Natural Resource Km Jt Department of Environmental Conservation i j f i l Waste Management Division ft y^y( 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park ft Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and the Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation are outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
bull perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste water lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot 19-11 using small-diameter wells and a field GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
MITEC 104e perform one day ofwellpoint permeability testing at selected monitoring wells 02452
000060 MlWP_OOCSN73Iirmraquo01|rngtlaquo|gtl
Mr Michael Smith Septembers 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
MITEC 104e 02453
000061 Mwr_cocS4miinmogtmoltsri
HSI GEOTRANS
T T Q T 6 Lancaster County Road ^ Harvard Massachusetts
GEOTRANS laquolaquo A TETRA TECH-COMPANY 978-772-7557 FAX 978-772-6183
PNN753-014
October 151999
Mr Michael Smith vZ Agency of Natural Resource J Department of Environmental Conservation Waste Management Division I 103 South Main StreetWest Building j Waterbury VT 05671-0404
Re Ailing Industrial Park Source Area Investigation
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants Evaluation of field data has determined the extent ofthe dissolved phase contamination migrating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) HSI GeoTrans will begin a Source Area Investigation on October 181999 to determine the nature and areal extent ofthe suspected contaminant source The investigation will be undertaken to gather the data necessary to complete the Site Investigation Report and the Feasibility Study which was set forth by the Agreement Between Mitec Telecom INC and Vermont Concerning the Ailing Industrial Park (1999) The Source Investigation will focus on the property owned by Beatrice Ailing and former MITEC lease hold (Lot 19-11 Williston plat map) and the area ofthe Ailing Industrial Park which has exhibited elevated contaminant concentrations during Site Investigation activities We are submitting this letter to The Vermont Department of Conservation(VTDEC) as an addendum to the approved Site Investigation Work Plan The addendum Source Investigation Work Plan will outline the tasks and methodologies to be utilized during the investigative work
Jack Guswa and I met with you on September 101999 to present the plans to investigate the suspected source area in the Ailing Industrial Park You agreed with the additional work as presented with the addition of two upgradient wells to be located to the west ofthe suspected source area (Figurel-1 ASI-30 and ASI-31) The VTDEC also agreed during the meeting to arrange access to the property for the Source Area Investigation The VTDEC and HSI GeoTrans were subsequently granted access to the property on September 111999 In addition to the work presented at the meeting it is necessary to preform a 72 hour pump test to characterize the
000054 MwrDOCSW79JimMOUIIOOpd
MITEC 104e 02454
Mr Michael Smith 2 October 151999
hydrologic conditions at the site The additional Source Area Investigation activities to be undertaken are presented below
Site Reconnaissance Ground Penetrating Radar (GPR) Survey Monitoring Well and Soil Boring Installation Low Flow Groundwater Sampling Hydraulic Characterization
The additional field work attributed to the Source Area Investigation will follow the standard operating procedures presented in the approved Site Investigation Work Plan (HSI GeoTrans 1999) The locations ofthe proposed well cluster installations and GPR survey are presented on Figure 1-1 The well cluster locations presented in Figure 1-1 were finalized during the September meeting between HSI GeoTrans and the VTDEC The GPR survey and hydraulic characterization tasks are presented below The Source Area Investigation field work will be completed within two week after its initiation The task specific outlines are presented below
Site Reconnaissance
The monitoring wells to be included in the site reconnaissance are monitoring wells MI-1 MI-2 MI-6 and RB-2 The monitoring wells on Lot 19-11 will be surveyed to a common datum with the existing site wide survey data Well integrity testing consisting of depth to bottom water level and visual inspection ofthe wells will be preformed Groundwater samples will be collected from selected monitoring wells based on the integrity testing Samples will be collected by the Low Flow Protocol set forth in the Site Investigation Work Plan (HSI GeoTrans 1999)
GPR Survey
A GPR survey will be preformed to identify on-site leach field septic tank or cesspool location remnants of waste water lagoon and any other subsurface anomalies We propose to use a 5 foot by 5 foot orthogonal grid survey to detect any near surface anomalies which exist on Lot 19-11 Geophysics GPR International will be performing the survey and will be utilizing a GSSI SR10 ground penetrating radar system with a high resolution 500 MHz antenna and a deep-penetration 100 MHZ antenna Any GPR response which indicate buried metal objects will be investigated with a Fisher TW6 pipe locator to augment the radar data All data will be analyzed in the field by GPR personnel and presented to HSI GeoTrans field personnel to determine the optimal location for well cluster ASI-28 If several anomalies are detected the VTDEC and HSI GeoTrans will evaluate the anomalies and modify the work plan accordingly
Well Installation and Soil Boring Advancement MITEC 104e 02455
The well clustes will consist of a small diameter shallow monitoring well and a deeper conventional well screened across the zone of highest concentration Well cluster installation will be performed in accordance with the Site Investigation Work Plan (HSI GeoTrans 1999) yjth 0 0 5 5
MWP_DOCSK731IW9M OOSIIOOprl
HSI GEOTRANS
Mr Michael Smith 3 October 151999
the exception ofthe deep wells The site conditions observed during previous field work prohibit the use of standard commercially available screen slot sizes The deep wells will be advanced by a large diameter Geoprobereg rod and installed using an outer filter sock to prohibit the infiltration offine sediments in to the well The well cluster installations will be performed jointly by Checkpoint Environmental and Twin State Environmental HSI GeoTrans will be provide oversite ofthe contractors and analysis of groundwater samples using afield Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999) The rationale for the selected well cluster locations is presented below
Monitoring well clusters ASI-25 through ASI-27 are located down gradient ofthe suspected source area The well clusters will be installed to more adequately define the areal extent ofthe concentrated portion ofthe contaminant plume A single soil boring will be advanced at location ASI-26 The soil boring will be screened as it is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-28 will be located after the GPR survey has been completed shyThe cluster will help define the suspected source area and the vertical migration of contaminants in the area The location will be determined in thefield after review ofthe GPR survey is completed The location will be based on any anomalies observed in the GPR data A single soil boring will be advanced at location ASI-28 The soil will be screened with a Flame Ionization Detector as the soil boring is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-29 will be located upgradient ofthe suspected source area The cluster will define the upgradient boundary andor any additional upgradient source areas The ASI-29 well will be paired with the existing shallow monitoring well AL-14
Monitoring well clusters ASI-30 and ASI-31 will be installed to the west cross gradient from the suspected source area to document the areal distribution of dissolved phase contamination emanatingfrom the Ailing Industrial Park The locations selected for these wells should define the northwestern and western extent of contamination
Low Flow Sampling
The additional monitoring well clusters will be sampled in accordance with the approved Site Investigation Work Plan (HSI GeoTrans 1999) Lowflow sampling procedures will be used to sample the newly installed deep wells in their respective clusters ASI-25 through ASI-31
MITEC 104e 02456
000056 MWP_DOCSgtK15JlWMOWllltraquoraquoprl
HSI GEOTRANS
Mr Michael Smith 4 October 151999
Hydraulic Characterization
HSI GeoTrans will conduct a 72 hour pumping test on the deep well at cluster ASM 2 The test is being undertaken to more adequately characterize hydraulic conditions at the site The data from this test will be used in the evaluation of remedial alternatives in the Feasibility Study The pump test will be performed as a step-drawdown test The pumping rates will ultimately be determined in the field from observed conditions Preliminary calculations indicate that pumping rates of 2 5 and 10 gallons per minute will be necessary to achieve the desired drawdown at observation wells The water level data will be recorded at observation wells ASI-06 ASI-13 ASI-25 ASI-26 NO-1 NO-2 and NO-3 The water level data will be recorded using pressure transducers and dataloggers
The effluent water from the pumping test will be treated by liquid phase granular activated carbon filters provided by Carbtrol Inc Two 175 pound carbon filters will be connected in series to treat the pump test effluent The effluent will be discharged to the unnamed brook upon approval from Randy Bean ofthe VTDEC The effluent will be periodically sampled between the carbon units and at the discharge point to detect break through ofthe carbon units The effluent samples will be analyzed utilizing a field Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999)) If the effluent sample between the carbon canisters exceeds 1000 ugL Trichloroethene (TCE) the discharge point sample will be analyzed If concentration of TCE in the discharge point sample exceed 300 ugl the test will be discontinued
We hope that this letter addendum to the Site Investigation Work Plan for the Source Investigation is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJmm MITEC I04e
02457
000057 MWFDOCSN731imu00SI 100 bullpd
HSI GEOTRANS
JHSTUART March 1 1985
Agency of Environmental Conservation D e partment of Water Resources und
E nvironmental Engineering H a z a r d o u s Materials Management Program A t t n John A m i d o n H y d r o g e o l o g i s t M o n t p e l i e r Vermont 05602
R e M I T E C Systems Corp W i l liston
Dear J o h n
During our meeting at MITEC on February 20th you noted that some additional information was needed to c omplete the initial phase of testing as well as the d o c umentation of the activities under takentodate Outline d~ beTow-Ts ~t h e~1 n f o r m a ti o n t h a t y o u r e q u e s t shyed
1 Attac hed here to is the plan used to install the grou ndwat er moni t o r s collection and analysis of the grou ndwa t er samp les for metals and organics and the extr actio n of and testing of soils from the area of the dispo sal site 2 A rev ised sit e pla n has been incl uded refl ecting the new well posi tions and the e leva t ions of t he top of t he mo ni to r s and th e groundwa ter 1e vels as of F e shybr ua ry 0th As note d in our m ost r ecent tel ephone conv i on th e lat ter have r isen 14-15 inc hes as er sa t the It o f th e rec ent thaw Two copie s of the resu plan be f orw ar ded to Winslo w Lad ue as req uested will and pla ns t 0 sur vey all ho uses on Br owne 11 Rd MITEC _tp tain if there are ajiy shallo w wel I sources ltis ce r with e dr aina ge ar ea a f fecte d by the 1agoo n in th 3 ngla nd Ma r ine C o m r a c t o r has been con tacted New E for remo va 1 of th e lagoon soil a nd co ntra c tural the ar ra nts wil 1 be concluded du r ing t he comi ng ngeme week if ic at io n of work comme nceme nt wi II be proshy Not vide your off ice i n advance d to t m Resul t s of th e met als and or genies are expected shor tiy
f rom IEA and will be fo rwarded to your ofshyf ice oon as a va i la ble as s 5 R esul t
s fr om t he pr e vious soi 1 and water sampling have inc 1 ude d bee n
CIVIL 4 EfViROUMEI-L pound l j i t fcHpound P ) OGA lt i f r l h r l h w i l l n-- i i U - iO l i l ) bU i l I
MITEC 104e 02458
s
MITEC Page 2 March 1 1985
If you have any questions please do not hesitate to contact me
Stuart PE
JHSocc
MITEC 104e 02459
MITEC Systems Corporation Williston Vermont
Soil and Water Sampling Program
1 Install groundwater monitors at nine (9) locashytions consisting of two (2) inch inside diameter PJpound with ten (10) feet of factory slotted pipe extending into the groundwater and terminating with a minimum of two (2) feet above ground level and capped
2 Establish elevations of the groundwater monitors for the top of each pipe and the groundwater elevashytion for each for a specific date Due to the shalshylow depth to groundwater from 51-112 inches the level is established by graduated tape and a light Each measurement will be performed a minimum of three times to assure accuracy to within one-eighth inch The location of each well and the established elevations will be represented on a general site plan showing the MITEC property
3 Groundwater samples are to be collected from each well on the same date by pump or baling Prior to - k ~ -~-|1bdquo--bdquobdquo f bdquo k bdquobdquobdquobdquobullbdquo ltv~ 11 1 1 v bdquo bdquo bdquo
acidification for metals preservation to assure ac curacy of the test results All samples are to be analyzed for copper cadmium nickel cyanide pH conductivity total chromium and hexavalent chrome
U Soil samples are to be collected as follows
GWM09 Saturated zone (aaprox 5) Overburden East side lagoon Composite from
two holes 5 apart-at-1 bullbull2 bullbull A below the-sur=mdash face and one in the saturated zone
North wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface 1 into the saturated zone
South wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface I1 into the saturated zone
Bottom of lagoon Composite offour test holes 8 apart one in the unsaturated zone
MITEC 104e 02460
MITEC Sampling Program
All samples are to be analyzed for the same constituents as required of the water testing
5 Collect separate samples of the groundwater after the above referenced purging process for storage in air-tight vials The samples which are to be colshylected from wells A-9 with only 5 and 7 analyzed initially by the GCMS- EPA method 62A If organics are detected in the first samples testing must be performed on 4 and 8 as well
6 All sampling will be performed with a State repshyresentative on-site and results of the testing to be forwarded to the State as soon as available
7 The contaminated soil within the lagoon will be removed by a Vermont certified contractor for disposhysal in an approved wastedepository The top one (1) foot of soil from the flood level and below will be extracted during the process
MITEC 104e 02461
i
o H
ON f J
o
bull I I bull
HA
OOO
x x z
bull
MITEC 104e 02463
WK miui w ci ivnui II i ici ILUI ujiyitb inc iii PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5108
ANALYSIS REPORT
Customer j H S c u a r t Associates Date 26 February 1985
Address P gt 0 gt B o x 3 6 7 Date Samples Received
Ci ty S t a t e Zip Essex Center VT 05A15 20 February^1985
Customer Order Nomber
Attent ion J o h n S t u a r t
Station 9
J
2
3
A
5
6
7
8
9
poundH
5A
58
52
5A
A5
53
53
55
59
j MITEC
Conductivity U mbos ( 25degC)
206
A18
21A
176__
208
230
205
16A
265
GROUNDWATER ANALYSIS
O01 0 OS bull
Cadmium Total Chromium (mRl) (mRl)
0A1 lt0025
006- 270
00A 012
bull005 189
005 023
001 lt0025
lt0C Hexavalent Chromium (mKI)
bull
lt0025
239
005
183
lt0025
lt0025
ampo
Zinc (mKl)
005
0A0
032
015
OU
003
Note Organic analyses to follow in two weeks
cc John Amadon
Signature jJfcrryyS 7lrifrylC
Offices ond loborotones located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02464
if jsznoi U hnvironmentol jiolysts Inc PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5138
ANALYSIS REPORT
Customer J H Stuart Associates Date 21 December 1984
Address PO Box 367 Date Samples Received 14 December 1984
City State Zip Essex Center VT 05451 Customer Order Number
Attention John Stuart
WATER ANALYSIS
PH 52 57 50 53 45 34
Conductivity (pmhos 25degC) 213 420 152 167 202 bull 225
O l Cadmium (mgl) lt001 lt001 001 v 028 bull 005 003
o pound Chromium Total (ng1) lt0025 lt0025 lt0025 lt0025 2-35 v 014 - -bullbull - bull - -bull V 013 bull^Chromium Hexavalent (mgl)1 0 11
gt1p Copper (mgl) lt002 lt002 lt002 lt002 bull 084 004
Q Cyanide (mgl) lt0005 lt0005 lt0005 lt0005 bull -lt0005 lt000E
Z Nickel (mgl) lt0025 lt0025 lt0025 lt0025 bull 010 003
fO 2inc (mgl) 0J1 UU1 0U3 001 038 030
Hexavalent chromium was only analyzed when total chromium was present
Signature fmnigt Mji fnt f VncL 7
Offices and laboratories located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02465
bull i
ANALYSIS REPORT
Customer J H Stuart Associates Date 22 January 1985
Address PO Box 367 Date Samples Received 14 December 1984
Ci ty State Zip Essex Center VT 05415 Customer Order Number
Attent ion John Stuart
bull shy
bull bull mdash bull bull bull bull bull - bull bull bull bull shy SOIL ANALYSIS1
Hexavalent Cyanide Chromium Chromium Cadmium Copper Nickel Zinc
poundH bull (mgl) (mgl) (mq1) bull (mq1) (mq1) (mgl) (bullmgl) -
2 442 lt0005 lt0025 lt0025 lt 001 lt 002 015 006
4 402 lt0005 lt0025 lt0025 lt 001 lt 002 lt002 001
7 504 lt0005 lt0025 lt0025 lt001 lt002 lt002 001
8 486 lt0005 lt0025 lt0025 lt001 lt002 lt002 bull 008
9 441 lt0005 lt0025 lt0025 lt001 lt602 lt002 004
10 444 0005 lt0025 lt0025 lt001 lt002 lt002 006
11 498 lt0005 lt0025 lt0025 lt001 003 lt002 009
30 532 lt0005 lt0025 008 lt001 005 lt002 010
31 544 lt0005 lt0025 lt0025 lt001 002 056 003
32 472 lt0005 lt0025 lt0025 lt001 lt002 024 003
36 536 0008 lt0025 011 lt001 005 lt002 011
37 490 lt0005 lt0025 lt0025 lt001 021 lt002 009
38 391 lt0005 0276 032 lt001 050 lt002 011
41 416 lt0005 0108 018 001 229 lt002 o5i
42 395 lt0005 0399 041 lt001 039 lt002 014
i
Signature Ltrf(7( ni W0 6M Analysis of EP toxicity extract
Offices ond loborotoriei locoted in Essex Junction Vermont Reseorch Triongle Pork North Corolino
MITEC 104e 02466
JHSTUART
A p r i l 2 9 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Hazardous Waste Materials Program Attn Cedric Sanborn Environmental Engineer Montpelier Vermont 05602
Re Mitec Systems Williston
Dear Cedric
I was phoned by David Gee today and informed that a truckload of the contaminated material was removed from the lagoon area as the result of a previous commitment entered into by Mitec Due to conflicting information about Mitecs responsibilities at this juncture I am recommending that any further work cease until a realistic program be agreed to by both parties I base that on the following
1 Following the trial pre-hearing the State was inshystructed to contact Mitec to develop a schedule for further dialogue and actions connected with the reshyhabilitation of the lagoon site To my knowledge there has not been any such attempt made on the part of the State to resolve issues that need clarificashytion
2 On April 18th I forwarded a letter to you outlinshying some new information with recommendations That correspondence has not been addressed yet Mitec has been ordered to continue with the soil removal
3 A letter from John Amadon on April 23rd notes the organic sampling to be invalid due to the time lapse and the method of storing the samples We do not take issue with this position however there is apshyparently some question about the validity of the GCMS method of analysis We have been instructed to re-sample but now there is a question about whether we should employ GC or GCMS
A On numerous occasions we have expressed the deshysire to tailor the soil removal process to a minimum
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 3C7 ESSEX CTR VERMONT 05451 TELEPHONE 802 876 bull 5171
MITEC 104e 02467
L
Mitec Page 2 April 29 1985
2- bull number of truckloads as they are projected to cost about $4000 for each load Mitec being in a startshyup phase of their operation cannot approach this operation with a blank check Chris Stone who was on hand today to represent the State indicated that many more loads may be necessary to effectively rid the site of contamination
Too many questions surround this project for my clishyent to understand his responsibilities and ultimate costs The requirements issued by your office either in writing or verbally on-site have changed repeatshyedly and unless we can mutually agree to a reasonshyable program that is connrifpH rnmdashyr r i ng Mitec has no other option but to let the court decide the isshysue
Again keep in mind there are questions that we feel must be resolved in order to reach a satisfactory conclusion
1 Provided that all Browneil Road houses are connected to the CWD system and thereby reshymoved from any threat of groundwater conshy
- p tamination what level of soil contamination is permissible From this limitation provishyded we concur as to its reasonableness an approximation can be developed as to how many loads of soil must be removed
2 If the soil is to be removed why is it neshyy cessary to conduct organics sampling unless
i t~ i s tne ulterior motive ot the State to direct renovation of the groundwater as well If that is the case the process will now be more expensive than at the outset due to the mobilization of the contaminants
3 If the contaminated soil is to be removed whv is additional groundwater monitoring
pound bull necessary Documentation of the degree of dilution is not considered acceptable
A If organic testing is to be performed y_hich -- method of analysis is to be used
As soon as we can receive a response to the quest-
MITEC 104e 02468
I um laquoi i laquo m mdash n r r j mdash i mdash
Mitec Page 3 April 29 1985
ions at hand then further discussion with the State will dnsue Also please be advised that at the dishyrection of Mitec all future correspondence communishycations requests for information or notification of site vists are to be forwarded to my office We also request that one person in your office be designated to process such information
tuart PE
JHSocc cc Mitec
Robert Cronin Esq
MITEC 104e 02469
jmfMraquoi w i f u m i
A u u raquo laquo F pound raquo laquobull= -
B C f U S t B C INC ENVIRONv i bullbullbull bullbull
5 GREEN MOUNTAIN DRIVE SOUTH BURLINGTON VERMONT 05401 TELEPHONE (802) 658-1074
February 17 1984
I I Mr Cedric Sanborn i
of Environmental Conservationi AgencAgencyy ox ampnvifoiuneniai Lonservdciun I i Dept of Water Resources and
Environmental Engineering Montpelier VT 05602
Dear Mr Sanborn j i
RE Mitec Clean-Up 84011 j
I am writing this letter to inform you of the work that has been completed thus far at Mitec Systems Corp The discharge of i rinsewater into the lagoon has stopped and the rinsewater is being batched and treated at Aquatec as I described in my letter to Stan Corneille dated February 3 1984
Although the chemical reduction and precipatation process works bull bull
very well we have found that the cost for design installation j septic design and installation and permit reviews is far above | Mitecs budget Aquatec has looked at a second alternative for bull the treatment and reduction of rinsewater that being ion exchange J The ion exchange system will be purchased from a vendor and will bull be installed by Aquatec to accomodate Mitecs rinsewater volumes i The rinsewater will be recirculated and will not require any discharge hence there will be no need for subsurface disposal [ permits I will send you specifications on the system and resins j that will be used I
The proposal for the out-door clean up work is enclosed Mr Kucer is currently discussing the cost estimate with his Montreal office I see no reason to intiate this work as soon as I get formal approval from your office and from Mitec
Please feel free to call me if you should have any questions
Sincerely
liytrl Zi [U$) John R Deigo Project Engineer
Enclosure cc Mr Steven Kucer
Hydrographic Studies and Analyses bull Water Quality Studies raquo Analytical Laboratories Ecological Studies bull Aquatic Nuisance Control - Industrial Waste Surveys
MITEC 104e 02472
Recommended Treatment of Rinsewater
Mitec System Corporation
Prepared By
Aquatec Inc
South Burlington Vermont
January 23 1984
MITEC 104e 02473
RE Mitec Groundwater Cleanup - 84011
The treatment of rinsewater will consist of a three stage rinse system with a batch chemical reduction treatment process Parts submersed in chromic acid solutions will be rinsed in a primary rinse bath The primary rinse bath will be a closed system and considered a rough rinse
The secondary rinse bath will also be a closed rinse system The third and final rinse will be a continuous overflow system Effluent from the tertiary system will flow directly into the septic system Tertiary effluent limits must be less than 005 mgl (ppm) before entering an underground septic system
The primary rinse bath will eventually become saturated with chromic acid solutions and require periodic batch treatment When the primary rinse water becomes spent it will be transferred into a 250 gal polyethylene plating tank The rinse water from the secondary rinse bath will be transferred into the primary rinse bath and the secondary bath will be refilled with fresh rinse water
When the tank reaches 80 of its capacity treatment will be initiated The treatment will consist of reducing hexavalent chromium to trivalent chromium by the addition of anhydrous sodium sulfite to a pH of lt2 The amount of sodium sulfite added will depend on the concentration and volume of rinsewater to be treated A portable electric mixer will be attached to the tank to ensure proper mixing The rinsewater in the reduced form will be gravity fed into a second 250 gallon polypropylene plating tank where lime will be added precipatlng out trivalent chromium as well as other heavy metals The mixer should be used to agitate the solution when the lime is added The mixer should be removed and the solids allowed to settle Once the solids have completely settled the treated water will be pumped into the tertiary effluent to allow for further dilution before it is discharged into a septic system
Periodic sampling of effluent waters should be incorporated to ensure that rinsewater discharged does not exceed 005 mgl (ppm)
Sludge will be properly stored and eventually disposed of by a certified hazardous waste carrier
MITEC 104e 02474
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Wildlife and Department of Forests Parks and Recreation Environmental Engineering Department of Water Resources amp Environmental Engineering Natural Resources Conservation Council State Geologist
January 4 1984
3 2ampov~ loo Mr J H Stuart
f i 2 Sm ^
P O Box 3 67 - - l ^ J ^ S M J Essec Center Vt 05451
SUBJECT Mitec Z 0~npJ^
1 o
Dear J o h n
I appreciate your sending me a copy of the recent Mitec water quality results It appears that there remains a detrimenshytal affect of the lagoon on the downgradient groundwater quality This is best demonstrated with the pH and chrome data While it appears that the downgradient well 5 has higher metalic concenshytration then well 6 in the middle of the lagoon I believe the Well 5 results are anamously high due to the turbidity or solids that we saw in the sample In talking with Cathy Cutting of IEA sample 5 was not filtered prior to acid digestion for the AAS analysis ^^
I would suggest that well s 4 5 and 6be resampled and analyzed along with the wells installed on CecT 17 amp 18 We would like to have a representative of our office on site when the sampling is performed so please contact me when a purging and sampling date is set in the near future The groundwater sample from test well 6 that you helped me obtain on December 17 with the teflon bailer was confirmed by our laboratory to contain volatile organics Therefore you must include the volatile orshyganics assay done by JGCMSjas a part of your analysis plan Adshyditionally I would suggest that you review the appropriate protocol for groundwater sampling and obtain the necessary equipshyment A sampling and analysis plan must be submitted for our apshyproval prior to commencing this second round of sampling The plan should be submitted by January 18 1985 with the sampling done within one month of our approval Please feel free to conshytact me with any comments or questions you may have
R f n r mdash i 1 Off ices - BarreEssex J c t P i t t s f o r d N Spr ing f ie ld S t Johnsbury
MITEC 104e 02844
J H Stuart Page 2
I do look forward to reviewing the results of the soils asshysays along with your report outlining the sampling protocol sampling locations data interpretations and projected course of action based on the results
Very truly yours
John F Amadon Hydrogeologist Hazardous Materials Management Program
JFAkp
cc Meredith Wright AG
MITEC 104e 02845
b v
HSTUART ASSOCIATES September 10 1984
Agency of Environmental Conservation Department of Water Resources and Environmental Engineering Air and Solid Waste Programs Attn Cedric Sanborn Air Pollution Control Engineer Montpelier Vermont 05602
Re M I T E C Corporation Williston Vermont
Dear Cedric
As Che result of our conversation on September 7th I am forwarding the information Chat we discussed
The CesCing program format was prepared prior Co our disshycussion and will be altered slightly based on some inforshymation that was collected
A boring was established in the cencer of Che disposal pic and Che wacer Cable as well as che Impeding layer were found to be located at 29 Inches below the surface The shallow depth will allow us co place addicional wells in che area co accuracely depicc Che groundwacer copography
The plan submiCCed herewith provides general information abouc che locaclon of che plane propercy lines and sugshygested positions for Che monitors The final location of che laccer will be decermined in che field once we collect more data on water table elevations
As we are most anxious to proceed with the program your expeditious review and responsewill be most appreciated
SCuart PE
JHSadt
cc David Gee MITEC
CIVIL ENVIRONMENTAL ENGINEERS 120 LAKE STREET BURLINGTON VERMONT 0S401 TELEPHONE 802-8640094
MITEC 104e 02846
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Game and Department of Forests Parks and Recreation
Department of Water Resources amp Environmental Engineering Environmental Engineering Natural Resources Conservation Council
September 19 1984
Mr John H Stuart PE JH Stuart Associates 120 Lake Street Burlington Vermont 05401
RE MITEC Project
Dear Mr Stuart
Chris Stone and I have reviewed the proposed soil sampling and groundwater monitoring plan for Mitec A summary of comments follows
1) The site plan did not show the location of the soil sampling sites Also we felt that additional boringmonitoring sites should be made closer to the facility The map has been re-marked to reflect these additional sites
2) It was not clear as to why the monitoring wells are to be installed 5 feet into the impeding layer However at least one boring should be made into the impeding layer to detershymine its thickness
3) Permeability tests should be performed on at least four of the test holes to determine aquifer characteristics
4) Since the water table is apparently close to the surface we feel that factory slotted pipe would be appropriate for the final monitoring wells
5) All soil1 ft 5 ft
samples 10 ft or
shouldto imp
be eding
takenlayer
at whic
depthshever
of comes
first
MITEC 104e 02847
Mr JH Stuart -2- September 19 1984
6) In addition to the soil sample in the center of the former lagoon four other locations within 2 feet of the edge of the lagoon must be sampled These locations are marked on the enclosed map
7) The State regulations do not address a level below which the metals are no longer hazardous as is done by EPA Toxicity Levels The level of contamination that is acceptable to the State is determined on a case by case basis
8) The analysis for chromium should include both hexavalent and total chromium
If you have any questions regarding our comments do not hesitate to contact us at 828-3395shy
Sincere
Sanborn C h r i s t o p h e r T Stone Environmental Engineer Hydrogeo log i s t Hazardous M a t e r i a l s Hazardous M a t e r i a l s Management Program Management Program
c r s - c t s a d e n c l o s u r e
MITEC 104e 02848
JHSTUART November 9 1984
Agency of Environmencal Conservation Deparcmenc of Wacer Resources and
Environmencal Engineering Hazardous MaCerials Management Program Attn Cedric Sanborn Environmental Engineer Mnotpelier Vermont 05602
Re M I T E C Corporation Williston Vermonc
Dear Cedric
There has been an apparent misunderstanding regarding your letter of September 19 1984 as soil and wacer sampling has been commenced ac che above location A call was placed Co your office on October 30th or 31sc and a message lefc for you indicating that we would begin on November 6ch at 8 AM
In the afternoon of November 6th I telephoned Chris Scone co inform him of our progress On che following morning you notishyfied MITEC that approval to begin had not been granced and chac work musC cease AC chac point we had completed che installashytion of five monitors and had extracted Cwo soil samples from the botcom of che wasce pic
On November 8ch I met with you and Chris to oucline che reshysulCs from our effores I was informed Chat we may have to inshystall one or Cwo additional monitors and Chac all future work muse be performed wich an Agency represenCacive in accendance
LaCe that afternoon Gerry Adams phoned Co notify me chat on short notice he was leaving to begin a large contract in rUasashychusetts and that it was unlikely that he would be back in the area for an extended period Had we been permitted to continue ttith our work on the 7th his portion of the project vould have been concluded
Enclosed you will find an updated version of the site plan orishyginally submitced wich my leCCer of Sepcember lOch A new plan will be developed buc Chis drawing will serve the purpose of locating existing and proposed wells
Whereas I am now withouc a drilling concracCor I would like chu
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05461 TELEPHONE 802 878 5171
MITEC 104e 02849
M I T E C Page 2 November 9 1984
authorization to determine groundwater elevations by auger and then establish one more monitor in a location agreed to by all che parcles I feel chac we have developed sufficient information co date to proceed in this manner
Furcher since Adams will noc be available I would also like Co extract che remaining soil samples wich a bucket auger IC can demonstrated chac che sample collected in chls manner will provide a good represencacion of che soil ac che level desired in Che profile
We are prepared co conclude chls phase of che sice evaluacion Samples from Che groundwacer monitors can be secured in a few days and I would like co follow wich che soil samples using che method described above
Please contact me at 878-5171 if you need additional informashytion
H Stuart PE
JHSadt
cc David Gee MITEC
MITEC 104e 02850
JHSTUART December 19 1984
M I T E C Corporation AtCn David Gee Manager IS Commerce Way Wllliscon Vermonc 05495
Dear David
Under Che Cerms of our agreemenc daced 10584 I wish Co proshyvide you wish an up-daCe of the project status
At the completion of 1219 we will have completed Items 1-4 as specified in the agreement specifically the soils sampling and initial set of water samples will have been collected and submitted for analysis As of chls momenC we still do not know the extent of the problem but will have a better indication once the test results are available in about a week My feelshying Is chac the problem is noc severe
We have compleCed all wells as prescribed however Che State is opting for an additional well Although the contract provides for only six the costs to date are below my target and it does not appear Chac any exCra will be necessary provided ChaC che driller concludes his work coday
The only work remaining afCer chls dace will be che collecCion of che second baCch of waCer samples and discussions wich Che State about any remedial action if necessary
Feel free to contacC me if you have any quescions
Regards
John H Stuart PE
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 878 bull 5171
MITEC 104e 02851
JHSTUART
M I T E C Corporation December 20 1984 ACCn David Gee Manager 15 Commerce Way Willaton VT 05495
Dear David
During our investigations yesterday Che work was completed on the additional monitor well as invoiced as well as drilling to the impeding layer The State decided however that two addishytional wells are required both of which will be Installed toshyday west of the Industrial park boundary line
A major change developed In Che method of testing the soils in the vicinity of the disposal pit that is not covered by our contract Instead of the four peripheral borings and one in Che center of che pic which would have produced flfceen soil samshyples che StaCe representatives decided Co require a different CesC paCCern Chac produced thirty seven samples I have collectshyed all of the samples but have Instructed the Cest lab to hold until authorization Is received Co proceed on Chls change as it Is a subsCanClal cost and will cause Che contract limit to be exceeded
Included is an invoice reflecting the additional wells the cost Co sample the groundwater for those monitors and the additional funds needed to run the soil tests I do not believe that any further surprises are in order
Regards
John H Stuart PE
JHSadt
CIVIL ft ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 06451 TELEPHONE 802 878 5171
MITEC 104e 02852
JHSTUART
December 28 1984
M I T E C Corporation Attn David Gee Manager 15 Commerce Way Williston VT 05495
Dear David
Enclosed are the results from the water quality analyses of the samples submitted to our lab I have noted in the left hand column the allowable limits for each element A copy of this information has been forwarded to John Ami-don per his request
There are several readings that are suspicious according to John The cadmium level in 4 may be an error and Che chromium found in 5 mosc likely Includes che CurbldlCy measured only in ChaC well Both should be resampled to confirm The cadmium and chromium levels in 06 exceed che allowable llmlCs but not excessively so The soil tesCs which have begun will reveal more about the ultimate disshyposition of these elemenCs
On the sewer Issue I spoke wich Frank Ailing again and his plans are Co now develop Che design and receive approval chis wincer for consCrucCion of the required Improvements this spring
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 5171
MITEC 104e 02853
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MITEC 104e 02855
JHSTUART January 28 1985
M I T E C Corporation Attn David Gee Manager 15 Commerce Drive WillistonVermont 05495
Dear David
On January 25th I met with John Amadon and Cedric Sanborn to discuss the contents of my 12385 letshyter The following resulted subject to confirmation by more senior members of the AEC staff
1 The water samples to be collected from wells 45 and 6 are to be checked for cadmium both chromiums and conductivity Wells 1 2 and 3 will be tested for conductivity and pH only
2 Samples will be collected from wells 4-9 for orshyganics but only wells 56 and 9 are to be checked at this time to determine the scope of contaminatshyion
3 The material to be removed from the pit is conshysidered as a hazardous waste and there are not any disposal sites located within Vermont certified to receive it I did obtain a listing of contractors that are approved for handling the material and I will provide this during our next meeting
4 Attached is a copy of the State lab results that address the organics problem
5 Based on the above we will have to amend our ashygreement to include the $1150 additional costs for the testing connected with Items 1 and 2
Call me if you have any questions
John H Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 raquo 878 bull 5171
MITEC 104e 02856
JHSTUART January 30 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Attn John Amadon Hydrogeologist Montpelier Vermont 05602
Re M I T E C
Dear John
I have had several discussions with MITEC relative to our meeting of last Friday In essence they have agreed to the program that you defined but with several provisos
They would like a letter from your office detailing the additional measures to be implemented together wich specific instructions as to what steps must be taken in the process of removing the contaminated soil
Further their acceptance to collect and sample for volatile organics is limited Perchloroethylene as I had indicated is not and has not been used by MITEC The materials stored on the premises as well as the list of suppliers for paints and solvents are available for inspection co corroborate that position MITEC will provide a complete analysis of all organics for the specified wells however fushyture testing for TCE will not be at the expense of MITEC unless its presence can be attributed to their operation
We are prepared to proceed as soon as we receive the requested notification
Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 bull 5171
MITEC 104e 02857
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Page No 1 of - 1 Page PrnpnBal
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J H STUART ASSOCIATES 120 Lake Street
BURLINGTON VERMONT 05401 (802) 864-0094
PROPOSAL SUBMITTED TO PHONE DATE
MITEC Systems Corporation 864-0064 August 7 1984 STREET JOS NAME
15 Commerce Way So i l and groundwater analyses CITT STATE ANO ZIP CODE JOB LOCATION
Wi l l i s ton Vermont 05495 Ai l ing I n d u s t r i a l Park- W i l l i s t o n ARCHITECT DATE Of PLANS JOB PHONE NA NA
We hereby submit specifications and estimates for
Develop a site plan for location of a small waste disposal site to the rear of the manufacturing facility Said- plan to show where groundwater monitors are to be placed together with themethod of construction Further locations will be identified where soil samples are to be extracted for analyses All of the above information will be presented to the Vermont Agency of Environmental Conshyservation for review arid approval of requisitecorrective actionsThe specific functions to be provided are shy
1 Site plan development 2 Establish groundwater monitors in four (4) locations 3 Collect three (3) soil samples for analyses 4 Collect four(4) watersamples on two occasions with the second
batch occurring 90 days later shy5 Coordinate planning discussions and negotiations with the
Agency to remedy potential violations of State statutes and regulations
The above Includes all labor and equipment (backhoe) time needed to accomplish the tasks indicated by the State Not Included are groundwater sampling beyond the second batch of tests additional soil tests beyond the Initial batch and removal of any soil materials that may be found to be contaminated beyond acshyceptable Federal or State standards
MITEC 104e 00348
S f |JrnpDBP hereby to furnish materJaJ-jfl^Oabor mdash complete in accordance with above specifications for the sum MCTf T O c Q B t C T 7 7 0
dollars (J Payment lo be made as follows
Above work to commence by 81684 completed Alt m a t e r i a l Is guaran teed t o pound M a t tpac l fcad Ai l work t o ba e o m p M f d In a w o r k m a n l i k e m i r u M r a c c o r d l n | t o t t a n d a r d p r a c t i c a l Any laquo n laquo f a t laquo A or dev ia t i on r o m abova tpec i f i ca - Authorized ^ f e ^ M ^ t i o n t I n v o M n g ex t ra c o t t s wiU blaquo alaquocu tad on l y u p o n w r i t t en o rde r a n d w in b e c o m e a n Signature shy
e r t r a c h m raquo over a n d above t h a es t ima te Al l agreement i con t i ngen t u p o n t t r t f ca t acc iden ts o r de lays b e y o n d o u r c o n t r o l O w n t r l o ca r r y raquora t o rnado a n d o tha r necessary i nsu rance TJyi proposal may be lo Our worke rs ara fu l l y covered by Worlwnens Compensa t i on Insu rance withdrawn by not accepted wi th in
K t t t p t a n i P flf ^ m p H S a l - T h e above prices specifications Signature and conditions are satisfactory and are hereby accepted You are authorised
CORRECTIVE ACTION FEASIBILITY INVESTIGATION EPA SITE NUMBER VTD-0983 53545 (LOT 19-11)
January 29 2001
GeoX MITEC 104e Fc l I lS Inc A TETRA TECH COMPANY J L J 02269
6 Lancaster County Road Harvard MA 01451 978-772-7557 FAX 978-772-61 83
CORRECTIVE ACTION FEASIBILITY INVESTIGATION EPA SITE NUMBER VTD-098353545 (LOT 19-11)
J - J C T October 5 2000
GEOTRANS A TETRA TECH COMPANY
6 Lancaster County Road Suite Four Harvard Massachusetts 01451 MITEC 104e
02352
CORRECTIVE ACTION FEASIBILITY INVESTIGATION
EPA SITE NUMBER VTD-098353545 (LOT 19-11)
PREPARED FOR
ALLING INDUSTRIAL PARK
PREPARED BY
HSI GEOTRANS INC
6 LANCASTER COUNTY ROAD
HARVARD MASSACHUSETTS 01451
HSI GEOTRANS PROJECT NO N753-016 OCTOBER 52000
HSI GeoTrans inc
MITEC 104e 02353
TABLE OF CONTENTS
PAGE
1 INTRODUCTION 1-1
2 STUDY AREA CONCEPTUAL MODEL 2-1 21 STUDY AREA LOCATION AND DESCRIPTION 2-1
22 STUDY AREA LAND USE 2-1
23 HYDROGEOLOGIC SETTING 2-1
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION 2-3
3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES 3-1 31 IDENTIFICATION OF ARAR S 3-1
32 REMEDIAL ACTION OBJECTIVES 3-1
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES 3-1
322 GROUNDWATER 3-1
323 SURFACE WATER 3-2
324 INDOOR AIR 3-3
33 INITIAL SCREENING 3-3
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES 3-4
4 DETAILED ANALYSIS OF ALTERNATIVES 4-1 41 ALTERNATIVE 1 NO ACTION 4-1
411 SHORT-TERM EFFECTIVENESS 4-1
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-2
413 LONG-TERM EFFECTIVENESS 4-2
414 COMPLIANCE WITH ARARS 4-3
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 4-4
416 IMPLEMENTABILITY 4-4
417 COSTS 4-5
42 ALTERNATIVE 2 MONITORING INSTITUTIONAL CONTROLS AND
HYDRAULIC CONTAINMENT 4-5 421 SHORT-TERM EFFECTIVENESS 4-8
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-9
423 LONG-TERM EFFECTIVENESS 4-9
424 COMPLIANCE WITH ARAR S 4-10
425 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-11
426 IMPLEMENTABILITY 4-11
427 COSTS 4-12
FOR ALLING INDUSTRIAL PARK MWP_DOCSW5J20OTALlIWFS9-00U0030929wro 11 HSI GSOTrflnS IflC
MITEC 104e 02354
TABLE OF CONTENTS (CONTINUED)
PAGE
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS
AND PERMEABLE REACTIVE BARRIER 4-13
431 SHORT-TERM EFFECTIVENESS 4-15
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-16
433 LONG-TERM EFFECTIVENESS 4-17
434 COMPLIANCE WITH ARARs 4-18 435 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-18
436 IMPLEMENTABILITY 4-19
437 COSTS 4-20
44 ALTERNATIVE 4 MONITORING INSTITUTIONAL CONTROLS
AND NATURAL ATTENUATION 4-20
441 SHORT-TERM EFFECTIVENESS 4-21
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-21
443 LONG-TERM EFFECTIVENESS 4-22
444 COMPLIANCE WITH ARARS 4-23
445 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-23
446 IMPLEMENTABILITY 4-23
447 COSTS 4-24
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION 4-25
451 SHORT-TERM EFFECTIVENESS 4-26
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-27
453 LONG-TERM EFFECTIVENESS 4-27
454 COMPLIANCE WITH ARARS 4-28
455 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-29
456 IMPLEMENTABILITY 4-29
457 COSTS 4-30
FOR ALLING INDUSTRIAL PARK MWPJXgtCSN7532000AUJNOFSlaquo)0I0030929WPD 111 HSI GeOTrSDS ItlC
MITEC 104e 02355
TABLE OF CONTENTS (CONTINUED)
PAGE
5 COMPARATIVE EVALUATION OF ALTERNATIVES 5-1 51 SHORT-TERM EFFECTIVENESS 5-1
52 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT 5 - 3 53 LONG-TERM EFFECTIVENESS 5-4
54 COMPLIANCE WITH ARARS 5-4
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 5-4
56 IMPLEMENTABILITY 5-5
57 COSTS 5-5
6 PREFERRED REMEDY 6-1 61 PREFERRED REMEDY 6-1
62 MONITORING PROGRAM 6-2
REFERENCES 7-1
APPENDIX A TWODAN INPUT FILES
FOR ALLING INDUSTRIAL PARK MWgt_DOCSW7532000WJJNGfS9^)0M00J(raquo9wpo I V H S I G S O T r a H S I n C
MITEC 104e 02356
LIST OF TABLES
PAGE
TABLE 3-1 REMEDIAL ACTION OBJECTIVES 3-7
TABLE 3-2 DESCRIPTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES 3-8
TABLE 3-3 SELECTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES
FOR DETAILED ANALYSIS 3-11
TABLE 41 COST ESTIMATES FOR REMEDIAL ALTERNATIVES 4-31
TABLE 6-1 SAMPLING LOCATIONS 6-5
TABLE 6-2 VOC ANALYTES 6-6
TABLE 6-3 PARAMETERS TO EVALUATE BIODEGRADATION 6-7
FOR ALLING INDUSTRIAL PARK MWP DOCSN7S32000AUJNOFS9-00I0030929 wro HSI GeoTrans inc
MITEC 104e 02357
LIST OF FIGURES
PAGE
FIGURE 1-1 STUDY AREA LOCATION MAP 1-2
FIGURE 1 -2 LATERAL BOUNDARIES OF REGION OF TCE-CONTAMINATED GROUNDWATER 1 -3
FIGURE 4-1 MODELED SITE-EXISTING CONDITIONS 4-33
FIGURE 4-2 MODELED SITE WITH THREE RECOVERY WELLS PUMPING AT 5 GPM 4-34
FIGURE 4-3 MODELED SITE WITH TEN RECOVERY WELLS PUMPING AT 5 GPM 4-35
FIGURE 4-4 ALTERNATIVE 3 PERMEABLE REACTIVE BARRIER 4-36
FIGURE 6-1 PROPOSED MONITORING LOCATIONS 6-8
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUUNOFS9-OOV 10030929 w r o VI HSI GeoTrans inc
MITEC 104e 02358
1 INTRODUCTION
This Corrective Action Feasibility Investigation is submitted on behalf of Mitec Telecom
Inc (Mitec) by HSI GeoTrans The investigation was done to evaluate potential remedial
alternatives for groundwater contaminated by trichloroethylene (TCE) and to a lesser extent
tetrachloroethylene (PCE) and petroleum related compounds (BTEX) at the Ailing Industrial
Park (the Study Area) A recently prepared Site Investigation Report (SIR) (HSI GeoTrans
2000) identified the nature and extent of contaminated groundwater within the Study Area
Figure 1-1 is a map ofthe Study Area and Figure 1-2 is a map that outlines the region of
contaminated groundwater for which potential remedial alternatives were evaluated
The SIR concluded that the TCE contamination was widespread across the Study Area
that residual TCE dense non-aqueous phase liquid (DNAPL) resulting from one or more releases
was a continuing source of contamination to groundwater and that under current conditions the
groundwater contamination does not pose an unacceptable risk to human health and the
environment Current conditions include the continued effective mitigation of indoor air vapors
at the residence at Lot 3-30 no other residences with basements below the water table and no
use of groundwater within the Study Area as a potable supply The SIR also concluded that if
groundwater were to be used as a potable supply a significant health risk would exist as a result
of exposure to groundwater through ingestion dermal contact and inhalation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^X)M0030929WPD 1 - 1 HSI GCOTrdnS ITC
MITEC 104e 02359
I - N -
Former Mitec Hold y
Meters
Explanation
Study Area TITLE
MITEC 104e 02360
Study Area Location Map
LOCATION
Williston Vermont CHECKED MS FIGURE HSI OfVFTED RMK
GEOTRANS RLE f s ~ Expa nd~S(tsdirq 1-1 A T I T M TICK C011irraquoraquoT DATE- 10600 ~
2 STUDY AREA CONCEPTUAL MODEL
The following discussion ofthe Study Area conceptual model is summarized from
information contained in the previously submitted SIR (HSI GeoTrans 2000)
21 STUDY AREA LOCATION AND DESCRIPTION
The Study Area is located at the Ailing Industrial Park and adjacent areas in Chittienden
County Williston VT The VT state plane coordinates for the Study Area are Northing
71210837 (44 27 T north latitude) and Easting 147576375 (73 7 50 west longitude) The
Study area is within the Winooski River watershed and has an elevation ranging from 330 to 350
feet above mean sea level (MSL) The ground surface has little relief and slopes gently to the
southwest A small unnamed brook flows in a southerly direction along the eastern edge of an
industrial park located within the Study Area There is unlimited public pedestrian access to the
Study Area
22 S T U D Y A R E A L A N D U S E
The land in the Study Area is currently zoned for mixed residential commercial and
industrial use The eastern portion ofthe Study area is primarily zoned for commercial use and
the western portion ofthe Study Area is predominantly residential The Study Area includes an
industrial park where there has been light industrial and commercial use since 1946 Three lots
in the industrial park have been previously identified as locations of former manufacturing andor
fabrication operations that resulted in release of contaminants to groundwater (Brinkerd 1996
TRC 1993 Griffin 1995)
23 HYDROGEOLOGIC SETTING
The unconsolidated geologic deposits beneath the Study Area consist of sand silt and
clay which were deposited in the former Champlain Sea overlying till The unconsolidated
deposits occur in four distinct layers The surficial deposits are medium to fine sand which
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000VALUNoFS9^X)10030929wro 2 - 1 H S I G e O T r a f l S J n C
MITEC 104e 02362
generally becomes finer-grained with depth and extend to approximately 20 feet below ground
surface (bgs) Interbedded silts and fine sands are present from approximately 20 to 40 feet bgs
An areally-extensive clay layer underlies the interbedded silt and fine sands at a depth of
approximately 32 to 60 feet bgs Beneath the clay layer is a dense till which extends from about
60 to 100 feet bgs The underlying bedrock is comprised of massive gray limestone gray
dolomite and white marble ofthe Beckman formation This bedrock is of lower Ordovician age
and is part ofthe Hinesburg Synclinorium structure
The aquifer in the Study Area and surrounding regions is primarily the surficial medium
and fine sands although some water is capable of being extracted from the lower silt and fine
sand The residences and businesses within the Study Area are currently serviced by a public
water supply and the aquifer is not used for potable water supply within the Study Area The
hydraulic conductivity ofthe medium to fine sands was determined from a slug test to be about
20 feetday (Johnson 1999) The hydraulic conductivity ofthe interbedded silt and fine sand as
determined from rising and falling head slug tests (HSI GeoTrans 2000) ranged from 1 to 20
ftday with a geometric mean of 38 ftday A pumping test of well NO-1 yielded a hydraulic
conductivity estimate of about 2 to 30 ftday for the combined medium to fine sands and
underlying silt and fine sand There are no hydraulic conductivity data for the underlying clay
and till layers It is believed that the clay and till act as a lower confining layers restricting the
vertical flow of water between the overlying sand and the underlying bedrock
Beneath the Study Area the depth to water generally ranges from 3 to 11 feet below
ground surface In general groundwater flow beneath the Study Area is from the north to the
southeast and southwest There is a groundwater divide in the water table that runs generally
parallel to Commerce Street East ofthe divide groundwater flows toward and discharges to the
unnamed brook West ofthe divide groundwater flows toward Muddy Brook which is located
about 300 meters or 1000 feet west ofthe Study Area Groundwater recharge within the Study
FOR ALLING INDUSTRIAL PARK MAWPJgtOCSN753UOOOWXINOFS9-O0l0030929wro 2-2 HSI GCOTrdnS IDC
MITEC 104e 02363
Area is primarily from infiltration of precipitation Prior to 1986 when a sewer line was
installed groundwater recharge also resulted from discharge to numerous on-site disposal
systems
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION
Figure 1-2 illustrates the 1999 distribution of TCE-contaminated groundwater within the
Study Area The lateral boundaries ofthe region of TCE-contaminated groundwater
approximately represent the lateral boundaries ofthe region of volatile organic compound
(VOC)-contaminated groundwater As discussed in the SIR (HSI GeoTrans 2000) VOCs
present in groundwater include TCE PCE and BTEX The compound detected at the highest
concentrations and over the largest portion ofthe Study Area is TCE PCE is generally detected
in the same area as TCE but at significantly lower concentrations BTEX compounds have been
detected in groundwater primarily in the eastern portion ofthe Study Area and are commingled
with but not coincident with TCE-contaminated groundwater The lateral boundaries shown in
Figure 1-2 approximately represent the lateral extent of groundwater contamination and are not
intended to indicate that all groundwater within those boundaries is contaminated This figure
includes data collected on behalf of Mitec as part ofthe SIR (HSI GeoTrans 2000) and data
collected in 1999 by the Johnson Company (Johnson 1999) Figure 4-2 A ofthe SIR (HSI
GeoTrans 2000) shows all TCE concentration data collected in 1999 as well as some data
collected in 1997 The SIR (HSI GeoTrans 2000) summarized previous investigations that
indicated that at least three properties have contributed to the region of VOC-contaminated
groundwater On Lot 19-11 there were a disposal lagoon and a leach field that resulted in the
release ofthe VOCs TCE and PCE (perhaps as an impurity in the TCE) Lot 19-12 once had
underground storage tanks from which a previous release of BTEX was discovered when the
tanks were removed Lot 19-2 contained a disposal pit and outfall pipe from which TCE was
reportedly released
Figure 1-2 of this report shows in plan view the areal distribution of TCE-contaminated
groundwater Where there were multiple 1999 data values for the same location preference was
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AL1JNOFS9-OOM0030929WPD 2-3 HSI GSOTraHS JHC
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given to samples collected by low-flow sampling done subsequent to well installation In
addition for those locations which had samples from different depths the sample with the
highest concentration was used Figure 1-2 illustrates that TCE-contaminated groundwater is
widespread beneath the Study Area and that the highest TCE concentrations are detected in
groundwater beneath the eastern portion ofthe Study Area The figure illustrates that TCE-
contaminated groundwater in the eastern portion ofthe Study Area discharges to the unnamed
brook No VOCs including TCE have been detected in groundwater samples collected from
wells on the eastern side of the unnamed brook Based on surface water and groundwater data
that have been collected the unnamed brook appears to limit the southeasterly extent ofthe
region of VOC-contaminated groundwater In the western portion ofthe Study Area the lateral
boundaries of contaminated groundwater were identified through vertical profile sampling at
several locations Figure 1-2 shows the location ofthe vertical profiling borings that define the
lateral extent of TCE-contaminated groundwater The SIR (HSI GeoTrans 2000) recommended
periodic sampling and analysis of wells in the western portion ofthe Study Area for the purpose
of determining whether this region of VOC-contaminated groundwater was stable or expanding
in size
While not evident from Figure 1-2 it was determined that throughout the Study Area the
highest TCE concentrations were detected in samples collected from the interbedded siltclay
layer As shown on Figure 4-2A ofthe SIR the higher TCE concentrations were generally
detected at a depth of about 35 feet below ground surface in the eastern portion ofthe Study
Area and at a depth of about 30 feet below ground surface in the western portion ofthe Study
Area It is believed that the current distribution of TCE contamination resulted from DNAPL
releases at one or more locations within the Study Area One such release area was at Lot 19-11
DNAPL migrated downward through the upper medium to coarse sands under the primary
influence of gravitational forces There would have been some lateral displacement along
preferential pathways provided by sloping unconsolidated deposits but the primary flow would
have been downward Upon encountering the more resistive capillary pressure forces associated
with the water-saturated finer-grained geologic units such as the interbedded silts and sands
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which exist beneath the upper medium to coarse sands the DNAPL downward migration would
have stopped The DNAPL would have accumulated on top ofthe capillary pressure barrier layer
and then would have spread laterally following preferential flow paths within the coarser-grained
geologic units above the interbedded silts and sands The amount of lateral spreading of
DNAPL from any release area would have been dependent upon the volume and frequency ofthe
releases As the DNAPL migrated it would have created a region of residual DNAPL This
region of residual DNAPL consists of isolated DNAPL droplets trapped within pore spaces ofthe
unconsolidated deposits The lateral migration ofthe DNAPL would have been affected by the
slope ofthe surface ofthe finer-grained units that halted downward migration ofthe DNAPL
and it would not necessarily have been coincident with the direction of hydraulic gradient or
groundwater flow The region of residual DNAPL is now a continuing source of contamination
to the groundwater which flows past and gradually dissolves the DNAPL The locations ofthe
residual DNAPL zones are not known
There were no direct observations of DNAPL during drilling and well installation but it
is expected that residual DNAPL generally exists within regions of higher concentration detected
in the eastern portion of the Study Area The residual DNAPL is not necessarily continuously
connected within that region Based on the vertical distribution of TCE concentrations it is also
expected that the residual DNAPL exists in a relatively thin zone within the interbedded silt and
clay Limited hydrodynamic dispersion within the interbedded silt and clay has resulted in a
relatively thin zone of relatively high TCE concentrations in groundwater The southeastward
and southwestward divergence of groundwater flow has resulted in a laterally extensive region of
TCE-contaminated groundwater
There has been no indication in any ofthe investigations done within the Study Area
including the SIR (HSI GeoTrans 2000) that there are locations within the Study Area where
DNAPL is present in sufficient volume to be recoverable in the DNAPL phase
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3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES
31 IDENTIFICATION OF ARARS
Two Applicable or Relevant and Appropriate Requirements (ARARs) were identified in
consultation with Mr Mike Smith ofthe Vermont Department of Environmental Conservation
(VTDEC) The first are the Groundwater Enforcement Standards as outlined in Appendix one of
the Chapter 12 Groundwater Protection Rule (VTDEC 1997) These standards apply to
concentrations of contaminants in groundwater in the Study Area (TCE PCE and BTEX) The
second are the Vermont Water Quality Criteria dated March 142000 (VTDEC 2000) which
specify surface water quality criteria and policy
32 REMEDIAL ACTION OBJECTIVES
The remedial action objectives (RAOs) for the Study Area are summarized in Table 3-1
and further described below
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES
One ofthe RAOs for the Study Area is the remediation of source areas Soil excavation
and removal has already occurred at the known release areas Not withstanding the fact that
previous DNAPL releases are suspected no areas of recoverable DNAPL have been detected in
the Study Area Concentrations of TCE in groundwater indicate it is present in some areas as
residual phase below the water table One purpose of this Corrective Action Feasibility
Investigation is to evaluate options for remediating residual DNAPL in the Study Area
322 GROUNDWATER
Attain VT Groundwater Enforcement Standards The ultimate goal of remediation is to
attain Groundwater Enforcement Standards for VOCs in groundwater This is in accordance
with the VT Groundwater Protection Rule and Strategy (VTDEC 1997) which states that If an
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(MUJNOFS9^)OM0030929WPD 3 - 1 HSI GCOTranS IttC
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enforcement standard has been reached or exceeded at a compliance point the goal is to take
appropriate action to retum the groundwater quality to below the enforcement standard if
possible
Prevent Expansion ofthe Dissolved Plume A risk assessment (Menzie Cura 2000a and
2000b) was included as part ofthe SIR (HSI GeoTrans 2000) The risk assessment concluded
that under current conditions concentrations of VOCs dissolved in groundwater in the Study Area
do not pose a risk to human health andor the environment The SIR (HSI GeoTrans 2000) also
indicated that the available monitoring data were not sufficient to determine whether the region
of VOC-contaminated groundwater in the southwestern portion ofthe Study Area was stable in
size or expanding This Corrective Action Feasibility Investigation explores options for
monitoring groundwater quality and preventing the region of VOC-contaminated groundwater
from expanding in size
Prevent Potable Use of Groundwater Within the Dissolved Plume Menzie Cura prepared
a June 1 2000 addendum (Menzie Cura 2000b) to the April 2000 risk assessment (Menzie Cura
2000a) The addendum evaluated risk posed by potable use of groundwater at the site The
addendum found there to be a human health risk associated with the use of groundwater at the
site for potable purposes One RAO of this Corrective Action Feasibility Investigation is to
propose institutional controls so that groundwater within the region of contaminated
groundwater would not be used as a potable supply until concentrations are suitable for such use
323 SURFACE WATER
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
under current conditions VOCs dissolved in surface water in the Study Area do not pose arisk to
human health or the environment Currently however surface water concentrations in the
unnamed brook exceed VT Water Quality Criteria (VTDEC 2000) One ofthe RAOs for the
site will be to meet these surface water quality standards in the unnamed brook
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324 INDOOR AIR
The VTDEC has conducted air sampling at several residences along Kirby Lane and
South Browneil Road The results have indicated the presence of TCE and PCE in indoor air at
some ofthe South Browneil Road residences (Brinkerd 1996) and unacceptable VOC
concentrations in the basement ofthe residence at Lot 3-30 on South Browneil Road The
presence of VOC vapors in the residence on Lot 3-30 is believed to have resulted from
volatilization of groundwater which infiltrated the basement through a continuously operating
sump pump The sump was vented to the exterior ofthe house as part of a state-sponsored
action and the indoor air concentration ofthe contaminants reduced to an acceptable
concentration Therefore one institutional control for the site will be to maintain the sump
venting as long as necessary to prevent health risks due to inhalation of VOC concentrations in
indoor air Also an institutional control in the form of a zoning restriction should be
implemented to prohibit the construction of new buildings with basements below the water table
in the region of contaminated groundwater The restriction should specify that in cases where it
is unavoidable to place the basement below the water table proper containment and venting of
the sump drainage system is required
33 INITIAL SCREENING
Four general categories of remedial technologies were evaluated The first monitoring
may be used alone or in conjunction with other remedies The second category includes
institutional controls to prevent exposure to contamination in groundwater and indoor air
Institutional controls could also be used alone or in conjunction with other remedies The third
category includes source removal technologies
The fourth category includes contaminated groundwater containment technologies such
as a hydraulic barrier or permeable reactive barrier Containment technologies can be applied in
two different ways Thefirst source control application would entail installing the containment
technology directly downgradient ofthe highest dissolved concentrations in an attempt to contain
the contaminated groundwater nearest the source Over time if new contamination is not
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MITEC 104e 02369
allowed to migrate beyond the source VOC concentrations in the downgradient region of
contaminated groundwater should attenuate
The second application would entail installing the containment technology at the
downgradient edge ofthe region of Contaminated groundwater The containment would protect
downgradient receptors from impacts by the region of contaminated groundwater
Both containment technology approaches were considered for use in the event additional
monitoring data shows that the region of VOC-contaminated groundwater is expanding in size
or if VOC concentrations in groundwater discharging to the unnamed brook are increasing
Table 3-2 identifies the remedial technologies considered and summarizes the results ofthe
initial screening for applicability to addressing the ARARs
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES
The list of potentially viable technologies shown in Table 3-2 was subjected to an initial
screening process The purpose ofthe initial screening was to identify those technologies that are
potentially feasible in the Study Area prior to performing a more detailed technology screening
Many ofthe source removal technologies were removed from further consideration because of
the impracticability of remediating residual DNAPL at the site
As described in the SIR (HSI GeoTrans 2000) DNAPL is likely present in the Study
Area Although present DNAPL has not been directly observed in any location and there has
been no indication that there is recoverable DNAPL present The failure to detect DNAPL
directly is not an uncommon situation at DNAPL sites and commonly results from its
heterogeneous distribution or its presence only at residual saturation (US EPA 1992)
Groundwater extraction and treatment is not an effective technology for remediation of residual
DNAPL due to limitations resulting from the limited solubility of most DNAPL compounds and
the heterogeneous distribution ofthe DNAPL (US EPA 1993) Designing remedial strategies
for DNAPL is made difficult by the inability to accurately locate the DNAPL sources This
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inability to locate the DNAPL renders the use of targeted source remedies that might be cost
effective for a small readily definable source area ineffective These targeted source remedies
include excavation air sparging chemical oxidation in-situ thermal desorption and chemical
flushing technologies
Subsurface deposits in the Study Area are heterogeneous due to the interbedded nature of
the sands and silts overlying an areally extensive clay The presence of such heterogeneity
creates extremely variable and unpredictable groundwater flow velocities as well as flow paths
for DNAPL migration The contrast in permeability and porosity between different lithologies
results in the development of preferential flow pathways While preferential flow through coarse
sand and gravel zones provides higher than average groundwater flow rates and contaminant
flushing less preferential flow pathways such as silty sands silts and clays remain poorly
flushed even under forced hydraulic gradients created by extraction wells Contaminants
however may have migrated to these areas of less preferential flow as DNAPLs under
gravitational influence or by diffusion over long periods of time The low permeability zones
even if addressed by localized extraction of groundwater will transmit only small quantities of
water and hence contaminant flushing is slow This is compounded by the low solubility of
DNAPL constituents and the tendency for them to become trapped in soils by capillary pressure
forces
Specific source removal technologies which have been screened out as ineffective at this
stage include air sparging groundwater amendments excavation and in-situ thermal desorption
Low permeability zones prevent the migration of soil vapors or sparged air to the near-surface for
recovery due to the preferential flow caused by heterogenieties it is not possible to determine if
amendments which can be added to the groundwater or chemical flushing compounds which
displace the groundwater and help liberate residual DNAPL such as oxidants alcohol polymers
andor surfactant would reach the DNAPL Excavation which has already been used to remove
impacted surface soils in known release areas is not practical for removing residual DNAPL
deep below the water table The in-situ thermal desorption can be useful in some environments
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MITEC 104e 02371
but can also induce downward DNAPL migration if hydraulic control ofthe system is not
complete Because the location of residual DNAPL is not known and because hydraulic control
ofthe underlying silt clay and till into which the DNAPL may migrate cannot be assured in-situ
thermal desorption is not feasible for this site
Monitoring and institutional controls are included in each option evaluated except for the
no-action alternative These are required to rule out possible future health risks due to expansion
ofthe region of VOC-contaminated groundwater or the creation of new contaminant exposure
pathways
The technologies remaining after the initial screening are presented in Table 3-3
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MITEC 104e 02372
Table 3-1 Remedial action objectives
MEDIA REMEDIAL ACTION OBJECTIVE
Groundwater -Remove or control contaminant sources
bullAttain VT Groundwater Enforcement Standards
-Prevent expansion ofthe region of contaminated groundwater
-Prevent use of groundwater within the region of contaminated groundwater as a
potable water supply where contaminant concentrations exceed federal drinking
water standards
Surface Water -Attain VT Water Quality Criteria
Air -Prevent inhalation of concentrations in indoor air derived from groundwater
FOR ALLING INDUSTRIAL PARK MWP DOCSW7520(XMUJNOFS9^XM0030929WPO 3-7 HSI GeoTrans inc
MITEC 104e 02373
-n Table 3-2 Description of potentially viable remediation technologies o w o
i mi m rshym
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R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Basement Sump Venting
Restriction on new buildings with basements set below the water table
Restrict Potable Use of Groundwater
Excavation
Natural Gradient Flushing
Air Sparging
RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
PROCESS DESCRIPTION OPTIONS
No Action No Action
Monitor groundwater concentrations to confirm that region of VOC-contaminated groundwater is not expanding in size
Monitor surface water concentrations in unnamed brook to ensure concentrations remain below risk levels
Continue to vent the sumps at Lot 3-30 on South Browneil Road
Restrict construction of any new buildings with basements set below the water table within the area of dissolved VOC contamination and require basement sump venting in those where a below water table basement is unavoidable
Place restrictions on potable use of groundwater at properties overlying the region of VOCshy contaminated groundwater
Excavation and removal of soils containing residual DNAPL
Continued dissolution and natural attenuation of residual DNAPL
Injection of air beneath the water table to volatilize residual DNAPL and dissolved concentrations in groundwater
INITIAL SCREENING C O M M E N T
Used as a baseline for comparison No cost Long remediation time
Can be used in conjunction with other response actions Will be required in the southwest portion ofthe region of contaminated groundwater since existing data are inconclusive regarding this issue
Can be used in conjunction with other response actions
Will be required until data show there is no longer a risk to indoor air from groundwater in the basement
Will be required until data show there is no risk of migration of VOCs to indoor air from groundwater
Will be required at all properties in the area of VOC-contaminated groundwater to prevent a risk to human health
Has been used at the site to remove residual DNAPL in soils in the release areas Impractical to recover residual DNAPL at depth The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Intermediate cost Short time frame to cleanup if all residual source can be removed
Higher permeability zones are preferentially remediated On-going monitoring required No installation or on-going maintenance costs Long time frame to cleanup
Small-scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Intermediate installation and high on-going maintenance costs
MITEC 104e 02374
5 T l O Description of potentially viable remediation technologies (continued) PO
Table 3-2 O
RESPONSE REMEDIAL PROCESS g 5 ACTION TECHNOLOGY OPTIONS 5 m
r-m Source Chemical Ozone m Removal Oxidation Sparging q JO o n o
o
Potassium Permanganate Injection
Fentonss Reagent Injection
i co
Source In-Situ Steam Removal Thermal Stripping
Desorption
Electrical Resistance Heating
I Radio (pound Frequency
O m Heating OH 3) gt Z 0)
DESCRIPTION
Injection of air and encapsulated ozone beneath the water table to oxidize dissolved DNAPL constituents such as TCE
KMn04 is injected below the water table to oxidize dissolved DNAPL constituents
Fentons Reagent is injected below the water table to oxidize dissolved DNAPL constituents
Stream injected below the water table As the groundwater and soil are heated residual DNAPL is mobilized and collected by groundwater and soil vapor extraciion techniques
Low frequency alternating current is applied below the water table to cause resistive heating ofthe soil and groundwater As the groundwater and soil heat residual DNAPL is mobilized Groundwater and soil vapor extraction techniques are used to collect dissolved and vaporized DNAPL constituents
Electromagnetic radiation is applied below the water table As the groundwater and soil heat residual DNAPL is mobilized
INITIAL SCREENING COMMENT
Presence of DNAPL will potentially require large quantities of ozone The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Small scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Ozone is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of KMn04 The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of Fentons Reagent The exact location of the residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Fentons Reagent is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Small scale heterogenieties can result in channeling during steam injection and reduce the recovery efficiency Shallow depth of application may preclude effective steam control The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeneity has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeniety has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult so target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
_ mdash_ mdash _ _
MITEC I04e 02375
bulln Table 3-2 Description of potentially viable remediation technologies (continued) o
R E S P O N S E
A C T I O N
tn Source Removal
Source Containment Plume Management
co bull
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REMEDIAL
TECHNOLOGY
Chemical Flushing
Hydraulic Containment
Impermeable Barrier
Permeable Reactive Barrier
Phytoshyremediation
PROCESS
OPTIONS
bull
DESCRIPTION
Injection and recovery of alcohol polymers andor surfactant below the water table to enhance dissolution of residual DNAPL
Pump groundwater in downgradient portion of VOC-contaminated region groundwater to intercept contamination before it reaches a receptor or downgradient ofthe highest concentrations as source containment
Impermeable barrier is installed in the subsurface to contain groundwater and reduce the pumping rate needed for containment Can be installed upgradient of a receptor to prevent exposure or downgradient of the highest concentrations as source containment
Reactive material such as zero valent iron placed in flow path of contaminated groundwater Contaminants are treated as the natural gradient causes groundwater to flow through the barrier
Extracting of contaminated groundwater by evaporation from high water use trees Organic contaminants may also be biodegraded by the root system or may adsorb to living or dead root tissue and become immobilized
INITIAL SCREENING C O M M E N T
Higher permeability zones are preferentially remediated The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Groundwater extraction is required to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent fulfresidual DNAPL removal Very high installation and operation cost
Effective in containing dissolved concentrations Relatively low installation cost moderate on-going maintenance costs
Effective in containing dissolved concentrations Requires groundwater extraction and treatment Moderate installation cost moderate on-going maintenance costs
Moderate installation costs Lifetime of reactive material difficult to predict and reinstallation may become necessary No on-going maintenance costs prior to replacement
Still experimental Hard to confirm water usage rates and prove containment Trees may require ongoing monitoring and replacement Low installation and maintenance costs Only operates during the growing season
MITEC 104e 02376
1 T l Table 3-3 Selection of potentially viable remediation technologies for detailed analysis 1
rt g g g
5
i 8 5
3
CO
o m O H JO gtZW
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spound r m rshymO
M nn o
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RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Indoor Air Monitoring
Basement Sump Venting
Potable Use of Groundwater
Restrict Basements Below Water Table
Excavation
Natural Gradient Flushing
Air Sparging
Chemical Oxidation
In-Situ Thermal Desorption
Chemical Flushing
PROCESS
OPTIONS
No Action
Ozone Sparging
Potassium Permanganate Injection
Fentonss Reagent Injection
Steam Stripping
Electrical Resistance Heating
Radio Frequency Heating
RETAINED
DISCARDED
Retained
Retained
Retained
Retained
Retained
Retained
Retained
Discarded
Retained
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
RATIONALE
Used as a baseline for comparison
Necessary to evaluate if the region of VOC-contaminated groundwater is expanding in size and if the VOC concentrations in groundwater discharging to the unnamed brook are increasing
Necessary to monitor that concentrations remain below health risk levels
May be required al new residences with basements below the water table built in Browneil Road area
The existing sump vents at Lot 3-30 on South Browneil Road will be required to mitigate indoor air risks
Restriction of potable use of groundwater at properties overlying the region of VOC-contaminated groundwater will be required to prevent dermal ingestion and inhalation exposure
Restriction of construction of new basements below the water table in the area of VOC-contamination will be required to prevent future inhalation risks
Residual DNAPL located too far below ground surface to make excavation feasible The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Excavation of known release areas has occurred
Longer time frame to clean up not a drawback at this site Lower cost is a benefit
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location of the residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL Steam control difficult
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
MITEC 104e 02377
2 Table 3-3 Selection of potentially viable of remediation technologies for detailed analysis (continued) a m RESPONS E R E M E D I A L PROCES S RETAINED RATIONALE
ACTION T E C H N O L O G Y OPTION S DISCARDED
Source Containment Hydraulic Containment Retained Proven effective at containing expansion ofthe region of contaminated groundwater Region of Contaminated
iisect
n n o
Groundwater Management
Impermeable Barrier Retained Proven effective at region of contaminated groundwater containment
Permeable Reactive Retained Proven effective at region of contaminated groundwater containment Barrier
Phyto-remediation Retained Experimental however there are no potential negative consequences in using the technology Low cost is a benefit
co i
IO
I (A O m OH 73 gtZ
MITEC 104e 02378
4 DETAILED ANALYSIS OF ALTERNATIVES
41 ALTERNATIVE 1 NO ACTION
The no-action alternative is included in accordance with EPAs Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA (EPA 1988) The no-action
alternative provides a baseline for comparison and involves taking no additional actions at the
Study Area This remedy assumes no continuing monitoring of dissolved concentrations in
groundwater surface water or concentrations in indoor air This remedy assumes no institutional
controls on basement sump venting at Lot 3-30 on South Browneil Road property no restrictions
on new buildings with basements set below the water table constructed within the area of VOC
concentrations in groundwater and no restrictions groundwater use for potable purposes within
the region of VOC-contaminated groundwater
411 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community The risk assessment completed for the SIR
(HSI GeoTrans 2000) concluded that current conditions at the Study Area do not pose a risk to
human health Current conditions include venting ofthe sump at Lot 3-30 on South Browneil
Road no buildings other than at Lot 3-30 with basements below the water table in VOC-
contaminated areas and no potable-use wells within the region of VOC-contaminated
groundwater Without institutional controls to ensure this there may be future risk The risk
evaluation indicated that concentrations in the unnamed brook resulting from contaminated
groundwater discharge while not above risk-based thresholds were close to levels that could
pose a risk to human health Therefore monitoring is advised to confirm that VOC
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
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that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of VOC-contaminated groundwater could result in health risks not
evaluated in the risk assessment
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative
Time to Achieve Remedial Action Objectives It is estimated that the time frame required
for natural attenuation of contaminants to meet the groundwater cleanup concentrations will
significantly exceed the two-year time frame used to evaluate short-term effectiveness
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment There is no treatment of contaminants under this option
Reduction in Toxicity Mobility or Volume Some reduction of residual DNAPL and
accompanying dissolved concentrations is expected through natural attenuation over time if no
action were pursued at the Study Area However no monitoring data would be available to
confirm the progress
Amount of Material Contained or Treated Natural attenuation may serve to contain the
entirety of the region of groundwater contaminated with dissolved VOCs
413 LONG-TERM EFFECTIVENESS
Residual Risk Therisk assessment completed for the SIR (HSI GeoTrans 2000)
concluded that current conditions at the Study Area do not pose a risk to human health
However the risk evaluation indicated that concentrations in the unnamed brook resulting from
contaminated groundwater discharge while not above risk-based thresholds were close to levels
that could pose a risk to human health Therefore monitoring is advised to confirm that VOC
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concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of contaminated groundwater could result in health risks not evaluated in
the risk assessment Without institutional controls to ensure basement sump venting at Lot 3-30
on South Browneil Road restrictions on new buildings with basements set below the water table
within the region of VOC-contaminated groundwater and prevention ofthe installation of wells
for potable supplies within the region of VOC concentrations in groundwater a residualrisk to
human health remains
Adequacy and Reliability of Controls This remedy does not assume the sump in the
basement ofthe residence at Lot 3-30 on South Browneil Road remains sealed and vented to the
outside and that the pump is maintained in operable condition to continue to keep groundwater
out ofthe basement Previous air sampling conducted by the VTDEC has confirmed that this is
necessary to control indoor air impacts to this residence This remedy relies on natural
attenuation to control the region of VOC-contaminated groundwater however there is no
continuing monitoring of dissolved VOC concentrations in groundwater Since monitoring to
date has not confirmed that the region of VOC-contaminated groundwater is not expanding in
size a remedy which has a natural attenuation component but does not include monitoring does
not provide adequate control
Permanence of Remedy In the very long-term natural gradient flushing should reduce
VOC concentrations in groundwater to acceptable levels
414 COMPLIANCE WITH ARARs
Groundwater Protection Rule and Strategy It is expected that natural attenuation would
over time reduce groundwater concentrations to below VT Groundwater Enforcement Standards
However a no-action response would not comply with VT Groundwater Protection Rule and
Strategy (VTDEC 1997) which allows for remediation of sites by natural attenuation if sufficient
monitoring is perfonned to document that expansion ofthe region of contaminated groundwater
is not occurring and that natural attenuation is occurring The no-action alternative would not
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AU1NGFS90010030929wro 4-3 HSI GSOTraFIS IflC
MITEC 104e 02381
allow for continued monitoring and would not meet this requirement
Surface Water Quality Standards It is expected that natural attenuation would over
time reduce surface water concentrations to below VT Water Quality Criteria for the protection
of human health and aquatic organisms (VTDEC 2000)
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
concentrations of VOCs adsorbed to soil and dissolved in groundwater in the Study Area do not
pose a risk to human health andor the environment under current uses There would be arisk if
groundwater within the region of VOC-contamination were used as a potable supply Therefore
if dissolved concentrations were not migrating beyond the limits ofthe region identified in the
SIR (HSI GeoTrans 2000) and groundwater were not used for potable purposes the no action
alternative would be protective of human health and the environment However there are not
sufficient data to determine whether the region of VOC-contaminated groundwater is stable or
decreasing in size If the region of contaminated groundwater were expanding beyond the limits
upon which the risk assessment was based there may be a future risk to human health and the
environment Also restrictions should be placed on properties overlying the region of VOC-
contaminated groundwater to prohibit construction of basements below the water table and the
use of groundwater as a potable supply and the venting ofthe sump at Lot 3-30 should continue
416 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000AlXINGFS900U0030929wro 4-4 HSI GGOTrdRS IflC
MITEC 104e 02382
Technical Feasibility The no-action alternative is technically feasible
bull Ability to Construct the Alternative The no-action alternative requires no
construction
bull Reliability ofthe Technology No technology would be applied under the no-
action alternative
bull Ease of Undertaking Additional Remedial Actions The no-action alternative
would not prevent future remedial actions
Administrative Feasibility The no-action alternative is administratively feasible
Availability of Services and Materials No services or materials are required to carry out
the no-action alternative
417 COSTS
There are no costs associated with the no-action alternative The no-action alternative is
shown on Table 41 for purposes of comparison
4 2 A L T E R N A T I V E 2 M O N I T O R I N G INSTITUTIONAL C O N T R O L S AND
H Y D R A U L I C C O N T A I N M E N T
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull institutional controls would be implemented to restrict construction of any
buildings with basements within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull groundwater extraction and treatment would be done to contain the region of
VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753laquo000WJJNoFS9JXI10030929wro 4 - 5 HSI GSOTraDS JllC
MITEC 104e 02383
Groundwater pumping is an effective technology for hydraulic containment of
contaminated groundwater Hydraulic containment can be used if the region of VOC-
contaminated groundwater is impacting a sensitive receptor or is expanding is size The risk
assessment (Menzie Cura 2000a and 2000b) showed that groundwater was not impacting any
receptors to a degree that would represent a human health risk or risk to the environment There
is not sufficient temporal data however to confirm that the region of VOC-contaminated
groundwater is not expanding is size Therefore an analysis of hydraulic containment has been
included in this Corrective Action Feasibility Investigation in the event that future monitoring
shows the region of VOC-contaminated groundwater is expanding and that containment is
necessary
If monitoring indicates that natural attenuation is not causing the region of VOC-
contaminated groundwater to be stable in size or to shrink then an active containment remedy
may be required Under this scenario a groundwater pump-and-treat system would be installed
and operated in the Study Area to hydraulically contain contaminated groundwater and prevent
expansion ofthe region of VOC-contaminated groundwater Pumping wells would be installed
in the overburden silts and sands to the clay layer Wells would be installed in the downgradient
portions of contaminated groundwater to the southeast and southwest Extracted groundwater
would be treated before discharge to surface water The primary treatment operation will be air
stripping with a low-profile stripper for the removal of VOCs primarily TCE Depending on
treatment efficiencies secondary treatment with granular activated carbon may be required In
addition a particulate filter may be added to remove iron prior to treatment and reduce iron
fouling ofthe air stripper and carbon Extracted and treated groundwater would be discharged to
surface water via an outfall Compliance sampling can be conducted at the outfall or at a
sampling point within the treatment building The outfall should be constructed to minimize
hydraulic impacts on the receiving water body
The number and location of pumping wells that may be required to capture and contain
the region of TCE-contaminated groundwater has been investigated using the two-dimensional
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9JXA10030929WO 4-6 HSI GSOTfanS IdC
MITEC 104e 02384
analytical element simulation code TWODAN (Fitts 1997) TWODAN is a commercially
available copyrighted program The input parameters to the model are based on the values
reported in the SIR (HSI GeoTrans 2000) Input data sets for the analyses contained in this
report are included in Appendix A The bottom elevation ofthe model is 306 ft which is
representative ofthe top ofthe continuous clay layer beneath the site The model represents the
interbedded silts and fine sand layer and the overlying medium to fine sand surficial unit as one
layer The hydraulic conductivity ofthe modeled layer is 184 ftday The estimated areal
recharge for the model is 10 inyr The basement sump at Lot 3-30 on South Browneil Road
pumps groundwater year round The resulting depression ofthe water table is represented by a
constant head of 33128 ft which is approximately 8ft below ground surface at that location
Groundwater elevations used in the model were based on an average ofthe July 1999 and
December 1999 potentiometric surface in wells with screened intervals intersecting the water
table The model representation of current hydrologic conditions at the Study Area is shown in
Figure 4-1 Groundwater elevations are shown in meters on this figure
Two containment scenarios were evaluated The first was a source control application in
which the TWODAN model was used to determine the number of wells and pumping rates
required to contain the 10000 to 20000+ ugL TCE concentration zone as shown in Figure 1-2
In this scenario pumping would contain the contaminated groundwater nearest the source(s)
Over time if new contamination is not allowed to migrate from the source(s) the VOC
concentrations in the rest ofthe region of contaminated groundwater would attenuate The
second scenario was a containment application in which the TWODAN model was used to
determine the number of wells and pumping rate required to contain the 1000 to 10000 (igL
TCE concentration zone as displayed in Figure 1-2 In this scenario pumping occurs in the
downgradient portions ofthe contaminated groundwater
Each recovery well was assumed to be 4 inches in diameter fully screened and have a
pumping rate of 5 gpm The pumping rate was based on the aquifer testing results reported in the
SIR (HSI GeoTrans 2000) applied to a fully screened extraction well The results ofthe model
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000A1XINOFS9JX)10030929WPD 4-7 HSI GSOTraDS IflC
MITEC 104e 02385
analyses indicate that a minimum of three 4-inch diameter recovery wells pumping at 5 gpm are
required to contain the 10000 to 20000+ ugL TCE concentration zone The results of this
model simulation are shown on Figure 4-2 The model analyses also indicated that a minimum
often 4-inch diameter recovery wells pumping at 5 gpm are required to contain the 1000 to
10000 ugL TCE concentration zone Figure 4-3 shows the results of this model simulation
Figures 4-2 and 4-3 also show that groundwater extraction for hydraulic containment may induce
infiltration of surface water in response to pumping thereby reducing the amount of water
flowing in the brook
421 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 2 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with extraction well construction and treatment plant construction Access by
unauthorized personnel would be restricted by fencing temporary barriers andor warning signs
The groundwater treatment building would be locked and secured A health and safety plan
(HASP) would be prepared for the remedial activities In conformance with Occupational Safety
and Health Administration (OSHA) regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative Suitable dust control measures would be implemented during
construction ofthe groundwater treatment system Additionally the treatment process is
expected to be relatively simple with a low potential for exceedance of discharge limitations
Monitoring ofthe treatment process would be performed
Time to Achieve Remedial Action Objectives The time estimated for well installation
system debugging and establishing hydraulic gradient control is three to six months The RAOs
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^XM0030929wro 4-8 HSI GSOTraOS IIIC
MITEC 104e 02386
for groundwater would be achieved when monitoring results indicated that VOC concentrations
had attenuated and groundwater standards had been met It is estimated that attenuation of VOC
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of recovered groundwater would remove some ofthe VOCs from
the aquifer This treatment would generate residuals such as used filters and spent carbon This
process is irreversible
Reduction in Toxicity Mobility or Volume Treatment ofthe extracted groundwater
would reduce its toxicity prior to surface water discharge Contaminants adsorbed to any
secondary carbon would ultimately be destroyed during the process of regenerating the carbon
Contaminants adsorbed to any particulate filters would be landfilled or incinerated along with the
filters The toxicity and volume of contamination in groundwater are nominally reduced by
extraction and treatment but effectiveness is limited as discussed in Section 421 above
Modeling shows that groundwater extraction would be effective in reducing the mobility ofthe
dissolved phase contamination
Amount of Material Contained or Treated The volume of contaminated groundwater
that would be treated on a long-term basis is estimated at about 8 million gallons per year for the
source containment option and about 26 million gallons per year for containment of all dissolved
TCE concentrations greater than 1000 ugl
423 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
FOR ALLING INDUSTRIAL PARK MWPJXXTSN75320(XAAUJNOFS9-OCM0030929WKgt 4-9 HSI GSOTrSDS IDC
MITEC 104e 02387
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Groundwater pumping would control any risks caused by expansion ofthe
region of contaminated groundwater Residual risk to human health would be controlled through
institutional controls
Adequacy and Reliability of Controls Extracted groundwater would be treated on-site to
standards required for discharge to surface water The extraction well pumps and groundwater
treatment equipment would require maintenance on a long-term basis Groundwater monitoring
to ensure that the contamination was being adequately contained by the groundwater extraction
would be necessary on a long-term basis
Permanence of Remedy The groundwater treatment plant would be enclosed and
designed as a modular system and its equipment would be readily replaceable if required The
extraction wells may need to be rehabilitated andor replaced during the life ofthe remedy
424 COMPLIANCE WITH A R A R S
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to return the
remaining groundwater to below Groundwater Enforcement Standards Groundwater extraction
would also eventually return the areas of highest groundwater contamination to below
Groundwater Enforcement Standards
Surface Water Quality Standards Hydraulic control of the groundwater migration would
interrupt and remove contaminates from groundwater thereby preventing discharge to the
unnamed brook resulting in achievement of Water Quality Criteria for the protection of human
health and aquatic organisms (VTDEC 2000)
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200OALUNoFS9^Kgtl0030929wro 4-10 HSI GOOTrSDS IDC
laquoTEC I04e 02388
425 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The hydraulic containment alternative would offer protection to both human health and
the environment if expansion ofthe region of contaminated groundwater were identified Since
the risk assessment (Menzie Cura 2000a) found that under current conditions groundwater and
surface water concentrations are below levels which constitute a risk to human health and since
hydraulic containment would ensure the region of VOC-contaminated groundwater remained in
the current configuration hydraulic containment would be protective of human health and the
environment This alternative assumes institutional controls will be in place to continue sump
venting in the basement at Lot 3-30 on South Browneil Road restrict the installation of
basements below the water table within the region of VOC-contaminated groundwater and
prevent potable use of groundwater within the region of VOC-contaminated groundwater
Protection would be achieved at the end ofthe construction period of three to six months The
residual risks posed by contaminated material remaining within the groundwater would not be
significant because all potential exposure routes would be addressed
426 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction which would present no special problems
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AUB4CFS9^10l0030929wro 4 - 1 1 HSI GGOTrdDS IDC
MITEC 104e 02389
bull Reliability ofthe Technology Hydraulic gradient control is a frequently used
alternative that has proven effective in preventing further expansion of areas with
- contamination in groundwater Filtration air stripping and carbon absorption
have frequently been used and proven effective in treating groundwater in other
applications
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the
gradient control system was inadequate to restrict the expansion ofthe region of
contaminated groundwater implementation of additional resources would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
operate maintain and monitor the well head portions ofthe treatment system Institutional
controls would also be needed to implement institutional controls to continue sump venting in
the basement at Lot 3-30 on South Browneil Road The town must pass zoning restriction which
would prevent construction of basements below the water table and potable use of groundwater
within the region of contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor the groundwater treatment system associated with the hydraulic containment option
are available
427 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 2 The
capital costs would be $207000 for the source control application and $732000 for the
containment option OampM costs include groundwater monitoring and maintenance ofthe
groundwater extraction and treatment system These are $77000 per year for the source control
application and $139000 per year for the containment option The present worth analysis
(calculated at a 7 discount rate interest for 30 years) yields a total of $1085403 for the source
control application and $2287474 for the plume containment option
FOR ALLING INDUSTRIAL PARK MWPJXXSN753U0OOALUNGFS9-tfW0030929wro 4-12 HSI GSOTrailS IRC
MITEC 104e 02390
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS AND
PERMEABLE REACTIVE BARRIER
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull and a permeable reactive barrier would be installed and maintained at a
downgradient location to reduce concentrations of TCE dissolved in groundwater
as it flows under natural gradient flow conditions if groundwater monitoring
shows the region of VOC-contaminated groundwater is expanding in size
PRBs consist of a permeable region of chemically reactive materials constructed to
intercept the path of a dissolved groundwater contaminants Reactive materials may include
bull zero-valent iron for reductive dehalogenation
precipitation agents such as gypsum to create insoluble metal salts
bull sorptive agents such as granular activated carbon to capture and immobilize organics
bull reducing agents such as dithionite and hydrogen sulfide to reduce and insolubilize metals
and
bull biologic electron acceptors such as lactic acid or nitrate to enhance aerobic
biodegradation
FOR ALLING INDUSTRIAL PARK MAWPJX)CSVN7532000AmNOFS9-OOU0030929wpo 4-13 HSI GSOTrSDS IDC
MITEC 104e 02391
Zero-valent iron and granular activated carbon are both applicable for use in the treatment
of TCE in a PRB Granular zero-valent iron has been widely applied in PRB installations and
promotes reductive dehalogenation of TCE to chloride ion ethane and ethene Activated carbon
has been used in a limited number of field and lab studies to simply adsorb dissolved organic
constituents as they pass through thePRB
Because ofthe costs ofthe reactive or adsorptive material PRBs are generally
constructed as a funnel and gate system The funnel portion ofthe PRB is a typical vertical
barrier wall constructed of sheet piles bentonite or other impermeable material which is
designed to direct groundwater flow to the gate portion ofthe PRB containing the reactive or
adsorptive material Funnel and gate sections ofthe PRB are keyed together and generally to a
low permeablility zone located at depth
The use of permeable reactive barriers is not directly applicable to treatment of DNAPL
The mechanism for groundwater remediation using a PRB would include
bull dissolution ofthe DNAPL into groundwater by natural processes
bull downgradient transport ofthe dissolved contaminants to the PRB location
artificial channeling ofthe contaminated groundwater to the reactive material located in
the gate by the barrier funnel and
bull reductive dehalogenation or adsorption of a portion ofthe VOC as is passes through the
gate
A variety of methods are available for emplacement ofthe PRB The most conventional
method includes excavation of a trench and backfill will a soilbentonite slurry for the funnel
portion and granular iron or carbon in the gate section Other methods such as sheet-piling jet
grouting continuous trenching fracturing and others are available For the subject site because
ofthe presence of sand in the formation it is likely that a continuous trenching method would be
the most applicable and cost effective
FOR ALLING INDUSTRIAL PARK MWPJX)CSN7S320O0ALUNGFSraquo-O0U0030929wro 4-14 HSI GGOTfaDS IOC
MITEC 104e 02392
Operation maintenance and monitoring ofthe PRB is relatively simple Groundwater
samples would be periodically collected from locations upgradient and downgradient ofthe gate
section(s) ofthe PRB to monitor its effectiveness Media installed in the gate (iron or carbon)
would require periodic replacement probably on a annual basis for carbon and every 5 to 10
years for iron
The placement depth width and length ofthe PRB would depend on the region of
VOC-contaminated groundwater that was desired to be intercepted the depth to the underlying
low permeability layer and the desired TCE concentration reduction (which determines resident
time required in the gate) As wilh hydraulic containment two scenarios were investigated The
first a source control option would intercept VOC-contaminated groundwater with TCE
concentrations greater than 10000 ugL A PRB of approximately 1200 feet in length would be
required The second a region of contaminated groundwater containment option would
intercept VOC-contaminated groundwater with TCE concentrations in excess of 1000 ugL A
PRB of approximately 2200 feet in length would be required The depth ofthe PRB in both
cases would likely extend from ground surface to about 40 feet below ground surface The PRB
would be installed into the underlying areally-extensive clay layer Figure 4-4 shows the
placement ofthe PRB under each opinion
431 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 3 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with PRB construction since either conventional or continuous trenching methods
would be employed during its construction However exposure hazards during construction
would be considerable since the emplacement requires excavation and handling of a large
volume of potentially contaminated soils During construction access by unauthorized personnel
would be restricted by fencing temporary barriers andor warning signs Following
FOR ALLING INDUSTRIAL PARK
MWP_DOCSN753 2000 AUJNCFS9^10 10030929 WPD 4-15 HSI GSOTrSPS IDC
MITEC 104e 02393
construction little to no hazards should be expected from the long-term operation ofthe PRB A
HASP would be prepared for the construction activities In conformance with OSHA
regulations site workers would be trained required to wear appropriate protective equipment
and as applicable would be enrolled in a medical monitoring program Groundwater monitoring
wells would be sampled to determine changes in VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative with proper controls Suitable dust control vapor monitoring and
stormwater runoff measures would be implemented during construction ofthe PRB
Time to Achieve Remedial Action Objectives The time estimated for PRB emplacement
is four to six months The RAOs for groundwater would be achieved when monitoring results
indicated that the VOC concentrations have attenuated and groundwater standards have been
met It is estimated that attenuation of contaminant concentrations to ARARS will significantly
exceed the two-year time frame for short-term effectiveness This is because the application of a
PRB at the site would not significantly alter groundwater flow or TCE dissolution from within
the source area Therefore it would not increase the rate at which concentrations of residual
DNAPL or dissolved constituents of DNAPL (TCE) were removed from the source area It
would however limit the size ofthe region of VOC-contaminated groundwater
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of groundwater flowing through the permeable sections ofthe PRB
would remove the dissolved TCE as is flows under natural gradient conditions from the source
area
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNGFS9^X)10030929WPO 4-16 HSI G G O T T S O S jflC
MITEC 104e 02394
Reduction in Toxicity Mobility or Volume Treatment ofthe groundwater would reduce
its toxicity Contaminants adsorbed to carbon (if used as the treatment media in the gate sections
ofthe PRB) would be excavated on a periodic basis and ultimately be destroyed during the
process of regenerating the carbon
Amount of Material Contained or Treated The volumetric flux of contaminated
groundwater through the PRB is estimated to be approximately two million gallons per year for
the 10000 (igL source containment option and approximately four million gallons per year for
containment of all dissolved TCE concentrations greater than 1000 ugL
433 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Treatment of groundwater intersecting the PRB would control any risks
caused by expansion ofthe region of contaminated groundwater to the southeast Residual risk
to human health would be controlled through institutional controls
Adequacy and Reliability of Controls Performance of PRBs in reducing concentrations
of chlorinated organics such as TCE using zero-valent iron has been mixed Most ofthe PRB
performance demonstrations indicate that a concentration reduction of 60 to 90 percent can be
expected Some applications however have been much less successful at reducing VOC
concentrations Although little experience is available for PRBs using activated carbon the
removal efficiency should be expected to be greater and more reliable than zero-valent iron but
far more costly Groundwater monitoring would ensure that the contamination was being
adequately contained by the PRB and would be necessary on a long-term basis
Permanence of Remedy Installation of a PRB would be considered a permanent remedy
although periodic maintenance and replacement of reactive material in the gate would be
required for both carbon and iron-based systems
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9^X)l0030929wro 4-17 HSI GGOTfSnS IDC
MITEC 104e 02395
434 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to reduce VOC
concentrations in the remaining groundwater to below Groundwater Enforcement Standards
Natural gradient flushing would also eventually reduce the areas of highest groundwater
contamination to below Groundwater Enforcement Standards
Surface Water Quality Standards VOC concentrations in groundwater discharging to the
unnamed brook would be reduced significantly Thus operation ofthe PRB would result in
achievement of Water Quality Criteria for the protection of human health and aquatic organisms
(VTDEC 2000)
435 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This downgradient containment alternative would offer protection to both human health
and the environment if VOC concentrations in groundwater discharging to the unnamed brook
were to increase or if the region of contaminated groundwater were to expand in size This
alternative assumes institutional controls will be in place to continue sump venting in the
basement at Lot 3-30 on South Browneil Road restrict installation of new basements below the
water table within the region of VOC-contaminated groundwater and prevent potable use of
groundwater within the contaminated region Protection relative to the risks posed by expansion
ofthe region of contaminated groundwater to the unnamed brook would be achieved at the end
ofthe construction period of four to six months The residual risks posed by contaminated
material remaining within the groundwater would not be significant because all potential
exposure routes would be addressed
FOR ALLING INDUSTRIAL PARK MWP JX3CSN753V2000AIXINOFS90Crl0O30929wPD 4-18 HSI GCOTtSHS IRC
MITEC 104e 02396
436 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
bull Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction Removal and handling of contaminated soils
presents potential risks to construction workers during construction which could
be minimized through health and safety controls
bull Reliability of the Technology Although many full-scale applications of this
approach have been conducted they have been relatively recent Long-term
reliability and effectiveness of PRBs has not been established
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the PRB
was inadequate to prevent expansion ofthe region of VOC-contaminated
groundwater implementation of additional resources would not be hampered by
this alternative
Administrative Feasibility Installing and maintaining the PRB will require access to
properties overlying the region of VOC-contaminated groundwater Additionally property
owner cooperation would be needed to operate maintain and monitor wells located upstream
and downstream ofthe gate sections ofthe PRB system Restrictions would also be needed to
implement institutional controls to continue sump venting in the basement at Lot 3-30 on South
Browneil Road restrict the construction of basements below the water table within the region of
VOC-contaminated groundwater and prevent potable use of groundwater within the region of
VOC contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UO(XAAUJNOFS9-O0 10030929 WPO 4-19 HSI GGOTrSMS IDC
MITEC 104e 02397
Availability of Services and Materials The materials equipment and personnel required
to design install and maintain the PRB are readily available
437 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 3 The
capital costs would be $572000 for the source control application and $1022000 for the
containment option OampM costs include groundwater monitoring and periodic replacement of
the permeable barrier These average $64000 per year for the source control application and
$112000 per year for the containment option The present worth analysis calculated at a 7
discount rate over a 30-year duration yields a total of $1277356 for the source control option
and $2248691 for the containment option
4 4 A L T E R N A T I V E 4 M O N I T O R I N G I N S T I T U T I O N A L C O N T R O L S AND
N A T U R A L A T T E N U A T I O N
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water
The chief mechanisms contributing to reduction of contaminant concentrations in
groundwater by natural attenuation include biotransformation dilution dispersion and discharge
through advective flow and volatilization (EPA 1998) Volatilization is not likely a major
mechanism at the Study Area since contaminated groundwater is located at depth below the
FOR ALLING INDUSTRIAL PARK
MWP_DOCSW7S3U000WXINoFS9-001003O929wro 4-20 HSI GGOTfaDS IDC
MITEC 104e 02398
water table A natural attenuation evaluation will be conducted to better identify the mechanisms
contributing to concentration reduction through natural attenuation Monitoring to be completed
for this evaluation is included in Section 62 EPAs Technical Protocol for Evaluating Natural
Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) was used as the basis for the
design ofthe natural attenuation evaluation
441 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community A HASP would be prepared for the remedial
activities In conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Groundwater monitoring wells would be sampled to determine changes in
VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative
Time to Achieve Remedial Action Objectives The RAOs for groundwater would be
achieved when monitoring results indicated that the region of contaminated groundwater had
naturally attenuated and groundwater standards had been met It is estimated that natural
attenuation of contaminants to ARARS will exceed the two-year time frame for short-term
effectiveness
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0ALUNOFS9^X)M0030929wro 4-21 HSI GGOTfaflS jflC
MITEC 104e 02399
Treatment This alternative involves only natural in-situ processes No remediation
wastes would be generated
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area
Amount of Material Contained or Treated Natural attenuation may serve to contain the
region of VOC-contaminated groundwater at the Study Area Treatment may be accomplished
through biotransformation ofthe contaminants to environmentally acceptable compounds
443 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation of VOC-contaminated groundwater at the Study Area
would eventually achieve the ARARs Residual risk to human health would be controlled
through institutional controls Implementing institutional controls to maintain the sump venting
at Lot 3-30 on South Browneil Road restrict the construction of basements below the water table
within the region of VOC-contaminated groundwater and to control the use of groundwater
within the region of VOC-contaminated groundwater for potable purposes would provide
protection against the potential for exposure
Adequacy and Reliability of Controls Monitoring for VOC concentration reductions in
groundwater and institutional controls would be the main controls of this alternative Sump
venting at Lot 3-30 on South Browneil Road would prevent indoor air impacts at this location
and restrictions on construction of basements below the water table would prevent future indoor
air impacts Control ofthe use of groundwater within the region of VOC-contaminated
groundwater for potable purposes would minimize potential use of groundwater with VOCs
above federal and state drinking water standards Groundwater monitoring would ensure that
attenuation of VOC concentrations was proceeding and provide for periodic assessment ofthe
region of VOC-contaminated groundwater in the Study Area
FOR ALLING INDUSTRIAL PARK bull MWPJXXSN7532000AUINOFS9-00I0O30929WPD 4 - 2 2 HSI GGOTPaMS IRC
MITEC 104e 02400
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time
444 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
445 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
446 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK _
M W P _ D O C S N 7 5 3 U O O O A L U N O F S 9 - O O U 0 0 3 0 9 2 9 W P O 4-23 HSI GGOT 13118 IflC
MITEC 104e 02401
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
bull Ability to Construct the Alternative No major construction is included in this
alternative
bull Reliability ofthe Technology Ongoing monitoring and evaluation on would
ensure that natural attenuation was controlling and remediating the contaminated
groundwater
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation was not restricting the size ofthe region of VOC-contaminated
groundwater implementation of additional remedial actions would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
sample and maintain monitoring wells Restrictions would also be needed to implement
institutional controls to continue sump venting in the basement at Lot 3-30 on South Browneil
Road restrict construction of basements below the water table in VOC-contaminated
groundwater and prevent potable use of groundwater within the region of VOC-contaminated
groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor natural attenuation are also available
447 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 4 The
capital costs would be $55000 and include the initial natural attenuation evaluation and the
implementation of institutional controls OampM costs include groundwater monitoring These are
$9000 per year The present worth analysis yields a total of $163083 for this 30-year
alternative
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0AUJNOFS9^X)10030929wro 4-24 HSI GGOTraDS 1110
MTECl04e 02402
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water and
phytoremediation would be used to intercept TCE-contaminated groundwater
where it discharges to the unnamed brook
In this alternative all components of Alternative 4 would be implemented and
phytoremediation would be implemented in the area where TCE- contaminated groundwater
intersects the unnamed brook to intercept the contaminated groundwater and reduce the amount
of VOCs reaching the brook Phytoremediation of VOCs is still an experimental technology
Several field studies have used hybrid poplars (EPA 2000) to extract TCE- contaminated
groundwater It has been shown that TCE is removed along with groundwater by the trees and
metabolized as well as transpired from the leaves The rate of TCE contaminant removal from
the groundwater and its discharge to air by transpiration varies based on site specific conditions
and season Therefore contaminant or groundwater removal rates are impossible to predict at
this time without field studies Trees may be subject to destruction by natural disasters and pests
Their condition must be monitored and they may require replacement
F O R ALLING INDUSTRIAL PARK MWPJXXSN7532OOOWXINGFS9JraquoIOO30929WPO 4 - 2 5 H S I G G O T r S D S IOC
MITEC 104e 02403
In order for interception ofthe region of contaminated groundwater to be effective the
trees must be planted so that the root zone intercepts the contaminated groundwater Due to the
depth ofthe higher VOC concentrations in most areas ofthe site phytoremediation would be
ineffective in containing expansion ofthe region of contaminated groundwater An exception to
this is the area near the unnamed brook According to the SIR (HSI GeoTrans 2000) VOC-
contaminated groundwater appears to be discharging upward in groundwater into the unnamed
brook Trees planted along the border ofthe brook may help to intercept this contaminated
groundwater before it discharges into the brook
451 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 5 are as follows
Protection of Workers and the Community Normal landscaping hazards would be
associated with installation ofthe trees A HASP would be prepared for the remedial activities
In conformance with OSHA regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative Suitable dust control measures would be implemented during
planting of trees
Time to Achieve Remedial Action Objectives The time required for maximum
interception ofthe contaminated groundwater by the trees would depend on site specific
conditions such as root growth rate and tree survival rate The RAOs for groundwater would be
achieved when monitoring results indicated that VOC concentrations had attenuated and
groundwater standards had been met It is estimated that natural attenuation of contaminant
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
FOR ALLING INDUSTRIAL PARK MWP J X 3 C S N 7 5 3 2 0 0 0 A U J N O F S 9 ^ ) 0 1 0 0 3 0 9 2 9 W P D 4-26 HSI G G O T H S I I S IDC
MITEC 104e 02404
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment This alternative involves only in-situ treatment ofthe groundwater Plant
tissue would be analyzed for the presence of VOCs Plant materials can bio-accumulate metals
present in soil and groundwater If concentrations are high enough dead plant matter may have
to be disposed in an appropriate manner
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area Phytoremediation may
metabolize some ofthe VOCs
Amount of Material Contained or Treated Natural attenuation and phytoremediation
may serve to prevent expansion ofthe region of VOC-contaminated groundwater at the Study
Area Treatment is accomplished with biotransformation ofthe contaminants to environmentally
acceptable compounds
453 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation ofthe region of VOC-contaminated groundwater and
phytoremediation at the Study Area would eventually achieve the ARARs Implementing
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil Road
restrictions on construction of basements below the water table in regions of VOC-contaminated
groundwater and to control the use of groundwater for potable purposes within the region of
VOC-contaminated groundwater would provide protection against the potential for exposure
FOR ALLING INDUSTRIAL PARK MWP_IXXSW532000ALL1NOFS9^)0I0030929WTO 4-27 HSI GCOTraDS IflC
M l T E C l 0 4 e 0240S
Therefore despite the fact that an extended time period may be required to reduce VOC
concentrations to an acceptable level the residual risk associated with this alternative would be
minimal Trees planted near the unnamed brook may serve to intercept contaminated
groundwater before it discharges to this receptor
Adequacy and Reliability of Controls Groundwater monitoring for natural attenuation
institutional controls and interception of contaminated groundwater before it reaches the
unnamed brook would be the main controls of this alternative Sump venting at Lot 3-30 on
South Browneil Road would prevent indoor air impacts at this location and restriction on the
construction of new basements below the water table within the region of VOC-contaminated
groundwater would prevent future indoor air impacts at other locations Control ofthe use of
groundwater for potable purposes within the region of VOC-contaminated groundwater would
minimize potential use of groundwater with VOCs above federal and state drinking water
standards Groundwater monitoring would ensure that natural attenuation of contaminants was
proceeding and provide for periodic assessment ofthe region of VOC-contaminated groundwater
in the Study Area Groundwater and surface water monitoring would also be conducted to
monitor success ofthe phytoremediation in intercepting contaminated groundwater before it
reaches the unnamed brook
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time Trees must be monitored and will be replaced in
the event of destruction by severe weather pests or other reasons
454 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUINOFS9-00I0030929WPD 4-28 HSI GGOTraflS IllC
MITEC 104e 02406
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
Phytoremediation at the edge ofthe unnamed brook would further reduce the VOC
concentrations in groundwater discharging to the brook
455 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
456 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
Ability to Construct the Alternative Installation of this alternative requires
landscaping skills which are readily available
bull Reliability ofthe Technology Ongoing monitoring and evaluation would ensure
that natural attenuation was controlling and remediating the contaminated
groundwater Ongoing monitoring ofthe condition ofthe trees would also be
required to ensure they are continuing to grow and do not need replacement
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^)OM0030929WPD 4-29 HSI GGOTfaDS jflC
MITEC 104e 02407
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation and phytoremediation were not restricting the size ofthe region of
VOC-contaminated groundwater implementation of additional resources would
not be hampered by this alternative
Administrative Feasibility Planting trees and if necessary installing and monitoring
additional wells might require access to private property Additionally property owner
cooperation would be needed to sample and maintain monitoring wells Restrictions would also
be needed to implement institutional controls to continue sump venting in the basement at Lot 3shy
30 on South Browneil Road restrict construction of new basements below the water table in
regions of VOC-contaminated groundwater and prevent potable use of groundwater within the
region of VOC-contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to plant the trees and monitor natural attenuation are also available
457 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 5 The
capital costs would be $80000 and include the initial natural attenuation evaluation the
implementation of institutional controls and installation of a phytoremedial barrier of poplars
OampM costs include groundwater monitoring and maintenance ofthe phytoremedial barrier
These are $11000 per year The present worth analysis yields a total of $209397 for this 30shy
year alternative
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000ALLINOFS9^)0I0030929WPD 4-30 HSI GGOTfaDS IPC
MITEC 104e 02408
r TI Table 41 Cost estimates for remedial alternatives i deg 5 70
8 P
QUANTITY UNITS UNIT C O S T CAPITA L C O S T ANNUAL
OampM C O S T
5 n Alternative I No Action 8 O a Q
na na $0 $0 $0 a sect
Total $0 $0
Alternative 2 Monitoring Institutional Controls and Hydraulic Containment
1) Implement Institutional Controls 32 properties $10000 $32000
2) Groundwater Monitoring $9000
3) Pumping System
Option 1 Source Containment
Extraction wellspiping $50000 $15000
Electrical distributioncontrol $25000 $8000
Construction oversight $25000
Groundwater treatment system $75000 $45000
Total Option 1 $207000 $77000
Option 2 region of contaminated
groundwater Containment
Extraction wellspiping $175000 $35000
w Electrical distributioncontrol $50000 $20000
O
o H mO Construction oversight $125000
o n gt Groundwater treatment system $350000 $75000
o z 0) Tolal Option 2 $732000 $139000
i deg QUANTITY UNITS UNI T C O S T
5 so
Alternative 3 Monitoring Institutional Controls and Permeable Barrier
m t - 1) Implement Institutional Controls 32 properties $10000
9 O 2) Groundwater Monitoring
| o 3) Permeable Harrier
Option I Source Containment
Barrier installation 1200 feel $450
Total Option 1
Option 2 region of contaminated
groundwater Containment
Barrier Installation 2200 feet $450
w Total Option 2 NJ
Alternative 4 Monitoring Institutional Controls and Natural Gradient Flushing
1) Implement Institutional Controls 32 properties $10000
2) Groundwater Monitoring
3) Natural Attenuation Evaluation
Total
Alternative 5 Monitoring Institutional Controls Natural Gradient Flushing and Phytoremediation
1) Implement Institutional Controls 32 properties $10000 X (A 2) Groundwater Monitoring
reg 3
o m O H
3) Natural Attenuation Evaluation
4) Phytoremediation
gt z Total (A
Notes na = not applicable
CAPITAL C O S T
$32000
$540000
$572000
$990000
$1022000
$32000
$23000
$55000
$32000
$23000
$25000
$80000
ANNUAL
OampM C O S T
$9000
$55000
$64000 1
$103000
$112000
$9000
$9000
$9000
$2000
$11000
MODEL CALCULATED GROUNDWATER CONTOUR IN FEET ABOVE MEAN SEA LEVEL
APPROXIMATE PROPERTY BOUNDARY
M6-2 raquo EXISTING MONITORING WELL
CP-6 bull EXISTING SOIL BORING
M 8 - 2 raquo MONITORING WELL (RESAMPLED)
bull SMALL DIAMETER BORING - BELOW CLAY
bull BEDROCK MONITORING WELL
A S I - 2 I H S I GEOTRANS WELL CLUSTER LOCATION
U-TRIB-8a SURFACE WATER SAMPLING LOCATION R S - U
a PASSIVE SAMPLER LOCATION
T2-2 PROFILE SAMPLE LOCA1ION (JOHNSON COMPANY 1999)
WELL DESTROYED
TEF Concentrat ions ( u g A l
1000 - 10000
iry IOOOO - 20000
bull 20000 + NOTES AREA WHERE TCE CONCENTRATION IS
M l LOCATIONS APPROXIMATE INTERPOLATED THERE IS NO TCE
BASE PUN DEVELOPED FROM DATA FROM THESE AREAS
1 TOWN OF WUUSION PARCEL BOUNOART MAP (SHIPPED 121597) PROVIDED ST (VS (BURUNCTON VT) IN DXF FORMAT
2 PLAN DEVELOPED BT HEINDEL AND NOTES (BURUNCTON VT) FOR THE BATES PROPER1Y 1NVESIBAT10N AND PROVIDED TO THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION HASTE MANAGEMENT DIVISION 1997
3 ORTHOPHOTO SHEET 100216 VERMONT STATE MAPPING PROJECT 1988
4 TORN OF WIUJSTON ASSESSORS MAP 1997
5 VARIOUS SITE PUVQ CN RLE WITH THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION WASTE HMUGElENr OOVBON
6 DM FROM JOHNSON DD REPORT UNTIED GROUNDWXIER IHVESI1CAH0M ALLWC INDUSTRIAL PARK DATED 7 W FDR THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Modeled Site - Existing Conditions copy H
pound n Williston Vermont o CHECKED MS HSI
DRAFTED RMK GEOTRANS FU fa-Site-mod-ECdwg 4 - 1 A TITIA T t n HBVAIT
DATE 10600
5 COMPARATIVE EVALUATION OF ALTERNATIVES
The purpose of this section is to compare the remedial alternatives on the basis ofthe
evaluation criteria developed and discussed in Section 4 and provide a recommended alternative
These criteria include overall protection of human health and the environment short-term
effectiveness reduction of toxicity mobility or volume long-term effectiveness and
permanence compliance with ARARs implementability and cost
The comparative analysis is conducted to highlight significant differences between
identified alternatives All alternatives for the Study Area groundwater except the no-action
alternative include the following
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater and
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
The no-action alternative is not included in the comparison provided in the following
sections since it would not meet the RAOs All four ofthe remaining alternatives would meet
the RAOs stated in Section 32
51 SHORT-TERM EFFECTIVENESS
Protection of Workers and the Community Groundwater would be monitored under all
scenarios to look for any changes in VOC concentration which might result in increased risk
The containment options in Alternatives 2 3 and 5 would be more protective ofthe community
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320MAUINOFSWWI0030929WPD 5 - 1 HSI GSOTrSflS IflC
MITEC 104e 02415
if the region of VOC-contaminated groundwater were shown to be expanding and presenting
increased risk However in the event that the region of VOC-contaminated groundwater is not
expanding Alternative 4 would be equally protective Under all options a HASP would be
prepared and in conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Alternatives 2 3 and 5 would involve normal construction hazards during
installation of pumping wells piping trenches treatment enclosures permeable reactive barrier
trenches or planting of trees In addition under Alternative 5 release of VOCs to air through
transpiration may need to be measured to prevent creation of a new exposure pathway and health
risk through air
Environmental Impacts Minor additional impacts may occur during installation of
Alternatives 2 3 and 5 due to dust and sediment production Groundwater would need to be
treated to regulatory discharge limits before discharge under Alternative 2 and treatment may be
temporarily hampered in the event of treatment system mechanical failure Because ofthe
experimental nature of phytoremediation greater uncertainty exists that the trees will be effective
in acting as a barrier to expansion ofthe region of contaminated groundwater to the unnamed
brook under Alternative 5 If it is shown that expansion ofthe region of contaminated
groundwater toward the unnamed brook poses a future health risk additional measures may
become necessary to contain the contaminated groundwater
Time to Achieve Remedial Action Objectives None ofthe alternatives has an appreciably
shorter time frame than the others in reducing groundwater concentrations to VT Groundwater
Enforcement Standards and VT Water Quality Criteria This is because while Alternatives 2 3
and 5 rely on engineered remedies to contain the region of contaminated groundwater residual
TCE DNAPL and geologic heterogenieties will cause the contaminant source to persist for an
extended time As discussed in Section 34 active DNAPL removal alternatives were removed
during the preliminary screening DNAPL has never been directly observed at the Study Area
and is assumed to be present based on dissolved concentrations of TCE DNAPL distribution is
FOR ALLING INDUSTRIAL PARK MWP_DOCSW753200OALLINOFS9-00M0O30929wPD 5-2 HSI GGOTr3nS IflC
MITEC 104e 02416
expected to occur heterogeneously at residual saturation and it is infeasible to locate the DNAPL
to treat it directly Because of this each ofthe remedies is expected to exceed the two-year time
frame for short term effectiveness
52 R E D U C T I O N O F T O X I C I T Y M O B I L I T Y O R V O L U M E T H R O U G H
T R E A T M E N T
Treatment All ofthe proposed alternatives would treat the residual DNAPL source of
contamination through dissolution and natural gradient flushing While Alternatives 2 3 and 5
are intended primarily for containment and not groundwater restoration these alternatives would
actively treat some concentrations in groundwater
Reduction in Toxicity Mobility or Volume The containment Alternatives 2 3 and 5
may result in decreased mobility ofthe region of contaminated groundwater However
groundwater monitoring may show that the region of contaminated groundwater is not
expanding under existing conditions If this were the case containment would not result in any
additional decrease in size ofthe region of VOC-contaminated groundwater
Since Alternatives 2 3 and 5 treat concentrations in groundwater without treating the
residual DNAPL source and the amount of contaminants that can be removed from groundwater
by these methods would likely equal the amount added by continued dissolution ofthe DNAPL
sources alternatives 2 3 and 5 would not result in a greater reduction in the total volume of
contaminant than Alternative 4
Amount of Material Contained or Treated As described above the amount of material
contained under Alternatives 2 3 and 5 would not be any greater than under Alternative 4 unless
the size ofthe region of VOC-contaminated groundwater is not presently contained by natural
attenuation If natural attenuation is currently controlling the size ofthe region of VOC-
contaminated groundwater then the amount of contaminants being removed by natural processes
equals the amount added by dissolution of residual DNAPL In this case intercepting and
removing contaminants from the groundwater using one ofthe containment alternatives will not
result in a significant increase in the amount of contaminant treated
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000ALUNOFS9-OOUM30929WPD 5-3 HSI GGOTrdHS jflC
MITEC 104e 02417
53 LONG-TERM EFFECTIVENESS
Residual Risk Implementing institutional controls to maintain the sump venting at Lot 3shy
30 on South Browneil Road to restrict construction of buildings with basements below the water
table within the region of VOC-contaminated groundwater and to control the use of groundwater
for potable purposes within the region of VOC-contaminated groundwater would provide
protection against the potential for exposure to existing concentrations in groundwater
Therefore despite the fact that some ofthe remedial alternatives may be required to operate for
an extended time the residual risk associated with any ofthe alternatives would be minimal
Adequacy and Reliability of Controls Alternative 5 has the least reliable controls
because ofthe difficulty in predicting the effectiveness of phytoremediation The second least
reliable alternative would be Alternative 2 because of its reliance on mechanical equipment to
maintain containment and to meet discharge standards
Permanence of Remedy All ofthe proposed alternatives would rely on permanent
destruction of contaminants through natural attenuation over time If one ofthe containment
technologies are required maintenance and periodic replacement would be necessary to ensure
containment was maintained until expansion ofthe region of VOC-contaminated groundwater
was no longer a threat This maintenance would be straight-forward and easy to continue for any
of the containment alternatives
54 COMPLIANCE WITH ARARs
All ofthe alternatives would eventually reduce contaminant concentrations within the
current region of contaminated groundwater to below VT Groundwater Enforcement Standards
and VT Water Quality Criteria
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Each ofthe alternatives would rely on groundwater monitoring and institutional controls
on venting basement sumps at Lot 3-30 on South Browneil Road restrictions on the construction
of new basements below the water table within the region of VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWPJX3CSN7S3UOOOAUJNGFS9-OOUM30929wro 5-4 HSI GOTr3nS IflC
MITEC 104e 02418
and potable use of groundwater from within the region of VOC-contaminated groundwater to
maintain conditions protective of human health and the environment If monitoring shows that
natural attenuation is not restricting the size ofthe region of VOC-contaminated groundwater
then one ofthe containment alternatives would be more protective than Alternative 4
56 IMPLEMENTABILITY
The most easily implemented alternativewould be Alternative 4 as it would not require
any installation but only groundwater monitoring to gauge the progress of natural attenuation
Alternative 5 requires all the components of Alternative 4 and adds trees along the unnamed
brook Alternatives 2 and 3 are the most difficult to implement as they require disruptive and
invasive installation techniques However the necessary equipment materials workers and
specialists required to implement all the alternatives are available
57 COSTS
The present worth costs range form a low of $163083 for Alternative 4 to a high of
$2287474 for the containment option of Alternative 3 These present worth costs were based on
a 30-year service period and an annual discount rate of seven percent
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALLINOFS9-OOM0030929WPD 5-5 HSI GGOTfaDS IflC
MITEC 104e 02419
6 PREFERRED REMEDY
61 PREFERRED REMEDY
Alternatives 2 34 and 5 are all protective of human health and the environment and rely
on the following technologies
bull groundwater monitoring to evaluate spatial and temporal trends in VOC
concentration
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil
Road
restrictions on the construction of new buildings within the region of VOC-
contaminated groundwater to prevent unacceptable concentrations of volatile
compounds in indoor air and
institutional controls to restrict the use of groundwater for potable purposes within
the region of VOC-contaminated groundwater
All ofthe alternatives rely on dissolution and natural gradient flushing to treat the
residual DNAPL source of groundwater contamination Therefore none ofthe alternatives has
an appreciably shorter time frame than the others in reducing groundwater concentrations to VT
Groundwater Enforcement Standards and VT Water Quality Criteria
Alternative 4 includes remediation by natural attenuation There is no active containment
technology associated with Alternative 4 As such it is simpler less costly and easier to
implement than Alternatives 2 3 and 5 which include some form of active containment ofthe
region of VOC-contaminated groundwater Containment could become necessary under
Alternative 4 if future groundwater quality monitoring indicates the region of VOC-contaminated
groundwater is impacting a sensitive receptor or is expanding in size and not contained by natural
attenuation The SIR (HSI GeoTrans 2000) risk assessment (Menzie Cura 2000a and 2000b)
showed that under current conditions groundwater was not impacting any receptors to a degree
FOR ALLING INDUSTRIAL PARK MWPJXXrSN7532000ALUNcFS9-OOU0030929WO 6 - 1 HSI GSOTraflS jflC
MITEC 104e 02420
that would represent a human health risk or risk to the environment Therefore containment is
not necessary to protect any sensitive receptors currently being impacted by the region of
contaminated groundwater Continued groundwater monitoring is required to demonstrate
whether the region of VOC-contaminated groundwater is stable in size or expanding
Alternative 4 has been selected as the preferred remedy On-going monitoring ofthe
effectiveness of natural attenuation in containing and remediating the region of VOC-
contaminated groundwater is part ofthe remedy Further details on this proposed monitoring are
provided in Section 62 If monitoring shows that size ofthe VOC-contaminated region is not
contained by natural attenuation then one ofthe other technologies could be used to supplement
Alternative 4 based on the nature ofthe expansion ofthe region of contaminated groundwater
If monitoring data indicates that VOC concentrations in the groundwater discharging to the
unnamed brook have increased and pose an unacceptable risk to human health and the
environment then phytoremediation could be considered in this location Phytoremediation
would be less costly than installation of a permeable reactive barrier or active groundwater
extraction system Phytoremediation would be ineffective in containing expansion ofthe region
of contaminated groundwater in the rest ofthe Study Area however because contaminated
groundwater is further below ground surface in these regions and phytoremediation is limited by
the depth ofthe roots ofthe selected plant If monitoring data indicates that the southwestern
portion ofthe region of VOC-contaminated groundwater is expanding then Alternative 4 could
be supplemented with extraction wells or a PRB for hydraulic containment
62 MONITORING PROGRAM
In its guidance document Use of Monitored Natural Attenuation at Superfund RCRA
Corrective Action and Underground Storage Tank Sites (EPA 1999) EPA states that long-term
performance monitoring will be a fundamental component of any remedy which relies on
monitored natural attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000 A1XINOFS9-00 I0030929 WPO 6-2 HSI GSOTrSDS IMC
MITEC 104e 02421
The SIR (HSI GeoTrans 2000) concluded that there were not sufficient temporal data to
determine whether the region of VOC-contaminated groundwater was stable in size or
expanding Continued monitoring for the compounds of concern will be necessary to confirm
that the region of VOC-contaminated groundwater is not expanding Table 6-1 identifies
locations which are proposed to be monitored annually to evaluate spatial and temporal trends in
VOC concentration These locations are shown in Figure 6-1
There are several mechanisms by which natural attenuation occurs These include
dilution of contaminant concentrations sorption ofthe contaminant onto the soil matrix and
biodegradation ofthe contaminant to a less toxic form Further study is necessary to determine
the contribution of each of these mechanisms to overall attenuation ofthe area of VOC
contamination
Evidence of biodegradation can be obtained by collecting three types of data of increasing
complexity (National Research Council 1993)
bull documentation of contaminant loss or transformation in the field
bull the presence of electron donors and acceptors andor alteration of groundwater
chemistry consistent with intrinsic biodegradation processes and
microcosm studies which provide direct microbiological evidence that indigenous
bacteria are capable of mediating the contaminant transformations observed
Microcosm studies are typically not employed unless the contaminant is unique or the
transformation which is being observed is not well documented in the literature For the
transformations anticipated in the Study Area numerous laboratory and field studies have
established that naturally-occurring bacteria are capable of mediating the contaminant
transformations of contaminants of concern For that reason microcosm studies will not be
performed as part of this study
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^)OM0030929 WPO 6-3 HSI GSOTrSHS jflC
MITEC 104e 02422
Of particular concern to the determination of biodegradation is the delineation of aerobic
and anaerobic zones within the contaminant area because these zones dictate the types of
biological degradation that would be expected to occur Oxygen is the primary electron acceptor
during aerobic oxidation Anaerobic processes including denitrification iron-reduction sulfate-
reduction and methanogenesis occur in the absence of oxygen and use nitrate iron (III) sulfate
and carbon dioxide respectively as primary electron acceptors Reductive dehalogenation of
TCE has been observed under iron-reducing sulfate-reducing and methanogenic conditions
although very low redox (ie methanogenic) conditions may be necessary for production of
ethene and ethane
Further sampling and analysis of selected parameters in groundwater will be conducted to
assess the potential for biodegradation in accordance with EPAs Technical Protocol for
Evaluating Natural Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) The
twelve sampling locations shown in Table 6-1 used to monitor ofthe area of VOC contamination
will also be sampled for parameters used to evaluate biodegradation The parameters include
compounds of concern and compounds which are degradation products ofthe compounds of
concern shown in Table 6-2 Table 6-3 lists parameters chosen to evaluate the presence of
electron donors and a groundwater chemical environment conducive to biologic reductive
dechlorination These parameters will be sampled once unless evaluation ofthe data indicates
that further sampling would be beneficial to calculate a rate of attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000ALUNCFS9JraquoM0030929 WPD 6-4 HSI GSOTfaHS IDC
MITEC 104e 02423
Table 6-1 Sampling locations
LOCATION
ID
ASI-32D2
RB-1
ASI-26D2
ASI-I6D2
ASI-13D2
ASI-23D2
ASI-18D2
ASI-12D2
ASI-01D2
ASI-09D2
U-TRIB-5
SW-I
Notes BGS =
SCREENED
INTERVAL
DEPTH BGS
35-40
35-40
35-40
30-35
31-36
25-30
32-37
35-40
31-36
31-36
surface
surface
Below Ground Surface
RATIONALE
Upgradient of region of highest VOC concentrations
Closest to lot 19-11 former lagoon and septic leach field source areas
Within area of highest concentrations
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient ofthe region of VOC concentrations in the southwest direction
Downgradient of source area within region of VOC concentrations in southeast direction
Downgradient of source area within region of VOC concentrations in southeast direction
At downgradient edge of region of VOC concentrations in southeast direction
Stream upgradient of VOC discharge from groundwater
Stream at location of VOC discharge from groundwater
(
FOR ALLING INDUSTRIAL PARK MWP DOCSN7532000ALUNCFS9^X)VI0030929WPO 6-5 HSI GeoTrans inc
MITEC 104e 02424
Table 6-2 VOC analytes
PARAMETER
TCE
PCE
11-DCE
cis 12-DCE
trans 12-DCE
Vinyl Chloride
Benzene
Toluene
Ethylbenzene
Xylenes
ANALYTICAL METHOD
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
8260A
8260A
8260A
8260A
RATIONALE |
Contaminant of Concern
Contaminant of Concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
Notes SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical
Methods SW-846 US EPA 3ri edition 1986
TCE = Trichloroethene
PCE = Tetrachloroethene
11-DCE = 11-Dichloroethene
cis 12-DCE = cis 12-Dichloroethene
trans 12-DCE = trans 1 2-Dichloroethene
FOR ALLING INDUSTRIAL PARK MAWP DOCSN75320laquoMLUNOFS9^XM0030929WPO 6-6 HSI GeoTrans inc
MITEC 104e 02425
Table 6-3 Parameters to evaluate biodegradation
PARAMETER ANALYTICAL METHOD RATIONALE
Field Parameters
Alkalinity as CaCO Hach Alkalinity Test Kit Model ALP Positive correlation between microbial activity and
MG-L alkalinity Measures the buffering capability of
groundwater
Total Ferrous Iron Hach Method 8146 May indicate anerobic degradation
Dissolved Hydrogen Reducing Gas Detector Predicts possibility for reductive dechlorination
Dissolved Oxygen Direct Meter Reading Indicates probability of aerobic vs aerobic
degradation
PH Direct Meter Reading Aerobic and anaerobic biological processes are pH
sensitive
Redox potential (Eh) A2580B An indicator ofthe relative tendency of a solution
to accept or transfer electrons
Specific Conductivity Direct Meter Reading Used to determine when purging of a well for
sampling is complete
Temperature Direct Meter Reading Affects the metabolic activity of bacteria and the
solubility of dissolved gasses
Laboratory Analyses
Dissolved Organic Carbon SW 9060 Carbon and energy source which can drive
dechlorination
Nitrate-N IC Method E300 At higher concentrations may compete with
reductive pathway
Total Manganese EPA 2007 or 2009 To determine if anaerobic biological activity is
solubilizing Mn for the aquifer matrix
Chloride SW 9250 Can be used as a conservative tracer to estimate
biodegredation rates
Sulfate IC Method E300 May be used as an electron acceptor for
biodegradation after dissolved oxygen and nitrate
are depleted
Sulfide IC Method E300 Indicates if reductive pathway is possible
Ethane SW 3810 Modified Daughter product of Ethene
Ethene SW 3810 Modified Daughter product of Vinyl Chloride
Methane SW 3810 Modified Ultimate reductive daughter product
Notes Rationales taken from USEPA 1998
Hach refers to Hach Company Catalogue
A refers to Standard Methods for the Examination of Water and (fostewater 18 edition 1992
E refers to Methods for Chemical Analysis of Water and Wastes US EPA 1983
SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical Methods SW-846 US EPA 31 edition
1986
FOR ALLING INDUSTRIAL PARK | C I nr A^Twmrmr bullbullltlaquo MWP DOCSN7532000ALLINCFS9-0Ol0030929wro 6-7
MITEC 104e 02426
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REFERENCES
Brinkerd 1996 Site Investigation Ailing Industrial Park Williston Vermont April to
September 1996 October 1996
Fitts C R 1997 TWODAN documentation prepared by Dr Charles Fitts Scarborough Maine
Griffin 1995 Monitor Well Log (MW-4) and Analytical Data Bove-Fagan Ice Cream
Distribution Investigation Williston VT Griffin International Inc
HSI GeoTrans Inc 2000 Site Investigation Report June 15 2000
Johnson 1999 Limited Groundwater Investigation N753 July 6 1999
Menzie Cura 2000a Screening Level Risk Characterization April 2000
Menzie Cura 2000b Addendum to Screening Level Risk Characterization June 1 2000
NRC 1993 National Research Council Committee on Bioremediation In Situ Bioremediation
When Does it Work Washington DC National Academy Press 1993
TRC 1993 Site Inspection-Ailing Industrial Park Williston Vermont VTD982748477 Final
Report
US EPA 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies
Under CERCLA OSWER Directive 93553-01
U S EPA 1992 Estimating Potential for Occurrence of DNAPL at Superfund Sites OSWER
Number 93554-07FS 9p
FOR ALLING INDUSTRIAL PARK MWP_DOCSW75JV20(XKALUNOFS9-0(AI0030929WPD 7 - 1 HSI GeOTTSHS irtC
MITEC 104e 02428
US EPA 1993 Guidance for Evaluating the Technical Impractibility of Groundwater
Restoration EPA540-R-93-080
US EPA 1998 Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents
in Ground Water EPA600R-9812~8
US EPA 1999 Use of Monitored Natural Attenuation at Superfund RCRA Corrective Action
and Underground Storage Tank Sites EPA Directive 92004-17P
US EPA 2000 Introduction to Phytoremediation EPA600R-99107
VTDEC 1996 Site Investigation Guidance August 1996
VTDEC 1997 Chapter 12 Groundwater Protection Rule and Strategy October 1997
VTDEC 2000 Vermont Water Quality Standards March 2000
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(AAUJNGFS9^)OM0030929WPD 7-2 HSI GSOTfanS tC
MITEC I04e 02429
APPENDIX A
TWODAN INPUT FILES
FOR ALUNG INDUSTRIAL PARK MWP_DOCSVN7S3200(AALUNOFS9-0(AI0030929WPO HSi GfiOTfanS WC
MITEC 104e 02430
i - i i a a o U 0 t A X H i d t l Z 018J UaiUEAJJLKATia Htj v j pound
50-oo
4 e s y lt lt 4 A M ^ L S m m 9 m mdash t j y m
MITEC 104e 02431
15
6 Lancaster County Road HSI Harvard Massachusetts
GEOTRANS 01451 A TETRA TECH COMPANY 97^772-7557 FAX 978-772-6183
R E C E i ^ D PNN753-001
CUTLER A8TANPIELD Campltf December 11997
Mr Michael Smith Vermont Department of Environmental Conservation Waste Management Division 103 South Main Street Waterbury VT 05671-0404
Subject Proposed Surface Water Sampling MITEC Site Williston VT
Dear Michael
This letter describes the proposed surface water sampling at the MITEC site that we discussed during our meeting of November 201997 Our intention is to complete this work as soon as possible to avoid the complications of colder weather and possible freezing ofthe stream My understanding is that you are prepared to review and approve this plan fairly quickly and also to assist us with obtaining property access and appropriate maps to locate these sampling sites We appreciate this help In future we anticipate that the constraints of weather will not require such an expedited field mobilization process and that we will all have more time to prepare
Purpose and Extent of Sampling
The purpose ofthe surface water sampling is to further assess impacts to the unnamed tributary and to make preliminary inferences regarding the extent ofthe TCE plume currently migrating to the southeast across the Ailing Industrial Park by measuring the effects of its discharge to the stream To this end sampling locations have been chosen to 1) provide better spatial resolution in the area east of Commerce Street toward its southern end (SW-1 SW-2 SW-3 and S W-5) 2) assess the quality of surface water contributed by other tributaries (SW-4 SW-6) and 3) make preliminary estimates ofthe downgradient extent of impacts (SW-7 and SW-8) Samples from previously established sampling locations UTrib-6 7 8 1014 and 18 will also be obtained A total of 14 samples will be collected The proposed sampling locations
L-W7jni20iiooonl
MITEC 104e 02432
Michael Smith 2 December 11997
are indicated on the attached maps which depict the site at two different scales The first is a site map taken from the Binkerd report and shows the previous sampling locations east of Commerce Street as well as proposed new locations SW-1 SW-2 and SW-3 The second map shows the site and the surrounding area including the more downstream locations
Methods
At each proposed location a number of water quality indicators will be measured including temperature pH redox potential dissolved oxygen and conductivity Samples for volatile organic compound (VOC) analysis will be obtained in triplicate using a stainless steel sampling container samples will be transferred immediately to 40 mL glass vials with teflon septa and preserved with hydrochloric acid Each sample will be submitted to a local analytical laboratory for a screening level analysis of VOCs Three selected samples will also be analyzed using EPA Method 8260 The appropriate level of documentation will be generated for these samples such that laboratory analytical results can be validated to EPA Region 1 level Tier II This will require the collection and analysis of a duplicate sample a trip blank a field blank and matrix spikematrix spike duplicate samples
Sincerely
f i t mdash Peter ZeebPhD Senior Hydrogeologist
cc Sandy Feldman Sheila Jones
PZmm
m w MITEC 104e 02433
HSI GEOTRANS
LEGEND O Honrtorog Veil
A GeoProb Sortg
Figure 11 Station location map O Surface Water
Qfor monitoring wells borings and surface water MITEC 104e
02434
HD BINKERD ENVIRONMENTAL
HSI bull bull
GEOTRANS if prsTAOC
6 Cancaster County Road
A TETRA TECH COMPANY
Harvard Massachusetts 01451 faL32 HMETER 3 4 r t
Sheila Jones Esq Cutler and Stanfield 700 Fourteenth Street NW Washington DC 200052010
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Harvard Massachusetts 01451 GEOTRANS
A T E T R A T E C H C O M P A N Y 978-772-7557 FAX 978-772-6183
PN N753-002
May 111999 RECEIVED
MAY t 3 1999 Mr Michael Smith
CUTLER ampSTANrlc-uAgency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Dear Mike
Based on the site walkover and well inventory ofthe existing monitoring well network completed on April 201999 HSI GeoTrans determined that several monitoring wells proposed for sampling and monitoring in the Work Plan are not accessible or are damaged or missing Outlined below are the actions we will undertake to resolve the outstanding issues with the monitoring well network
As ofthe date of this letter access to the Bates well network has not been obtained The Work Plan identified eleven off property well clusters installed by the Bates and two wells installed by the State on the Bates property to be included in the sampling and monitoring activities for the Site Investigation (BW-2 BW-5 BW-7 BW-8 BW-9 BW-11 BW-12 BWshy13 BW-17 BW-18 BW-19) Ten ofthe off property clusters were included in the sampling plan and all eleven were included in the site water level round The wells installed by the State on the Bates property were included in the both sampling and water level rounds Replacement of eight ofthe well clusters slated for groundwater sampling is recommended (BW-5 BW-8 BW-9 BWshy12 BW-13 BW-17 BW-18 BW-19) The remaining Bates wells do not require replacement in order to achieve the goals ofthe Site Investigation Note that two ofthe original well clusters in the Work Plan BW-17 and BW-18 have been destroyed and would require replacement even if access is granted by Bates In addition HSI GeoTrans well clusters had already been proposed adjacent to BW-2 BW-7 and BW-11 and will provide the required data at these locations
It is our understanding that the two monitoring wells installed by the State on the Bates property JB-1 and JB-2 are accessible to the State for sampling and water level monitoring and that the State will sample and monitor these wells to fulfill the goals ofthe Site Investigation IF this is not the case please let me know at your earliest convenience
M WP DOCS NT^VWMiSimbW wpd
MITEC 104e 02438
Mr Michael Smith 2 May 11 1999
Several ofthe remaining wells (BF-1 BF-3 NO-2 and OE-1) were observed to be damaged during the inspection We propose to repair the wells which have been damaged The repairs will involve installation of protective casing or road boxes re-development and reshysurveying of the new measuring points The other wells are missing and presumed destroyed (ARC-2 ARC-3 BF-2 BM-2 MB-1 PO-SOUTH and RB-1) We believe that only monitoring wells MB-1 and MB-1 A require replacement The remaining wells that could not be located during the site inspection do not require replacement in order to achieve the goals ofthe Site Investigation
Based on our telephone conference on May 10 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MWgt_DOCSN753l9Wlaquo310l600raquopd M l 1 XA ~r
02439
HSI GEOTRANS
Mr Michael Smith 3 May 11 1999
bcc Sheila Jones
snwp_DocjN7sni9wcmoi6i)iraquoplti TVflTEC 1046
02440
HSI GEOTRANS
X_l ^ T 6 Lancaster Countv Road
Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-11 i 5
PN N753-002
June 25 1999
Mr Michael Smith Agency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Work Plan Modifications Ailing Industrial Park Site Williston VT
Dear Mike
This letter documents changes to the work plan for the Ailing Industrial Park Site in accordance with a telephone conference between you myself and Peter Zeeb On the results of the Site Investigation to date as well as additional data collection by the DEC we agreed that several revisions to the work plan are warranted The revisions for the work plan include the location and method of installation for the bedrock monitoring wells and the sampling of shallow monitoring wells recently installed Outlined below are the revisions to the specific tasks that we will undertake
Re-location of Bedrock Monitoring Weil BR-1
The DECs Source Area investigative work in the original location of BR-1 identified high levels (100 mgL) of VOCs present at or near the silt clay interface DEC believes that drilling through the clay layer in this location creates an unacceptable risk ofthe migration of contaminants into the underlying units HSI GeoTrans will relocate the bedrock well BR-1 adjacent to ASI-16 as located on the attached site plan
Bedrock Well Installation Method
Geophysical work at the site has refined our estimation of the depth to bedrock Depth to bedrock was initially anticipated to be greater than 150 feet below ground surface We currently anticipate bedrock at 100 to 140 feet below ground surface The shallower depth to Bedrock will
M AWPDOCStfnSIMnWUJIIW mft
MITEC 104e 02441
Mr Michael Smith 2 June 25 1999
enable us to reduce the size ofthe pilot hole needed for the well installation At locations BR-1 and BR-2 drillers will advance and set 4 in casing several feet into the clay unit and chop and wash the annulus ofthe casing All cuttings and wash water will be contained for proper disposal The casing will be refilled with potable water and the hole will be advanced with a 3 in roller bit When telescoping becomes necessary to prevent caving 3 in casing will be installed The 3 in casing will be advanced to the bedrock surface and seated The coring of bedrock will follow the original work plan specifications
Shallow Monitoring Well Sampling
The field GC water quality data obtained during small diameter installation at the site has demonstrated that contaminant concentrations in the upper portion ofthe aquifer to be low (lt 10 MgL) or non-detect in most locations This has led to the revision of our sampling plan Select shallow wells will be sampled to confirm the field GC data If these data are confirmed the low level and none detect shallow wells will not be sampled The shallow wells to be used for confirmation sampling are listed below
ASI-01 ASI-02 ASI-03 ASI-05 ASI-08 ASI-10 ASM 2 ASI-08
Based on our telephone conference on June 24 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MXTECl04e 02442
HSI GEOTRANS
Mr Michael Smith 3 June 25 1999
bcc Sheila Jones
MITEC I04e
02443
HSI GEOTRANS
1 0 T 2 shyCylty
T-TCT 6 Lancaster County Road _ _ _ Harvard Massachusetts
GEOTRANS OH 5 1
A TETRA TECH COMPANY 978-772-7557 FAX 978-772-6183
PN 753-010
July 9 1999
Mr Michael Smith Agency of Natural Resources Vermont Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Bedrock Monitoring Well Installation Ailing Industrial Park Site Williston VT
Dear Michael
On July 8 we became aware that a drill casing was advanced through the sand clay and till strata at the Ailing Industrial Park (site) without being sealed at the sandclay interface Although for the reasons described below we do not believe any vertical migration of contaminates occurred this method of drilling is contrary to the work plan for the site Therefore we are notifying you of this incident
On June 4 shallow direct push monitoring wells were installed at location ASI-06 where a deeper bedrock monitoring well is planned Groundwater quality profiling data from this location is provided on the attached boring log TCE is present in groundwater here at concentrations as high as 2270 ugl at 31 - 36 ft below ground surface (bgs) decreasing to 262 ugL at 41 - 44 ft bgs A soil boring (D-2) was advanced at this location on June 22 Field screening data from soil samples obtained in this boring are also provided on the attached log As apparent from the log fine to medium sand occurs to a depth of approximately 15 ft at this location grading to silt at depth A clay layer is encountered at 40 ft bgs Glacial till is present from 57 to 100 ft bgs where the bedrock surface is located Prior to drilling through the clay and glacial till a direct push well screen was advanced through the clay and into the till to a depth of 58 bgs and no groundwater recharge to the well screen occurred at any of five sampling depths
MWP_DOCSN753 199M7M1600 wpd
MITEC 104e 02444
Mr Michael Smith 2 July 9 1999
Drilling of bedrock monitoring well BR-2 began on June 29 Four inch casing was advanced to a depth of 44 ft and sealed within the clay layer Three inch casing was then advanced through the till layer to the bedrock surface During seating ofthe casing in the bedrock the casing was damaged and was subsequently withdrawn from the borehole
On July 7 a different drill rig was used to continue drilling the same location In accordance with both the drillers proposal to HSI GeoTrans and the work plan for the site investigation the driller was to seat a casing in the clay establish a seal and drill through the clay and till with smaller casing prior to coring bedrock Instead the drilling contractor withdrew the previously installed four inch casing without grouting it changed the drive shoe on the casing to a spin shoe and advanced the four inch casing directly to the bedrock surface Upon arrival at the site to log the coring of bedrock on July 8 HSI GeoTrans ascertained that the borehole had not been sealed at the clay surface prior to drilling deeper as was specified HSI GeoTrans then instructed the drilling contractor to immediately remove the casing and to seal the borehole with grout in the process
It is our intention to have a new drilling contractor complete the installation of BR-2 at an adjacent location in a manner that limits the potential for introducing contaminated unconsolidated deposits groundwater to the bedrock as specified in the work plan for this site investigation Within one week of completing the installation of BR-2 groundwater quality data collected from BR-2 will be evaluated with respect to the potential for contaminant migration along the unsealed borehole that existed at this location for approximately 24 hours As the casing was advanced by spinning providing a relatively good seal between the casing wall and the formation we do not anticipate that vertical migration along the casing was significant
If you have any questions regarding this letter please contact me at (978) 772-7557
Sincerely yours
Peter Zeeb PhD Senior Hydrogeologist
PZcas
MWP OOCSVN7S3M999070ll600wpri
MITEC 104e 02445
HSI GEOTRANS
1 HSI | 9pound9TPpoundSpound SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
LOCATION Williston VT CASING TYPEDIAMETER None
DRILUNG METHOD Drive and Wash Direct Push SCREEN TYPESLOT None
SAMPLING METHOD ss shelbv GRAVEL PACK TYPE None
GROUND ELEVATION GROUT TYPEQUANTITY Bentonite Portland Slurry
TOP OF CASING DEPTH TO WATER
LOGGED BY NSB GROUND WATER ELEVATION
REMARKS This log compiles the results o the all methods used to comolete the borehole over its entire depth
gtshyci IT UJ t o UJ E t shygt z L oi lti LITHOLOGIC DESCRIPTION 3Q O bdquo a UJ lt a ca sect 1a UJ
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Light olive Brown SILT w trace fine sand wet poorly - 1 5 shy graded
O2-SS02 4 7 11 8
A7
6 7
- 2 0 shy Dark greenish Grey SILT wet poorly graded
O2-SS03 2 0 41 1
WOR WOR l
D2-SS04 2 4 2 X - 2 5 shy4
D2 13 1159
3
1 D2-SS05 2 5 39 v
WOR AWOR WOR - 3 0 shyD2-SS06 4 921 WOR
XWOR WOR
02-SS07 8 2270 1
X1 2 3
Continued Next Page 1 OF 3 02446
HSI GEOTRANS SOIL BORING LOG BR-02 A T E T R A T E C H C O M P A N Y
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
9 gtshyOC
UJ - j a
UJ gt o ^ r-6 LITHOLOGIC DESCRIPTION
ui
CD U UJ S oc =
o o
uj _ Q pound iT O
o
Medium Grey dayey SILT wet poorly graded
D2-SS09 4 S
28 1572
3 6
D2-SS10 WOR 1 18 13
4 6
D2-SS11 3 3 20 NO Medium Grey CLAY wet poorly graded 262
4 5
BR2-SS01 1 2 20 ND Soft Olive Grey CLAY moist laminated coheisive 2 4
BR2-SS02 20 NO
- 5 0 -
BR2-SS03 20 NO - 5 5 -
Dense Light olive Grey sandy GRAVEL w few fines
BR2-SS04 16 19 24
ND
bull60
moist poorly graded
21
Very dense Light olive Grey gravelly SAND w little fines moist well graded angular
BR2-SS05 40 51
13 ND 6 5 shy
60 66
I-7 0 shySO BR2-SS06 11 ND 50 100
5000
MITEC 104e 02447
Continued Next Page PAGE 2 OF 3
HSI GEOTRANS A T E T R A T E C H C O M P A N Y SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
a UJ
Q
05
i i m u
gt ac ui gtO bdquo UJ 3 oc S
o o
0 CO UJ _ Q pound LL C5
LITH0L0GIC DESCRIPTION 9 LU O
BR2-SS07 81 1004
10 NO E 8 0 shy
BR2-SS08 30 59 68
16 ND w8 5 shy
BR2-SS09 1005 NO 9 0 shy
BR2-SS10 89 1944
ND E bull95shy
- 1 0 0 shyND
Limestone
MITEC 104e 02448
PAGE 3 OF 3
Mr Michael Smith 3 July 9 1999
bcc Sheila Jones bcc Jerry Amman
MWPJXXSN753M9MW70J160Owpd
MITEC 104e 02449
6 Lancaster Countv Road HSI Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6 I i 5
PN N753-014
Septembers 1999
Mr Michael Smith Agency of Natural Resource Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in die Site Investigation Ailing Industrial Park Williston IT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and die Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation ore outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste waler lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot IV-11 using small-diameter wells and afield GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
bull perform one day ofwellpoint permeability testing at selected monitoring wells
mwFDocwsiMwwwnoootd MITEC 104e 02450
Mr Michael Smith September 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
M l T ECl04e 02451
U laquo OOCTN791Mtm01IOOOraquofrl
HSI GEOTRANS
HSI GEOTRANS
6 Lancaster County Road Harvard Massachusetts
01451
A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6183
PNN753-014
Septembers 1999 amp y gt
Mr Michael Smith D oJ Agency of Natural Resource Km Jt Department of Environmental Conservation i j f i l Waste Management Division ft y^y( 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park ft Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and the Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation are outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
bull perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste water lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot 19-11 using small-diameter wells and a field GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
MITEC 104e perform one day ofwellpoint permeability testing at selected monitoring wells 02452
000060 MlWP_OOCSN73Iirmraquo01|rngtlaquo|gtl
Mr Michael Smith Septembers 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
MITEC 104e 02453
000061 Mwr_cocS4miinmogtmoltsri
HSI GEOTRANS
T T Q T 6 Lancaster County Road ^ Harvard Massachusetts
GEOTRANS laquolaquo A TETRA TECH-COMPANY 978-772-7557 FAX 978-772-6183
PNN753-014
October 151999
Mr Michael Smith vZ Agency of Natural Resource J Department of Environmental Conservation Waste Management Division I 103 South Main StreetWest Building j Waterbury VT 05671-0404
Re Ailing Industrial Park Source Area Investigation
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants Evaluation of field data has determined the extent ofthe dissolved phase contamination migrating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) HSI GeoTrans will begin a Source Area Investigation on October 181999 to determine the nature and areal extent ofthe suspected contaminant source The investigation will be undertaken to gather the data necessary to complete the Site Investigation Report and the Feasibility Study which was set forth by the Agreement Between Mitec Telecom INC and Vermont Concerning the Ailing Industrial Park (1999) The Source Investigation will focus on the property owned by Beatrice Ailing and former MITEC lease hold (Lot 19-11 Williston plat map) and the area ofthe Ailing Industrial Park which has exhibited elevated contaminant concentrations during Site Investigation activities We are submitting this letter to The Vermont Department of Conservation(VTDEC) as an addendum to the approved Site Investigation Work Plan The addendum Source Investigation Work Plan will outline the tasks and methodologies to be utilized during the investigative work
Jack Guswa and I met with you on September 101999 to present the plans to investigate the suspected source area in the Ailing Industrial Park You agreed with the additional work as presented with the addition of two upgradient wells to be located to the west ofthe suspected source area (Figurel-1 ASI-30 and ASI-31) The VTDEC also agreed during the meeting to arrange access to the property for the Source Area Investigation The VTDEC and HSI GeoTrans were subsequently granted access to the property on September 111999 In addition to the work presented at the meeting it is necessary to preform a 72 hour pump test to characterize the
000054 MwrDOCSW79JimMOUIIOOpd
MITEC 104e 02454
Mr Michael Smith 2 October 151999
hydrologic conditions at the site The additional Source Area Investigation activities to be undertaken are presented below
Site Reconnaissance Ground Penetrating Radar (GPR) Survey Monitoring Well and Soil Boring Installation Low Flow Groundwater Sampling Hydraulic Characterization
The additional field work attributed to the Source Area Investigation will follow the standard operating procedures presented in the approved Site Investigation Work Plan (HSI GeoTrans 1999) The locations ofthe proposed well cluster installations and GPR survey are presented on Figure 1-1 The well cluster locations presented in Figure 1-1 were finalized during the September meeting between HSI GeoTrans and the VTDEC The GPR survey and hydraulic characterization tasks are presented below The Source Area Investigation field work will be completed within two week after its initiation The task specific outlines are presented below
Site Reconnaissance
The monitoring wells to be included in the site reconnaissance are monitoring wells MI-1 MI-2 MI-6 and RB-2 The monitoring wells on Lot 19-11 will be surveyed to a common datum with the existing site wide survey data Well integrity testing consisting of depth to bottom water level and visual inspection ofthe wells will be preformed Groundwater samples will be collected from selected monitoring wells based on the integrity testing Samples will be collected by the Low Flow Protocol set forth in the Site Investigation Work Plan (HSI GeoTrans 1999)
GPR Survey
A GPR survey will be preformed to identify on-site leach field septic tank or cesspool location remnants of waste water lagoon and any other subsurface anomalies We propose to use a 5 foot by 5 foot orthogonal grid survey to detect any near surface anomalies which exist on Lot 19-11 Geophysics GPR International will be performing the survey and will be utilizing a GSSI SR10 ground penetrating radar system with a high resolution 500 MHz antenna and a deep-penetration 100 MHZ antenna Any GPR response which indicate buried metal objects will be investigated with a Fisher TW6 pipe locator to augment the radar data All data will be analyzed in the field by GPR personnel and presented to HSI GeoTrans field personnel to determine the optimal location for well cluster ASI-28 If several anomalies are detected the VTDEC and HSI GeoTrans will evaluate the anomalies and modify the work plan accordingly
Well Installation and Soil Boring Advancement MITEC 104e 02455
The well clustes will consist of a small diameter shallow monitoring well and a deeper conventional well screened across the zone of highest concentration Well cluster installation will be performed in accordance with the Site Investigation Work Plan (HSI GeoTrans 1999) yjth 0 0 5 5
MWP_DOCSK731IW9M OOSIIOOprl
HSI GEOTRANS
Mr Michael Smith 3 October 151999
the exception ofthe deep wells The site conditions observed during previous field work prohibit the use of standard commercially available screen slot sizes The deep wells will be advanced by a large diameter Geoprobereg rod and installed using an outer filter sock to prohibit the infiltration offine sediments in to the well The well cluster installations will be performed jointly by Checkpoint Environmental and Twin State Environmental HSI GeoTrans will be provide oversite ofthe contractors and analysis of groundwater samples using afield Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999) The rationale for the selected well cluster locations is presented below
Monitoring well clusters ASI-25 through ASI-27 are located down gradient ofthe suspected source area The well clusters will be installed to more adequately define the areal extent ofthe concentrated portion ofthe contaminant plume A single soil boring will be advanced at location ASI-26 The soil boring will be screened as it is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-28 will be located after the GPR survey has been completed shyThe cluster will help define the suspected source area and the vertical migration of contaminants in the area The location will be determined in thefield after review ofthe GPR survey is completed The location will be based on any anomalies observed in the GPR data A single soil boring will be advanced at location ASI-28 The soil will be screened with a Flame Ionization Detector as the soil boring is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-29 will be located upgradient ofthe suspected source area The cluster will define the upgradient boundary andor any additional upgradient source areas The ASI-29 well will be paired with the existing shallow monitoring well AL-14
Monitoring well clusters ASI-30 and ASI-31 will be installed to the west cross gradient from the suspected source area to document the areal distribution of dissolved phase contamination emanatingfrom the Ailing Industrial Park The locations selected for these wells should define the northwestern and western extent of contamination
Low Flow Sampling
The additional monitoring well clusters will be sampled in accordance with the approved Site Investigation Work Plan (HSI GeoTrans 1999) Lowflow sampling procedures will be used to sample the newly installed deep wells in their respective clusters ASI-25 through ASI-31
MITEC 104e 02456
000056 MWP_DOCSgtK15JlWMOWllltraquoraquoprl
HSI GEOTRANS
Mr Michael Smith 4 October 151999
Hydraulic Characterization
HSI GeoTrans will conduct a 72 hour pumping test on the deep well at cluster ASM 2 The test is being undertaken to more adequately characterize hydraulic conditions at the site The data from this test will be used in the evaluation of remedial alternatives in the Feasibility Study The pump test will be performed as a step-drawdown test The pumping rates will ultimately be determined in the field from observed conditions Preliminary calculations indicate that pumping rates of 2 5 and 10 gallons per minute will be necessary to achieve the desired drawdown at observation wells The water level data will be recorded at observation wells ASI-06 ASI-13 ASI-25 ASI-26 NO-1 NO-2 and NO-3 The water level data will be recorded using pressure transducers and dataloggers
The effluent water from the pumping test will be treated by liquid phase granular activated carbon filters provided by Carbtrol Inc Two 175 pound carbon filters will be connected in series to treat the pump test effluent The effluent will be discharged to the unnamed brook upon approval from Randy Bean ofthe VTDEC The effluent will be periodically sampled between the carbon units and at the discharge point to detect break through ofthe carbon units The effluent samples will be analyzed utilizing a field Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999)) If the effluent sample between the carbon canisters exceeds 1000 ugL Trichloroethene (TCE) the discharge point sample will be analyzed If concentration of TCE in the discharge point sample exceed 300 ugl the test will be discontinued
We hope that this letter addendum to the Site Investigation Work Plan for the Source Investigation is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJmm MITEC I04e
02457
000057 MWFDOCSN731imu00SI 100 bullpd
HSI GEOTRANS
JHSTUART March 1 1985
Agency of Environmental Conservation D e partment of Water Resources und
E nvironmental Engineering H a z a r d o u s Materials Management Program A t t n John A m i d o n H y d r o g e o l o g i s t M o n t p e l i e r Vermont 05602
R e M I T E C Systems Corp W i l liston
Dear J o h n
During our meeting at MITEC on February 20th you noted that some additional information was needed to c omplete the initial phase of testing as well as the d o c umentation of the activities under takentodate Outline d~ beTow-Ts ~t h e~1 n f o r m a ti o n t h a t y o u r e q u e s t shyed
1 Attac hed here to is the plan used to install the grou ndwat er moni t o r s collection and analysis of the grou ndwa t er samp les for metals and organics and the extr actio n of and testing of soils from the area of the dispo sal site 2 A rev ised sit e pla n has been incl uded refl ecting the new well posi tions and the e leva t ions of t he top of t he mo ni to r s and th e groundwa ter 1e vels as of F e shybr ua ry 0th As note d in our m ost r ecent tel ephone conv i on th e lat ter have r isen 14-15 inc hes as er sa t the It o f th e rec ent thaw Two copie s of the resu plan be f orw ar ded to Winslo w Lad ue as req uested will and pla ns t 0 sur vey all ho uses on Br owne 11 Rd MITEC _tp tain if there are ajiy shallo w wel I sources ltis ce r with e dr aina ge ar ea a f fecte d by the 1agoo n in th 3 ngla nd Ma r ine C o m r a c t o r has been con tacted New E for remo va 1 of th e lagoon soil a nd co ntra c tural the ar ra nts wil 1 be concluded du r ing t he comi ng ngeme week if ic at io n of work comme nceme nt wi II be proshy Not vide your off ice i n advance d to t m Resul t s of th e met als and or genies are expected shor tiy
f rom IEA and will be fo rwarded to your ofshyf ice oon as a va i la ble as s 5 R esul t
s fr om t he pr e vious soi 1 and water sampling have inc 1 ude d bee n
CIVIL 4 EfViROUMEI-L pound l j i t fcHpound P ) OGA lt i f r l h r l h w i l l n-- i i U - iO l i l ) bU i l I
MITEC 104e 02458
s
MITEC Page 2 March 1 1985
If you have any questions please do not hesitate to contact me
Stuart PE
JHSocc
MITEC 104e 02459
MITEC Systems Corporation Williston Vermont
Soil and Water Sampling Program
1 Install groundwater monitors at nine (9) locashytions consisting of two (2) inch inside diameter PJpound with ten (10) feet of factory slotted pipe extending into the groundwater and terminating with a minimum of two (2) feet above ground level and capped
2 Establish elevations of the groundwater monitors for the top of each pipe and the groundwater elevashytion for each for a specific date Due to the shalshylow depth to groundwater from 51-112 inches the level is established by graduated tape and a light Each measurement will be performed a minimum of three times to assure accuracy to within one-eighth inch The location of each well and the established elevations will be represented on a general site plan showing the MITEC property
3 Groundwater samples are to be collected from each well on the same date by pump or baling Prior to - k ~ -~-|1bdquo--bdquobdquo f bdquo k bdquobdquobdquobdquobullbdquo ltv~ 11 1 1 v bdquo bdquo bdquo
acidification for metals preservation to assure ac curacy of the test results All samples are to be analyzed for copper cadmium nickel cyanide pH conductivity total chromium and hexavalent chrome
U Soil samples are to be collected as follows
GWM09 Saturated zone (aaprox 5) Overburden East side lagoon Composite from
two holes 5 apart-at-1 bullbull2 bullbull A below the-sur=mdash face and one in the saturated zone
North wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface 1 into the saturated zone
South wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface I1 into the saturated zone
Bottom of lagoon Composite offour test holes 8 apart one in the unsaturated zone
MITEC 104e 02460
MITEC Sampling Program
All samples are to be analyzed for the same constituents as required of the water testing
5 Collect separate samples of the groundwater after the above referenced purging process for storage in air-tight vials The samples which are to be colshylected from wells A-9 with only 5 and 7 analyzed initially by the GCMS- EPA method 62A If organics are detected in the first samples testing must be performed on 4 and 8 as well
6 All sampling will be performed with a State repshyresentative on-site and results of the testing to be forwarded to the State as soon as available
7 The contaminated soil within the lagoon will be removed by a Vermont certified contractor for disposhysal in an approved wastedepository The top one (1) foot of soil from the flood level and below will be extracted during the process
MITEC 104e 02461
i
o H
ON f J
o
bull I I bull
HA
OOO
x x z
bull
MITEC 104e 02463
WK miui w ci ivnui II i ici ILUI ujiyitb inc iii PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5108
ANALYSIS REPORT
Customer j H S c u a r t Associates Date 26 February 1985
Address P gt 0 gt B o x 3 6 7 Date Samples Received
Ci ty S t a t e Zip Essex Center VT 05A15 20 February^1985
Customer Order Nomber
Attent ion J o h n S t u a r t
Station 9
J
2
3
A
5
6
7
8
9
poundH
5A
58
52
5A
A5
53
53
55
59
j MITEC
Conductivity U mbos ( 25degC)
206
A18
21A
176__
208
230
205
16A
265
GROUNDWATER ANALYSIS
O01 0 OS bull
Cadmium Total Chromium (mRl) (mRl)
0A1 lt0025
006- 270
00A 012
bull005 189
005 023
001 lt0025
lt0C Hexavalent Chromium (mKI)
bull
lt0025
239
005
183
lt0025
lt0025
ampo
Zinc (mKl)
005
0A0
032
015
OU
003
Note Organic analyses to follow in two weeks
cc John Amadon
Signature jJfcrryyS 7lrifrylC
Offices ond loborotones located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02464
if jsznoi U hnvironmentol jiolysts Inc PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5138
ANALYSIS REPORT
Customer J H Stuart Associates Date 21 December 1984
Address PO Box 367 Date Samples Received 14 December 1984
City State Zip Essex Center VT 05451 Customer Order Number
Attention John Stuart
WATER ANALYSIS
PH 52 57 50 53 45 34
Conductivity (pmhos 25degC) 213 420 152 167 202 bull 225
O l Cadmium (mgl) lt001 lt001 001 v 028 bull 005 003
o pound Chromium Total (ng1) lt0025 lt0025 lt0025 lt0025 2-35 v 014 - -bullbull - bull - -bull V 013 bull^Chromium Hexavalent (mgl)1 0 11
gt1p Copper (mgl) lt002 lt002 lt002 lt002 bull 084 004
Q Cyanide (mgl) lt0005 lt0005 lt0005 lt0005 bull -lt0005 lt000E
Z Nickel (mgl) lt0025 lt0025 lt0025 lt0025 bull 010 003
fO 2inc (mgl) 0J1 UU1 0U3 001 038 030
Hexavalent chromium was only analyzed when total chromium was present
Signature fmnigt Mji fnt f VncL 7
Offices and laboratories located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02465
bull i
ANALYSIS REPORT
Customer J H Stuart Associates Date 22 January 1985
Address PO Box 367 Date Samples Received 14 December 1984
Ci ty State Zip Essex Center VT 05415 Customer Order Number
Attent ion John Stuart
bull shy
bull bull mdash bull bull bull bull bull - bull bull bull bull shy SOIL ANALYSIS1
Hexavalent Cyanide Chromium Chromium Cadmium Copper Nickel Zinc
poundH bull (mgl) (mgl) (mq1) bull (mq1) (mq1) (mgl) (bullmgl) -
2 442 lt0005 lt0025 lt0025 lt 001 lt 002 015 006
4 402 lt0005 lt0025 lt0025 lt 001 lt 002 lt002 001
7 504 lt0005 lt0025 lt0025 lt001 lt002 lt002 001
8 486 lt0005 lt0025 lt0025 lt001 lt002 lt002 bull 008
9 441 lt0005 lt0025 lt0025 lt001 lt602 lt002 004
10 444 0005 lt0025 lt0025 lt001 lt002 lt002 006
11 498 lt0005 lt0025 lt0025 lt001 003 lt002 009
30 532 lt0005 lt0025 008 lt001 005 lt002 010
31 544 lt0005 lt0025 lt0025 lt001 002 056 003
32 472 lt0005 lt0025 lt0025 lt001 lt002 024 003
36 536 0008 lt0025 011 lt001 005 lt002 011
37 490 lt0005 lt0025 lt0025 lt001 021 lt002 009
38 391 lt0005 0276 032 lt001 050 lt002 011
41 416 lt0005 0108 018 001 229 lt002 o5i
42 395 lt0005 0399 041 lt001 039 lt002 014
i
Signature Ltrf(7( ni W0 6M Analysis of EP toxicity extract
Offices ond loborotoriei locoted in Essex Junction Vermont Reseorch Triongle Pork North Corolino
MITEC 104e 02466
JHSTUART
A p r i l 2 9 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Hazardous Waste Materials Program Attn Cedric Sanborn Environmental Engineer Montpelier Vermont 05602
Re Mitec Systems Williston
Dear Cedric
I was phoned by David Gee today and informed that a truckload of the contaminated material was removed from the lagoon area as the result of a previous commitment entered into by Mitec Due to conflicting information about Mitecs responsibilities at this juncture I am recommending that any further work cease until a realistic program be agreed to by both parties I base that on the following
1 Following the trial pre-hearing the State was inshystructed to contact Mitec to develop a schedule for further dialogue and actions connected with the reshyhabilitation of the lagoon site To my knowledge there has not been any such attempt made on the part of the State to resolve issues that need clarificashytion
2 On April 18th I forwarded a letter to you outlinshying some new information with recommendations That correspondence has not been addressed yet Mitec has been ordered to continue with the soil removal
3 A letter from John Amadon on April 23rd notes the organic sampling to be invalid due to the time lapse and the method of storing the samples We do not take issue with this position however there is apshyparently some question about the validity of the GCMS method of analysis We have been instructed to re-sample but now there is a question about whether we should employ GC or GCMS
A On numerous occasions we have expressed the deshysire to tailor the soil removal process to a minimum
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 3C7 ESSEX CTR VERMONT 05451 TELEPHONE 802 876 bull 5171
MITEC 104e 02467
L
Mitec Page 2 April 29 1985
2- bull number of truckloads as they are projected to cost about $4000 for each load Mitec being in a startshyup phase of their operation cannot approach this operation with a blank check Chris Stone who was on hand today to represent the State indicated that many more loads may be necessary to effectively rid the site of contamination
Too many questions surround this project for my clishyent to understand his responsibilities and ultimate costs The requirements issued by your office either in writing or verbally on-site have changed repeatshyedly and unless we can mutually agree to a reasonshyable program that is connrifpH rnmdashyr r i ng Mitec has no other option but to let the court decide the isshysue
Again keep in mind there are questions that we feel must be resolved in order to reach a satisfactory conclusion
1 Provided that all Browneil Road houses are connected to the CWD system and thereby reshymoved from any threat of groundwater conshy
- p tamination what level of soil contamination is permissible From this limitation provishyded we concur as to its reasonableness an approximation can be developed as to how many loads of soil must be removed
2 If the soil is to be removed why is it neshyy cessary to conduct organics sampling unless
i t~ i s tne ulterior motive ot the State to direct renovation of the groundwater as well If that is the case the process will now be more expensive than at the outset due to the mobilization of the contaminants
3 If the contaminated soil is to be removed whv is additional groundwater monitoring
pound bull necessary Documentation of the degree of dilution is not considered acceptable
A If organic testing is to be performed y_hich -- method of analysis is to be used
As soon as we can receive a response to the quest-
MITEC 104e 02468
I um laquoi i laquo m mdash n r r j mdash i mdash
Mitec Page 3 April 29 1985
ions at hand then further discussion with the State will dnsue Also please be advised that at the dishyrection of Mitec all future correspondence communishycations requests for information or notification of site vists are to be forwarded to my office We also request that one person in your office be designated to process such information
tuart PE
JHSocc cc Mitec
Robert Cronin Esq
MITEC 104e 02469
jmfMraquoi w i f u m i
A u u raquo laquo F pound raquo laquobull= -
B C f U S t B C INC ENVIRONv i bullbullbull bullbull
5 GREEN MOUNTAIN DRIVE SOUTH BURLINGTON VERMONT 05401 TELEPHONE (802) 658-1074
February 17 1984
I I Mr Cedric Sanborn i
of Environmental Conservationi AgencAgencyy ox ampnvifoiuneniai Lonservdciun I i Dept of Water Resources and
Environmental Engineering Montpelier VT 05602
Dear Mr Sanborn j i
RE Mitec Clean-Up 84011 j
I am writing this letter to inform you of the work that has been completed thus far at Mitec Systems Corp The discharge of i rinsewater into the lagoon has stopped and the rinsewater is being batched and treated at Aquatec as I described in my letter to Stan Corneille dated February 3 1984
Although the chemical reduction and precipatation process works bull bull
very well we have found that the cost for design installation j septic design and installation and permit reviews is far above | Mitecs budget Aquatec has looked at a second alternative for bull the treatment and reduction of rinsewater that being ion exchange J The ion exchange system will be purchased from a vendor and will bull be installed by Aquatec to accomodate Mitecs rinsewater volumes i The rinsewater will be recirculated and will not require any discharge hence there will be no need for subsurface disposal [ permits I will send you specifications on the system and resins j that will be used I
The proposal for the out-door clean up work is enclosed Mr Kucer is currently discussing the cost estimate with his Montreal office I see no reason to intiate this work as soon as I get formal approval from your office and from Mitec
Please feel free to call me if you should have any questions
Sincerely
liytrl Zi [U$) John R Deigo Project Engineer
Enclosure cc Mr Steven Kucer
Hydrographic Studies and Analyses bull Water Quality Studies raquo Analytical Laboratories Ecological Studies bull Aquatic Nuisance Control - Industrial Waste Surveys
MITEC 104e 02472
Recommended Treatment of Rinsewater
Mitec System Corporation
Prepared By
Aquatec Inc
South Burlington Vermont
January 23 1984
MITEC 104e 02473
RE Mitec Groundwater Cleanup - 84011
The treatment of rinsewater will consist of a three stage rinse system with a batch chemical reduction treatment process Parts submersed in chromic acid solutions will be rinsed in a primary rinse bath The primary rinse bath will be a closed system and considered a rough rinse
The secondary rinse bath will also be a closed rinse system The third and final rinse will be a continuous overflow system Effluent from the tertiary system will flow directly into the septic system Tertiary effluent limits must be less than 005 mgl (ppm) before entering an underground septic system
The primary rinse bath will eventually become saturated with chromic acid solutions and require periodic batch treatment When the primary rinse water becomes spent it will be transferred into a 250 gal polyethylene plating tank The rinse water from the secondary rinse bath will be transferred into the primary rinse bath and the secondary bath will be refilled with fresh rinse water
When the tank reaches 80 of its capacity treatment will be initiated The treatment will consist of reducing hexavalent chromium to trivalent chromium by the addition of anhydrous sodium sulfite to a pH of lt2 The amount of sodium sulfite added will depend on the concentration and volume of rinsewater to be treated A portable electric mixer will be attached to the tank to ensure proper mixing The rinsewater in the reduced form will be gravity fed into a second 250 gallon polypropylene plating tank where lime will be added precipatlng out trivalent chromium as well as other heavy metals The mixer should be used to agitate the solution when the lime is added The mixer should be removed and the solids allowed to settle Once the solids have completely settled the treated water will be pumped into the tertiary effluent to allow for further dilution before it is discharged into a septic system
Periodic sampling of effluent waters should be incorporated to ensure that rinsewater discharged does not exceed 005 mgl (ppm)
Sludge will be properly stored and eventually disposed of by a certified hazardous waste carrier
MITEC 104e 02474
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Wildlife and Department of Forests Parks and Recreation Environmental Engineering Department of Water Resources amp Environmental Engineering Natural Resources Conservation Council State Geologist
January 4 1984
3 2ampov~ loo Mr J H Stuart
f i 2 Sm ^
P O Box 3 67 - - l ^ J ^ S M J Essec Center Vt 05451
SUBJECT Mitec Z 0~npJ^
1 o
Dear J o h n
I appreciate your sending me a copy of the recent Mitec water quality results It appears that there remains a detrimenshytal affect of the lagoon on the downgradient groundwater quality This is best demonstrated with the pH and chrome data While it appears that the downgradient well 5 has higher metalic concenshytration then well 6 in the middle of the lagoon I believe the Well 5 results are anamously high due to the turbidity or solids that we saw in the sample In talking with Cathy Cutting of IEA sample 5 was not filtered prior to acid digestion for the AAS analysis ^^
I would suggest that well s 4 5 and 6be resampled and analyzed along with the wells installed on CecT 17 amp 18 We would like to have a representative of our office on site when the sampling is performed so please contact me when a purging and sampling date is set in the near future The groundwater sample from test well 6 that you helped me obtain on December 17 with the teflon bailer was confirmed by our laboratory to contain volatile organics Therefore you must include the volatile orshyganics assay done by JGCMSjas a part of your analysis plan Adshyditionally I would suggest that you review the appropriate protocol for groundwater sampling and obtain the necessary equipshyment A sampling and analysis plan must be submitted for our apshyproval prior to commencing this second round of sampling The plan should be submitted by January 18 1985 with the sampling done within one month of our approval Please feel free to conshytact me with any comments or questions you may have
R f n r mdash i 1 Off ices - BarreEssex J c t P i t t s f o r d N Spr ing f ie ld S t Johnsbury
MITEC 104e 02844
J H Stuart Page 2
I do look forward to reviewing the results of the soils asshysays along with your report outlining the sampling protocol sampling locations data interpretations and projected course of action based on the results
Very truly yours
John F Amadon Hydrogeologist Hazardous Materials Management Program
JFAkp
cc Meredith Wright AG
MITEC 104e 02845
b v
HSTUART ASSOCIATES September 10 1984
Agency of Environmental Conservation Department of Water Resources and Environmental Engineering Air and Solid Waste Programs Attn Cedric Sanborn Air Pollution Control Engineer Montpelier Vermont 05602
Re M I T E C Corporation Williston Vermont
Dear Cedric
As Che result of our conversation on September 7th I am forwarding the information Chat we discussed
The CesCing program format was prepared prior Co our disshycussion and will be altered slightly based on some inforshymation that was collected
A boring was established in the cencer of Che disposal pic and Che wacer Cable as well as che Impeding layer were found to be located at 29 Inches below the surface The shallow depth will allow us co place addicional wells in che area co accuracely depicc Che groundwacer copography
The plan submiCCed herewith provides general information abouc che locaclon of che plane propercy lines and sugshygested positions for Che monitors The final location of che laccer will be decermined in che field once we collect more data on water table elevations
As we are most anxious to proceed with the program your expeditious review and responsewill be most appreciated
SCuart PE
JHSadt
cc David Gee MITEC
CIVIL ENVIRONMENTAL ENGINEERS 120 LAKE STREET BURLINGTON VERMONT 0S401 TELEPHONE 802-8640094
MITEC 104e 02846
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Game and Department of Forests Parks and Recreation
Department of Water Resources amp Environmental Engineering Environmental Engineering Natural Resources Conservation Council
September 19 1984
Mr John H Stuart PE JH Stuart Associates 120 Lake Street Burlington Vermont 05401
RE MITEC Project
Dear Mr Stuart
Chris Stone and I have reviewed the proposed soil sampling and groundwater monitoring plan for Mitec A summary of comments follows
1) The site plan did not show the location of the soil sampling sites Also we felt that additional boringmonitoring sites should be made closer to the facility The map has been re-marked to reflect these additional sites
2) It was not clear as to why the monitoring wells are to be installed 5 feet into the impeding layer However at least one boring should be made into the impeding layer to detershymine its thickness
3) Permeability tests should be performed on at least four of the test holes to determine aquifer characteristics
4) Since the water table is apparently close to the surface we feel that factory slotted pipe would be appropriate for the final monitoring wells
5) All soil1 ft 5 ft
samples 10 ft or
shouldto imp
be eding
takenlayer
at whic
depthshever
of comes
first
MITEC 104e 02847
Mr JH Stuart -2- September 19 1984
6) In addition to the soil sample in the center of the former lagoon four other locations within 2 feet of the edge of the lagoon must be sampled These locations are marked on the enclosed map
7) The State regulations do not address a level below which the metals are no longer hazardous as is done by EPA Toxicity Levels The level of contamination that is acceptable to the State is determined on a case by case basis
8) The analysis for chromium should include both hexavalent and total chromium
If you have any questions regarding our comments do not hesitate to contact us at 828-3395shy
Sincere
Sanborn C h r i s t o p h e r T Stone Environmental Engineer Hydrogeo log i s t Hazardous M a t e r i a l s Hazardous M a t e r i a l s Management Program Management Program
c r s - c t s a d e n c l o s u r e
MITEC 104e 02848
JHSTUART November 9 1984
Agency of Environmencal Conservation Deparcmenc of Wacer Resources and
Environmencal Engineering Hazardous MaCerials Management Program Attn Cedric Sanborn Environmental Engineer Mnotpelier Vermont 05602
Re M I T E C Corporation Williston Vermonc
Dear Cedric
There has been an apparent misunderstanding regarding your letter of September 19 1984 as soil and wacer sampling has been commenced ac che above location A call was placed Co your office on October 30th or 31sc and a message lefc for you indicating that we would begin on November 6ch at 8 AM
In the afternoon of November 6th I telephoned Chris Scone co inform him of our progress On che following morning you notishyfied MITEC that approval to begin had not been granced and chac work musC cease AC chac point we had completed che installashytion of five monitors and had extracted Cwo soil samples from the botcom of che wasce pic
On November 8ch I met with you and Chris to oucline che reshysulCs from our effores I was informed Chat we may have to inshystall one or Cwo additional monitors and Chac all future work muse be performed wich an Agency represenCacive in accendance
LaCe that afternoon Gerry Adams phoned Co notify me chat on short notice he was leaving to begin a large contract in rUasashychusetts and that it was unlikely that he would be back in the area for an extended period Had we been permitted to continue ttith our work on the 7th his portion of the project vould have been concluded
Enclosed you will find an updated version of the site plan orishyginally submitced wich my leCCer of Sepcember lOch A new plan will be developed buc Chis drawing will serve the purpose of locating existing and proposed wells
Whereas I am now withouc a drilling concracCor I would like chu
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05461 TELEPHONE 802 878 5171
MITEC 104e 02849
M I T E C Page 2 November 9 1984
authorization to determine groundwater elevations by auger and then establish one more monitor in a location agreed to by all che parcles I feel chac we have developed sufficient information co date to proceed in this manner
Furcher since Adams will noc be available I would also like Co extract che remaining soil samples wich a bucket auger IC can demonstrated chac che sample collected in chls manner will provide a good represencacion of che soil ac che level desired in Che profile
We are prepared co conclude chls phase of che sice evaluacion Samples from Che groundwacer monitors can be secured in a few days and I would like co follow wich che soil samples using che method described above
Please contact me at 878-5171 if you need additional informashytion
H Stuart PE
JHSadt
cc David Gee MITEC
MITEC 104e 02850
JHSTUART December 19 1984
M I T E C Corporation AtCn David Gee Manager IS Commerce Way Wllliscon Vermonc 05495
Dear David
Under Che Cerms of our agreemenc daced 10584 I wish Co proshyvide you wish an up-daCe of the project status
At the completion of 1219 we will have completed Items 1-4 as specified in the agreement specifically the soils sampling and initial set of water samples will have been collected and submitted for analysis As of chls momenC we still do not know the extent of the problem but will have a better indication once the test results are available in about a week My feelshying Is chac the problem is noc severe
We have compleCed all wells as prescribed however Che State is opting for an additional well Although the contract provides for only six the costs to date are below my target and it does not appear Chac any exCra will be necessary provided ChaC che driller concludes his work coday
The only work remaining afCer chls dace will be che collecCion of che second baCch of waCer samples and discussions wich Che State about any remedial action if necessary
Feel free to contacC me if you have any quescions
Regards
John H Stuart PE
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 878 bull 5171
MITEC 104e 02851
JHSTUART
M I T E C Corporation December 20 1984 ACCn David Gee Manager 15 Commerce Way Willaton VT 05495
Dear David
During our investigations yesterday Che work was completed on the additional monitor well as invoiced as well as drilling to the impeding layer The State decided however that two addishytional wells are required both of which will be Installed toshyday west of the Industrial park boundary line
A major change developed In Che method of testing the soils in the vicinity of the disposal pit that is not covered by our contract Instead of the four peripheral borings and one in Che center of che pic which would have produced flfceen soil samshyples che StaCe representatives decided Co require a different CesC paCCern Chac produced thirty seven samples I have collectshyed all of the samples but have Instructed the Cest lab to hold until authorization Is received Co proceed on Chls change as it Is a subsCanClal cost and will cause Che contract limit to be exceeded
Included is an invoice reflecting the additional wells the cost Co sample the groundwater for those monitors and the additional funds needed to run the soil tests I do not believe that any further surprises are in order
Regards
John H Stuart PE
JHSadt
CIVIL ft ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 06451 TELEPHONE 802 878 5171
MITEC 104e 02852
JHSTUART
December 28 1984
M I T E C Corporation Attn David Gee Manager 15 Commerce Way Williston VT 05495
Dear David
Enclosed are the results from the water quality analyses of the samples submitted to our lab I have noted in the left hand column the allowable limits for each element A copy of this information has been forwarded to John Ami-don per his request
There are several readings that are suspicious according to John The cadmium level in 4 may be an error and Che chromium found in 5 mosc likely Includes che CurbldlCy measured only in ChaC well Both should be resampled to confirm The cadmium and chromium levels in 06 exceed che allowable llmlCs but not excessively so The soil tesCs which have begun will reveal more about the ultimate disshyposition of these elemenCs
On the sewer Issue I spoke wich Frank Ailing again and his plans are Co now develop Che design and receive approval chis wincer for consCrucCion of the required Improvements this spring
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 5171
MITEC 104e 02853
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MITEC 104e 02855
JHSTUART January 28 1985
M I T E C Corporation Attn David Gee Manager 15 Commerce Drive WillistonVermont 05495
Dear David
On January 25th I met with John Amadon and Cedric Sanborn to discuss the contents of my 12385 letshyter The following resulted subject to confirmation by more senior members of the AEC staff
1 The water samples to be collected from wells 45 and 6 are to be checked for cadmium both chromiums and conductivity Wells 1 2 and 3 will be tested for conductivity and pH only
2 Samples will be collected from wells 4-9 for orshyganics but only wells 56 and 9 are to be checked at this time to determine the scope of contaminatshyion
3 The material to be removed from the pit is conshysidered as a hazardous waste and there are not any disposal sites located within Vermont certified to receive it I did obtain a listing of contractors that are approved for handling the material and I will provide this during our next meeting
4 Attached is a copy of the State lab results that address the organics problem
5 Based on the above we will have to amend our ashygreement to include the $1150 additional costs for the testing connected with Items 1 and 2
Call me if you have any questions
John H Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 raquo 878 bull 5171
MITEC 104e 02856
JHSTUART January 30 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Attn John Amadon Hydrogeologist Montpelier Vermont 05602
Re M I T E C
Dear John
I have had several discussions with MITEC relative to our meeting of last Friday In essence they have agreed to the program that you defined but with several provisos
They would like a letter from your office detailing the additional measures to be implemented together wich specific instructions as to what steps must be taken in the process of removing the contaminated soil
Further their acceptance to collect and sample for volatile organics is limited Perchloroethylene as I had indicated is not and has not been used by MITEC The materials stored on the premises as well as the list of suppliers for paints and solvents are available for inspection co corroborate that position MITEC will provide a complete analysis of all organics for the specified wells however fushyture testing for TCE will not be at the expense of MITEC unless its presence can be attributed to their operation
We are prepared to proceed as soon as we receive the requested notification
Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 bull 5171
MITEC 104e 02857
CORRECTIVE ACTION FEASIBILITY INVESTIGATION EPA SITE NUMBER VTD-0983 53545 (LOT 19-11)
January 29 2001
GeoX MITEC 104e Fc l I lS Inc A TETRA TECH COMPANY J L J 02269
6 Lancaster County Road Harvard MA 01451 978-772-7557 FAX 978-772-61 83
CORRECTIVE ACTION FEASIBILITY INVESTIGATION EPA SITE NUMBER VTD-098353545 (LOT 19-11)
J - J C T October 5 2000
GEOTRANS A TETRA TECH COMPANY
6 Lancaster County Road Suite Four Harvard Massachusetts 01451 MITEC 104e
02352
CORRECTIVE ACTION FEASIBILITY INVESTIGATION
EPA SITE NUMBER VTD-098353545 (LOT 19-11)
PREPARED FOR
ALLING INDUSTRIAL PARK
PREPARED BY
HSI GEOTRANS INC
6 LANCASTER COUNTY ROAD
HARVARD MASSACHUSETTS 01451
HSI GEOTRANS PROJECT NO N753-016 OCTOBER 52000
HSI GeoTrans inc
MITEC 104e 02353
TABLE OF CONTENTS
PAGE
1 INTRODUCTION 1-1
2 STUDY AREA CONCEPTUAL MODEL 2-1 21 STUDY AREA LOCATION AND DESCRIPTION 2-1
22 STUDY AREA LAND USE 2-1
23 HYDROGEOLOGIC SETTING 2-1
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION 2-3
3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES 3-1 31 IDENTIFICATION OF ARAR S 3-1
32 REMEDIAL ACTION OBJECTIVES 3-1
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES 3-1
322 GROUNDWATER 3-1
323 SURFACE WATER 3-2
324 INDOOR AIR 3-3
33 INITIAL SCREENING 3-3
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES 3-4
4 DETAILED ANALYSIS OF ALTERNATIVES 4-1 41 ALTERNATIVE 1 NO ACTION 4-1
411 SHORT-TERM EFFECTIVENESS 4-1
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-2
413 LONG-TERM EFFECTIVENESS 4-2
414 COMPLIANCE WITH ARARS 4-3
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 4-4
416 IMPLEMENTABILITY 4-4
417 COSTS 4-5
42 ALTERNATIVE 2 MONITORING INSTITUTIONAL CONTROLS AND
HYDRAULIC CONTAINMENT 4-5 421 SHORT-TERM EFFECTIVENESS 4-8
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-9
423 LONG-TERM EFFECTIVENESS 4-9
424 COMPLIANCE WITH ARAR S 4-10
425 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-11
426 IMPLEMENTABILITY 4-11
427 COSTS 4-12
FOR ALLING INDUSTRIAL PARK MWP_DOCSW5J20OTALlIWFS9-00U0030929wro 11 HSI GSOTrflnS IflC
MITEC 104e 02354
TABLE OF CONTENTS (CONTINUED)
PAGE
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS
AND PERMEABLE REACTIVE BARRIER 4-13
431 SHORT-TERM EFFECTIVENESS 4-15
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-16
433 LONG-TERM EFFECTIVENESS 4-17
434 COMPLIANCE WITH ARARs 4-18 435 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-18
436 IMPLEMENTABILITY 4-19
437 COSTS 4-20
44 ALTERNATIVE 4 MONITORING INSTITUTIONAL CONTROLS
AND NATURAL ATTENUATION 4-20
441 SHORT-TERM EFFECTIVENESS 4-21
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-21
443 LONG-TERM EFFECTIVENESS 4-22
444 COMPLIANCE WITH ARARS 4-23
445 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-23
446 IMPLEMENTABILITY 4-23
447 COSTS 4-24
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION 4-25
451 SHORT-TERM EFFECTIVENESS 4-26
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-27
453 LONG-TERM EFFECTIVENESS 4-27
454 COMPLIANCE WITH ARARS 4-28
455 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-29
456 IMPLEMENTABILITY 4-29
457 COSTS 4-30
FOR ALLING INDUSTRIAL PARK MWPJXgtCSN7532000AUJNOFSlaquo)0I0030929WPD 111 HSI GeOTrSDS ItlC
MITEC 104e 02355
TABLE OF CONTENTS (CONTINUED)
PAGE
5 COMPARATIVE EVALUATION OF ALTERNATIVES 5-1 51 SHORT-TERM EFFECTIVENESS 5-1
52 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT 5 - 3 53 LONG-TERM EFFECTIVENESS 5-4
54 COMPLIANCE WITH ARARS 5-4
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 5-4
56 IMPLEMENTABILITY 5-5
57 COSTS 5-5
6 PREFERRED REMEDY 6-1 61 PREFERRED REMEDY 6-1
62 MONITORING PROGRAM 6-2
REFERENCES 7-1
APPENDIX A TWODAN INPUT FILES
FOR ALLING INDUSTRIAL PARK MWgt_DOCSW7532000WJJNGfS9^)0M00J(raquo9wpo I V H S I G S O T r a H S I n C
MITEC 104e 02356
LIST OF TABLES
PAGE
TABLE 3-1 REMEDIAL ACTION OBJECTIVES 3-7
TABLE 3-2 DESCRIPTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES 3-8
TABLE 3-3 SELECTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES
FOR DETAILED ANALYSIS 3-11
TABLE 41 COST ESTIMATES FOR REMEDIAL ALTERNATIVES 4-31
TABLE 6-1 SAMPLING LOCATIONS 6-5
TABLE 6-2 VOC ANALYTES 6-6
TABLE 6-3 PARAMETERS TO EVALUATE BIODEGRADATION 6-7
FOR ALLING INDUSTRIAL PARK MWP DOCSN7S32000AUJNOFS9-00I0030929 wro HSI GeoTrans inc
MITEC 104e 02357
LIST OF FIGURES
PAGE
FIGURE 1-1 STUDY AREA LOCATION MAP 1-2
FIGURE 1 -2 LATERAL BOUNDARIES OF REGION OF TCE-CONTAMINATED GROUNDWATER 1 -3
FIGURE 4-1 MODELED SITE-EXISTING CONDITIONS 4-33
FIGURE 4-2 MODELED SITE WITH THREE RECOVERY WELLS PUMPING AT 5 GPM 4-34
FIGURE 4-3 MODELED SITE WITH TEN RECOVERY WELLS PUMPING AT 5 GPM 4-35
FIGURE 4-4 ALTERNATIVE 3 PERMEABLE REACTIVE BARRIER 4-36
FIGURE 6-1 PROPOSED MONITORING LOCATIONS 6-8
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUUNOFS9-OOV 10030929 w r o VI HSI GeoTrans inc
MITEC 104e 02358
1 INTRODUCTION
This Corrective Action Feasibility Investigation is submitted on behalf of Mitec Telecom
Inc (Mitec) by HSI GeoTrans The investigation was done to evaluate potential remedial
alternatives for groundwater contaminated by trichloroethylene (TCE) and to a lesser extent
tetrachloroethylene (PCE) and petroleum related compounds (BTEX) at the Ailing Industrial
Park (the Study Area) A recently prepared Site Investigation Report (SIR) (HSI GeoTrans
2000) identified the nature and extent of contaminated groundwater within the Study Area
Figure 1-1 is a map ofthe Study Area and Figure 1-2 is a map that outlines the region of
contaminated groundwater for which potential remedial alternatives were evaluated
The SIR concluded that the TCE contamination was widespread across the Study Area
that residual TCE dense non-aqueous phase liquid (DNAPL) resulting from one or more releases
was a continuing source of contamination to groundwater and that under current conditions the
groundwater contamination does not pose an unacceptable risk to human health and the
environment Current conditions include the continued effective mitigation of indoor air vapors
at the residence at Lot 3-30 no other residences with basements below the water table and no
use of groundwater within the Study Area as a potable supply The SIR also concluded that if
groundwater were to be used as a potable supply a significant health risk would exist as a result
of exposure to groundwater through ingestion dermal contact and inhalation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^X)M0030929WPD 1 - 1 HSI GCOTrdnS ITC
MITEC 104e 02359
I - N -
Former Mitec Hold y
Meters
Explanation
Study Area TITLE
MITEC 104e 02360
Study Area Location Map
LOCATION
Williston Vermont CHECKED MS FIGURE HSI OfVFTED RMK
GEOTRANS RLE f s ~ Expa nd~S(tsdirq 1-1 A T I T M TICK C011irraquoraquoT DATE- 10600 ~
2 STUDY AREA CONCEPTUAL MODEL
The following discussion ofthe Study Area conceptual model is summarized from
information contained in the previously submitted SIR (HSI GeoTrans 2000)
21 STUDY AREA LOCATION AND DESCRIPTION
The Study Area is located at the Ailing Industrial Park and adjacent areas in Chittienden
County Williston VT The VT state plane coordinates for the Study Area are Northing
71210837 (44 27 T north latitude) and Easting 147576375 (73 7 50 west longitude) The
Study area is within the Winooski River watershed and has an elevation ranging from 330 to 350
feet above mean sea level (MSL) The ground surface has little relief and slopes gently to the
southwest A small unnamed brook flows in a southerly direction along the eastern edge of an
industrial park located within the Study Area There is unlimited public pedestrian access to the
Study Area
22 S T U D Y A R E A L A N D U S E
The land in the Study Area is currently zoned for mixed residential commercial and
industrial use The eastern portion ofthe Study area is primarily zoned for commercial use and
the western portion ofthe Study Area is predominantly residential The Study Area includes an
industrial park where there has been light industrial and commercial use since 1946 Three lots
in the industrial park have been previously identified as locations of former manufacturing andor
fabrication operations that resulted in release of contaminants to groundwater (Brinkerd 1996
TRC 1993 Griffin 1995)
23 HYDROGEOLOGIC SETTING
The unconsolidated geologic deposits beneath the Study Area consist of sand silt and
clay which were deposited in the former Champlain Sea overlying till The unconsolidated
deposits occur in four distinct layers The surficial deposits are medium to fine sand which
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000VALUNoFS9^X)10030929wro 2 - 1 H S I G e O T r a f l S J n C
MITEC 104e 02362
generally becomes finer-grained with depth and extend to approximately 20 feet below ground
surface (bgs) Interbedded silts and fine sands are present from approximately 20 to 40 feet bgs
An areally-extensive clay layer underlies the interbedded silt and fine sands at a depth of
approximately 32 to 60 feet bgs Beneath the clay layer is a dense till which extends from about
60 to 100 feet bgs The underlying bedrock is comprised of massive gray limestone gray
dolomite and white marble ofthe Beckman formation This bedrock is of lower Ordovician age
and is part ofthe Hinesburg Synclinorium structure
The aquifer in the Study Area and surrounding regions is primarily the surficial medium
and fine sands although some water is capable of being extracted from the lower silt and fine
sand The residences and businesses within the Study Area are currently serviced by a public
water supply and the aquifer is not used for potable water supply within the Study Area The
hydraulic conductivity ofthe medium to fine sands was determined from a slug test to be about
20 feetday (Johnson 1999) The hydraulic conductivity ofthe interbedded silt and fine sand as
determined from rising and falling head slug tests (HSI GeoTrans 2000) ranged from 1 to 20
ftday with a geometric mean of 38 ftday A pumping test of well NO-1 yielded a hydraulic
conductivity estimate of about 2 to 30 ftday for the combined medium to fine sands and
underlying silt and fine sand There are no hydraulic conductivity data for the underlying clay
and till layers It is believed that the clay and till act as a lower confining layers restricting the
vertical flow of water between the overlying sand and the underlying bedrock
Beneath the Study Area the depth to water generally ranges from 3 to 11 feet below
ground surface In general groundwater flow beneath the Study Area is from the north to the
southeast and southwest There is a groundwater divide in the water table that runs generally
parallel to Commerce Street East ofthe divide groundwater flows toward and discharges to the
unnamed brook West ofthe divide groundwater flows toward Muddy Brook which is located
about 300 meters or 1000 feet west ofthe Study Area Groundwater recharge within the Study
FOR ALLING INDUSTRIAL PARK MAWPJgtOCSN753UOOOWXINOFS9-O0l0030929wro 2-2 HSI GCOTrdnS IDC
MITEC 104e 02363
Area is primarily from infiltration of precipitation Prior to 1986 when a sewer line was
installed groundwater recharge also resulted from discharge to numerous on-site disposal
systems
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION
Figure 1-2 illustrates the 1999 distribution of TCE-contaminated groundwater within the
Study Area The lateral boundaries ofthe region of TCE-contaminated groundwater
approximately represent the lateral boundaries ofthe region of volatile organic compound
(VOC)-contaminated groundwater As discussed in the SIR (HSI GeoTrans 2000) VOCs
present in groundwater include TCE PCE and BTEX The compound detected at the highest
concentrations and over the largest portion ofthe Study Area is TCE PCE is generally detected
in the same area as TCE but at significantly lower concentrations BTEX compounds have been
detected in groundwater primarily in the eastern portion ofthe Study Area and are commingled
with but not coincident with TCE-contaminated groundwater The lateral boundaries shown in
Figure 1-2 approximately represent the lateral extent of groundwater contamination and are not
intended to indicate that all groundwater within those boundaries is contaminated This figure
includes data collected on behalf of Mitec as part ofthe SIR (HSI GeoTrans 2000) and data
collected in 1999 by the Johnson Company (Johnson 1999) Figure 4-2 A ofthe SIR (HSI
GeoTrans 2000) shows all TCE concentration data collected in 1999 as well as some data
collected in 1997 The SIR (HSI GeoTrans 2000) summarized previous investigations that
indicated that at least three properties have contributed to the region of VOC-contaminated
groundwater On Lot 19-11 there were a disposal lagoon and a leach field that resulted in the
release ofthe VOCs TCE and PCE (perhaps as an impurity in the TCE) Lot 19-12 once had
underground storage tanks from which a previous release of BTEX was discovered when the
tanks were removed Lot 19-2 contained a disposal pit and outfall pipe from which TCE was
reportedly released
Figure 1-2 of this report shows in plan view the areal distribution of TCE-contaminated
groundwater Where there were multiple 1999 data values for the same location preference was
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AL1JNOFS9-OOM0030929WPD 2-3 HSI GSOTraHS JHC
MITEC 104e 02364
given to samples collected by low-flow sampling done subsequent to well installation In
addition for those locations which had samples from different depths the sample with the
highest concentration was used Figure 1-2 illustrates that TCE-contaminated groundwater is
widespread beneath the Study Area and that the highest TCE concentrations are detected in
groundwater beneath the eastern portion ofthe Study Area The figure illustrates that TCE-
contaminated groundwater in the eastern portion ofthe Study Area discharges to the unnamed
brook No VOCs including TCE have been detected in groundwater samples collected from
wells on the eastern side of the unnamed brook Based on surface water and groundwater data
that have been collected the unnamed brook appears to limit the southeasterly extent ofthe
region of VOC-contaminated groundwater In the western portion ofthe Study Area the lateral
boundaries of contaminated groundwater were identified through vertical profile sampling at
several locations Figure 1-2 shows the location ofthe vertical profiling borings that define the
lateral extent of TCE-contaminated groundwater The SIR (HSI GeoTrans 2000) recommended
periodic sampling and analysis of wells in the western portion ofthe Study Area for the purpose
of determining whether this region of VOC-contaminated groundwater was stable or expanding
in size
While not evident from Figure 1-2 it was determined that throughout the Study Area the
highest TCE concentrations were detected in samples collected from the interbedded siltclay
layer As shown on Figure 4-2A ofthe SIR the higher TCE concentrations were generally
detected at a depth of about 35 feet below ground surface in the eastern portion ofthe Study
Area and at a depth of about 30 feet below ground surface in the western portion ofthe Study
Area It is believed that the current distribution of TCE contamination resulted from DNAPL
releases at one or more locations within the Study Area One such release area was at Lot 19-11
DNAPL migrated downward through the upper medium to coarse sands under the primary
influence of gravitational forces There would have been some lateral displacement along
preferential pathways provided by sloping unconsolidated deposits but the primary flow would
have been downward Upon encountering the more resistive capillary pressure forces associated
with the water-saturated finer-grained geologic units such as the interbedded silts and sands
FOR ALLING INDUSTRIAL PARK MVWP_DOCSN7532000ALUNCFS9J3010030929wro 2 - 4 H S I G C O T r d n S I r t C
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which exist beneath the upper medium to coarse sands the DNAPL downward migration would
have stopped The DNAPL would have accumulated on top ofthe capillary pressure barrier layer
and then would have spread laterally following preferential flow paths within the coarser-grained
geologic units above the interbedded silts and sands The amount of lateral spreading of
DNAPL from any release area would have been dependent upon the volume and frequency ofthe
releases As the DNAPL migrated it would have created a region of residual DNAPL This
region of residual DNAPL consists of isolated DNAPL droplets trapped within pore spaces ofthe
unconsolidated deposits The lateral migration ofthe DNAPL would have been affected by the
slope ofthe surface ofthe finer-grained units that halted downward migration ofthe DNAPL
and it would not necessarily have been coincident with the direction of hydraulic gradient or
groundwater flow The region of residual DNAPL is now a continuing source of contamination
to the groundwater which flows past and gradually dissolves the DNAPL The locations ofthe
residual DNAPL zones are not known
There were no direct observations of DNAPL during drilling and well installation but it
is expected that residual DNAPL generally exists within regions of higher concentration detected
in the eastern portion of the Study Area The residual DNAPL is not necessarily continuously
connected within that region Based on the vertical distribution of TCE concentrations it is also
expected that the residual DNAPL exists in a relatively thin zone within the interbedded silt and
clay Limited hydrodynamic dispersion within the interbedded silt and clay has resulted in a
relatively thin zone of relatively high TCE concentrations in groundwater The southeastward
and southwestward divergence of groundwater flow has resulted in a laterally extensive region of
TCE-contaminated groundwater
There has been no indication in any ofthe investigations done within the Study Area
including the SIR (HSI GeoTrans 2000) that there are locations within the Study Area where
DNAPL is present in sufficient volume to be recoverable in the DNAPL phase
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3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES
31 IDENTIFICATION OF ARARS
Two Applicable or Relevant and Appropriate Requirements (ARARs) were identified in
consultation with Mr Mike Smith ofthe Vermont Department of Environmental Conservation
(VTDEC) The first are the Groundwater Enforcement Standards as outlined in Appendix one of
the Chapter 12 Groundwater Protection Rule (VTDEC 1997) These standards apply to
concentrations of contaminants in groundwater in the Study Area (TCE PCE and BTEX) The
second are the Vermont Water Quality Criteria dated March 142000 (VTDEC 2000) which
specify surface water quality criteria and policy
32 REMEDIAL ACTION OBJECTIVES
The remedial action objectives (RAOs) for the Study Area are summarized in Table 3-1
and further described below
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES
One ofthe RAOs for the Study Area is the remediation of source areas Soil excavation
and removal has already occurred at the known release areas Not withstanding the fact that
previous DNAPL releases are suspected no areas of recoverable DNAPL have been detected in
the Study Area Concentrations of TCE in groundwater indicate it is present in some areas as
residual phase below the water table One purpose of this Corrective Action Feasibility
Investigation is to evaluate options for remediating residual DNAPL in the Study Area
322 GROUNDWATER
Attain VT Groundwater Enforcement Standards The ultimate goal of remediation is to
attain Groundwater Enforcement Standards for VOCs in groundwater This is in accordance
with the VT Groundwater Protection Rule and Strategy (VTDEC 1997) which states that If an
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(MUJNOFS9^)OM0030929WPD 3 - 1 HSI GCOTranS IttC
MITEC 104e 02367
enforcement standard has been reached or exceeded at a compliance point the goal is to take
appropriate action to retum the groundwater quality to below the enforcement standard if
possible
Prevent Expansion ofthe Dissolved Plume A risk assessment (Menzie Cura 2000a and
2000b) was included as part ofthe SIR (HSI GeoTrans 2000) The risk assessment concluded
that under current conditions concentrations of VOCs dissolved in groundwater in the Study Area
do not pose a risk to human health andor the environment The SIR (HSI GeoTrans 2000) also
indicated that the available monitoring data were not sufficient to determine whether the region
of VOC-contaminated groundwater in the southwestern portion ofthe Study Area was stable in
size or expanding This Corrective Action Feasibility Investigation explores options for
monitoring groundwater quality and preventing the region of VOC-contaminated groundwater
from expanding in size
Prevent Potable Use of Groundwater Within the Dissolved Plume Menzie Cura prepared
a June 1 2000 addendum (Menzie Cura 2000b) to the April 2000 risk assessment (Menzie Cura
2000a) The addendum evaluated risk posed by potable use of groundwater at the site The
addendum found there to be a human health risk associated with the use of groundwater at the
site for potable purposes One RAO of this Corrective Action Feasibility Investigation is to
propose institutional controls so that groundwater within the region of contaminated
groundwater would not be used as a potable supply until concentrations are suitable for such use
323 SURFACE WATER
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
under current conditions VOCs dissolved in surface water in the Study Area do not pose arisk to
human health or the environment Currently however surface water concentrations in the
unnamed brook exceed VT Water Quality Criteria (VTDEC 2000) One ofthe RAOs for the
site will be to meet these surface water quality standards in the unnamed brook
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324 INDOOR AIR
The VTDEC has conducted air sampling at several residences along Kirby Lane and
South Browneil Road The results have indicated the presence of TCE and PCE in indoor air at
some ofthe South Browneil Road residences (Brinkerd 1996) and unacceptable VOC
concentrations in the basement ofthe residence at Lot 3-30 on South Browneil Road The
presence of VOC vapors in the residence on Lot 3-30 is believed to have resulted from
volatilization of groundwater which infiltrated the basement through a continuously operating
sump pump The sump was vented to the exterior ofthe house as part of a state-sponsored
action and the indoor air concentration ofthe contaminants reduced to an acceptable
concentration Therefore one institutional control for the site will be to maintain the sump
venting as long as necessary to prevent health risks due to inhalation of VOC concentrations in
indoor air Also an institutional control in the form of a zoning restriction should be
implemented to prohibit the construction of new buildings with basements below the water table
in the region of contaminated groundwater The restriction should specify that in cases where it
is unavoidable to place the basement below the water table proper containment and venting of
the sump drainage system is required
33 INITIAL SCREENING
Four general categories of remedial technologies were evaluated The first monitoring
may be used alone or in conjunction with other remedies The second category includes
institutional controls to prevent exposure to contamination in groundwater and indoor air
Institutional controls could also be used alone or in conjunction with other remedies The third
category includes source removal technologies
The fourth category includes contaminated groundwater containment technologies such
as a hydraulic barrier or permeable reactive barrier Containment technologies can be applied in
two different ways Thefirst source control application would entail installing the containment
technology directly downgradient ofthe highest dissolved concentrations in an attempt to contain
the contaminated groundwater nearest the source Over time if new contamination is not
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MITEC 104e 02369
allowed to migrate beyond the source VOC concentrations in the downgradient region of
contaminated groundwater should attenuate
The second application would entail installing the containment technology at the
downgradient edge ofthe region of Contaminated groundwater The containment would protect
downgradient receptors from impacts by the region of contaminated groundwater
Both containment technology approaches were considered for use in the event additional
monitoring data shows that the region of VOC-contaminated groundwater is expanding in size
or if VOC concentrations in groundwater discharging to the unnamed brook are increasing
Table 3-2 identifies the remedial technologies considered and summarizes the results ofthe
initial screening for applicability to addressing the ARARs
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES
The list of potentially viable technologies shown in Table 3-2 was subjected to an initial
screening process The purpose ofthe initial screening was to identify those technologies that are
potentially feasible in the Study Area prior to performing a more detailed technology screening
Many ofthe source removal technologies were removed from further consideration because of
the impracticability of remediating residual DNAPL at the site
As described in the SIR (HSI GeoTrans 2000) DNAPL is likely present in the Study
Area Although present DNAPL has not been directly observed in any location and there has
been no indication that there is recoverable DNAPL present The failure to detect DNAPL
directly is not an uncommon situation at DNAPL sites and commonly results from its
heterogeneous distribution or its presence only at residual saturation (US EPA 1992)
Groundwater extraction and treatment is not an effective technology for remediation of residual
DNAPL due to limitations resulting from the limited solubility of most DNAPL compounds and
the heterogeneous distribution ofthe DNAPL (US EPA 1993) Designing remedial strategies
for DNAPL is made difficult by the inability to accurately locate the DNAPL sources This
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320(XAALlJNoFS9^)010030929wro 3 - 4 H S I G C O T r a n S I n C
MITEC 104e 02370
inability to locate the DNAPL renders the use of targeted source remedies that might be cost
effective for a small readily definable source area ineffective These targeted source remedies
include excavation air sparging chemical oxidation in-situ thermal desorption and chemical
flushing technologies
Subsurface deposits in the Study Area are heterogeneous due to the interbedded nature of
the sands and silts overlying an areally extensive clay The presence of such heterogeneity
creates extremely variable and unpredictable groundwater flow velocities as well as flow paths
for DNAPL migration The contrast in permeability and porosity between different lithologies
results in the development of preferential flow pathways While preferential flow through coarse
sand and gravel zones provides higher than average groundwater flow rates and contaminant
flushing less preferential flow pathways such as silty sands silts and clays remain poorly
flushed even under forced hydraulic gradients created by extraction wells Contaminants
however may have migrated to these areas of less preferential flow as DNAPLs under
gravitational influence or by diffusion over long periods of time The low permeability zones
even if addressed by localized extraction of groundwater will transmit only small quantities of
water and hence contaminant flushing is slow This is compounded by the low solubility of
DNAPL constituents and the tendency for them to become trapped in soils by capillary pressure
forces
Specific source removal technologies which have been screened out as ineffective at this
stage include air sparging groundwater amendments excavation and in-situ thermal desorption
Low permeability zones prevent the migration of soil vapors or sparged air to the near-surface for
recovery due to the preferential flow caused by heterogenieties it is not possible to determine if
amendments which can be added to the groundwater or chemical flushing compounds which
displace the groundwater and help liberate residual DNAPL such as oxidants alcohol polymers
andor surfactant would reach the DNAPL Excavation which has already been used to remove
impacted surface soils in known release areas is not practical for removing residual DNAPL
deep below the water table The in-situ thermal desorption can be useful in some environments
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MITEC 104e 02371
but can also induce downward DNAPL migration if hydraulic control ofthe system is not
complete Because the location of residual DNAPL is not known and because hydraulic control
ofthe underlying silt clay and till into which the DNAPL may migrate cannot be assured in-situ
thermal desorption is not feasible for this site
Monitoring and institutional controls are included in each option evaluated except for the
no-action alternative These are required to rule out possible future health risks due to expansion
ofthe region of VOC-contaminated groundwater or the creation of new contaminant exposure
pathways
The technologies remaining after the initial screening are presented in Table 3-3
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MITEC 104e 02372
Table 3-1 Remedial action objectives
MEDIA REMEDIAL ACTION OBJECTIVE
Groundwater -Remove or control contaminant sources
bullAttain VT Groundwater Enforcement Standards
-Prevent expansion ofthe region of contaminated groundwater
-Prevent use of groundwater within the region of contaminated groundwater as a
potable water supply where contaminant concentrations exceed federal drinking
water standards
Surface Water -Attain VT Water Quality Criteria
Air -Prevent inhalation of concentrations in indoor air derived from groundwater
FOR ALLING INDUSTRIAL PARK MWP DOCSW7520(XMUJNOFS9^XM0030929WPO 3-7 HSI GeoTrans inc
MITEC 104e 02373
-n Table 3-2 Description of potentially viable remediation technologies o w o
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R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Basement Sump Venting
Restriction on new buildings with basements set below the water table
Restrict Potable Use of Groundwater
Excavation
Natural Gradient Flushing
Air Sparging
RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
PROCESS DESCRIPTION OPTIONS
No Action No Action
Monitor groundwater concentrations to confirm that region of VOC-contaminated groundwater is not expanding in size
Monitor surface water concentrations in unnamed brook to ensure concentrations remain below risk levels
Continue to vent the sumps at Lot 3-30 on South Browneil Road
Restrict construction of any new buildings with basements set below the water table within the area of dissolved VOC contamination and require basement sump venting in those where a below water table basement is unavoidable
Place restrictions on potable use of groundwater at properties overlying the region of VOCshy contaminated groundwater
Excavation and removal of soils containing residual DNAPL
Continued dissolution and natural attenuation of residual DNAPL
Injection of air beneath the water table to volatilize residual DNAPL and dissolved concentrations in groundwater
INITIAL SCREENING C O M M E N T
Used as a baseline for comparison No cost Long remediation time
Can be used in conjunction with other response actions Will be required in the southwest portion ofthe region of contaminated groundwater since existing data are inconclusive regarding this issue
Can be used in conjunction with other response actions
Will be required until data show there is no longer a risk to indoor air from groundwater in the basement
Will be required until data show there is no risk of migration of VOCs to indoor air from groundwater
Will be required at all properties in the area of VOC-contaminated groundwater to prevent a risk to human health
Has been used at the site to remove residual DNAPL in soils in the release areas Impractical to recover residual DNAPL at depth The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Intermediate cost Short time frame to cleanup if all residual source can be removed
Higher permeability zones are preferentially remediated On-going monitoring required No installation or on-going maintenance costs Long time frame to cleanup
Small-scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Intermediate installation and high on-going maintenance costs
MITEC 104e 02374
5 T l O Description of potentially viable remediation technologies (continued) PO
Table 3-2 O
RESPONSE REMEDIAL PROCESS g 5 ACTION TECHNOLOGY OPTIONS 5 m
r-m Source Chemical Ozone m Removal Oxidation Sparging q JO o n o
o
Potassium Permanganate Injection
Fentonss Reagent Injection
i co
Source In-Situ Steam Removal Thermal Stripping
Desorption
Electrical Resistance Heating
I Radio (pound Frequency
O m Heating OH 3) gt Z 0)
DESCRIPTION
Injection of air and encapsulated ozone beneath the water table to oxidize dissolved DNAPL constituents such as TCE
KMn04 is injected below the water table to oxidize dissolved DNAPL constituents
Fentons Reagent is injected below the water table to oxidize dissolved DNAPL constituents
Stream injected below the water table As the groundwater and soil are heated residual DNAPL is mobilized and collected by groundwater and soil vapor extraciion techniques
Low frequency alternating current is applied below the water table to cause resistive heating ofthe soil and groundwater As the groundwater and soil heat residual DNAPL is mobilized Groundwater and soil vapor extraction techniques are used to collect dissolved and vaporized DNAPL constituents
Electromagnetic radiation is applied below the water table As the groundwater and soil heat residual DNAPL is mobilized
INITIAL SCREENING COMMENT
Presence of DNAPL will potentially require large quantities of ozone The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Small scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Ozone is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of KMn04 The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of Fentons Reagent The exact location of the residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Fentons Reagent is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Small scale heterogenieties can result in channeling during steam injection and reduce the recovery efficiency Shallow depth of application may preclude effective steam control The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeneity has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeniety has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult so target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
_ mdash_ mdash _ _
MITEC I04e 02375
bulln Table 3-2 Description of potentially viable remediation technologies (continued) o
R E S P O N S E
A C T I O N
tn Source Removal
Source Containment Plume Management
co bull
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REMEDIAL
TECHNOLOGY
Chemical Flushing
Hydraulic Containment
Impermeable Barrier
Permeable Reactive Barrier
Phytoshyremediation
PROCESS
OPTIONS
bull
DESCRIPTION
Injection and recovery of alcohol polymers andor surfactant below the water table to enhance dissolution of residual DNAPL
Pump groundwater in downgradient portion of VOC-contaminated region groundwater to intercept contamination before it reaches a receptor or downgradient ofthe highest concentrations as source containment
Impermeable barrier is installed in the subsurface to contain groundwater and reduce the pumping rate needed for containment Can be installed upgradient of a receptor to prevent exposure or downgradient of the highest concentrations as source containment
Reactive material such as zero valent iron placed in flow path of contaminated groundwater Contaminants are treated as the natural gradient causes groundwater to flow through the barrier
Extracting of contaminated groundwater by evaporation from high water use trees Organic contaminants may also be biodegraded by the root system or may adsorb to living or dead root tissue and become immobilized
INITIAL SCREENING C O M M E N T
Higher permeability zones are preferentially remediated The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Groundwater extraction is required to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent fulfresidual DNAPL removal Very high installation and operation cost
Effective in containing dissolved concentrations Relatively low installation cost moderate on-going maintenance costs
Effective in containing dissolved concentrations Requires groundwater extraction and treatment Moderate installation cost moderate on-going maintenance costs
Moderate installation costs Lifetime of reactive material difficult to predict and reinstallation may become necessary No on-going maintenance costs prior to replacement
Still experimental Hard to confirm water usage rates and prove containment Trees may require ongoing monitoring and replacement Low installation and maintenance costs Only operates during the growing season
MITEC 104e 02376
1 T l Table 3-3 Selection of potentially viable remediation technologies for detailed analysis 1
rt g g g
5
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RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Indoor Air Monitoring
Basement Sump Venting
Potable Use of Groundwater
Restrict Basements Below Water Table
Excavation
Natural Gradient Flushing
Air Sparging
Chemical Oxidation
In-Situ Thermal Desorption
Chemical Flushing
PROCESS
OPTIONS
No Action
Ozone Sparging
Potassium Permanganate Injection
Fentonss Reagent Injection
Steam Stripping
Electrical Resistance Heating
Radio Frequency Heating
RETAINED
DISCARDED
Retained
Retained
Retained
Retained
Retained
Retained
Retained
Discarded
Retained
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
RATIONALE
Used as a baseline for comparison
Necessary to evaluate if the region of VOC-contaminated groundwater is expanding in size and if the VOC concentrations in groundwater discharging to the unnamed brook are increasing
Necessary to monitor that concentrations remain below health risk levels
May be required al new residences with basements below the water table built in Browneil Road area
The existing sump vents at Lot 3-30 on South Browneil Road will be required to mitigate indoor air risks
Restriction of potable use of groundwater at properties overlying the region of VOC-contaminated groundwater will be required to prevent dermal ingestion and inhalation exposure
Restriction of construction of new basements below the water table in the area of VOC-contamination will be required to prevent future inhalation risks
Residual DNAPL located too far below ground surface to make excavation feasible The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Excavation of known release areas has occurred
Longer time frame to clean up not a drawback at this site Lower cost is a benefit
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location of the residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL Steam control difficult
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
MITEC 104e 02377
2 Table 3-3 Selection of potentially viable of remediation technologies for detailed analysis (continued) a m RESPONS E R E M E D I A L PROCES S RETAINED RATIONALE
ACTION T E C H N O L O G Y OPTION S DISCARDED
Source Containment Hydraulic Containment Retained Proven effective at containing expansion ofthe region of contaminated groundwater Region of Contaminated
iisect
n n o
Groundwater Management
Impermeable Barrier Retained Proven effective at region of contaminated groundwater containment
Permeable Reactive Retained Proven effective at region of contaminated groundwater containment Barrier
Phyto-remediation Retained Experimental however there are no potential negative consequences in using the technology Low cost is a benefit
co i
IO
I (A O m OH 73 gtZ
MITEC 104e 02378
4 DETAILED ANALYSIS OF ALTERNATIVES
41 ALTERNATIVE 1 NO ACTION
The no-action alternative is included in accordance with EPAs Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA (EPA 1988) The no-action
alternative provides a baseline for comparison and involves taking no additional actions at the
Study Area This remedy assumes no continuing monitoring of dissolved concentrations in
groundwater surface water or concentrations in indoor air This remedy assumes no institutional
controls on basement sump venting at Lot 3-30 on South Browneil Road property no restrictions
on new buildings with basements set below the water table constructed within the area of VOC
concentrations in groundwater and no restrictions groundwater use for potable purposes within
the region of VOC-contaminated groundwater
411 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community The risk assessment completed for the SIR
(HSI GeoTrans 2000) concluded that current conditions at the Study Area do not pose a risk to
human health Current conditions include venting ofthe sump at Lot 3-30 on South Browneil
Road no buildings other than at Lot 3-30 with basements below the water table in VOC-
contaminated areas and no potable-use wells within the region of VOC-contaminated
groundwater Without institutional controls to ensure this there may be future risk The risk
evaluation indicated that concentrations in the unnamed brook resulting from contaminated
groundwater discharge while not above risk-based thresholds were close to levels that could
pose a risk to human health Therefore monitoring is advised to confirm that VOC
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7533000AUJNOFS9^010030929WPD 4 - 1 HSI GGOTrSOS jflC
MITEC 104e 02379
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of VOC-contaminated groundwater could result in health risks not
evaluated in the risk assessment
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative
Time to Achieve Remedial Action Objectives It is estimated that the time frame required
for natural attenuation of contaminants to meet the groundwater cleanup concentrations will
significantly exceed the two-year time frame used to evaluate short-term effectiveness
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment There is no treatment of contaminants under this option
Reduction in Toxicity Mobility or Volume Some reduction of residual DNAPL and
accompanying dissolved concentrations is expected through natural attenuation over time if no
action were pursued at the Study Area However no monitoring data would be available to
confirm the progress
Amount of Material Contained or Treated Natural attenuation may serve to contain the
entirety of the region of groundwater contaminated with dissolved VOCs
413 LONG-TERM EFFECTIVENESS
Residual Risk Therisk assessment completed for the SIR (HSI GeoTrans 2000)
concluded that current conditions at the Study Area do not pose a risk to human health
However the risk evaluation indicated that concentrations in the unnamed brook resulting from
contaminated groundwater discharge while not above risk-based thresholds were close to levels
that could pose a risk to human health Therefore monitoring is advised to confirm that VOC
FOR ALLING INDUSTRIAL PARK
M W P _ D O C S N 7 5 3 2 0 0 0 A L U N O F S W raquo I 0 0 3 0 9 2 9 W P D 4-2 HSI GeOTrdDS IflC
deg2380
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of contaminated groundwater could result in health risks not evaluated in
the risk assessment Without institutional controls to ensure basement sump venting at Lot 3-30
on South Browneil Road restrictions on new buildings with basements set below the water table
within the region of VOC-contaminated groundwater and prevention ofthe installation of wells
for potable supplies within the region of VOC concentrations in groundwater a residualrisk to
human health remains
Adequacy and Reliability of Controls This remedy does not assume the sump in the
basement ofthe residence at Lot 3-30 on South Browneil Road remains sealed and vented to the
outside and that the pump is maintained in operable condition to continue to keep groundwater
out ofthe basement Previous air sampling conducted by the VTDEC has confirmed that this is
necessary to control indoor air impacts to this residence This remedy relies on natural
attenuation to control the region of VOC-contaminated groundwater however there is no
continuing monitoring of dissolved VOC concentrations in groundwater Since monitoring to
date has not confirmed that the region of VOC-contaminated groundwater is not expanding in
size a remedy which has a natural attenuation component but does not include monitoring does
not provide adequate control
Permanence of Remedy In the very long-term natural gradient flushing should reduce
VOC concentrations in groundwater to acceptable levels
414 COMPLIANCE WITH ARARs
Groundwater Protection Rule and Strategy It is expected that natural attenuation would
over time reduce groundwater concentrations to below VT Groundwater Enforcement Standards
However a no-action response would not comply with VT Groundwater Protection Rule and
Strategy (VTDEC 1997) which allows for remediation of sites by natural attenuation if sufficient
monitoring is perfonned to document that expansion ofthe region of contaminated groundwater
is not occurring and that natural attenuation is occurring The no-action alternative would not
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AU1NGFS90010030929wro 4-3 HSI GSOTraFIS IflC
MITEC 104e 02381
allow for continued monitoring and would not meet this requirement
Surface Water Quality Standards It is expected that natural attenuation would over
time reduce surface water concentrations to below VT Water Quality Criteria for the protection
of human health and aquatic organisms (VTDEC 2000)
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
concentrations of VOCs adsorbed to soil and dissolved in groundwater in the Study Area do not
pose a risk to human health andor the environment under current uses There would be arisk if
groundwater within the region of VOC-contamination were used as a potable supply Therefore
if dissolved concentrations were not migrating beyond the limits ofthe region identified in the
SIR (HSI GeoTrans 2000) and groundwater were not used for potable purposes the no action
alternative would be protective of human health and the environment However there are not
sufficient data to determine whether the region of VOC-contaminated groundwater is stable or
decreasing in size If the region of contaminated groundwater were expanding beyond the limits
upon which the risk assessment was based there may be a future risk to human health and the
environment Also restrictions should be placed on properties overlying the region of VOC-
contaminated groundwater to prohibit construction of basements below the water table and the
use of groundwater as a potable supply and the venting ofthe sump at Lot 3-30 should continue
416 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000AlXINGFS900U0030929wro 4-4 HSI GGOTrdRS IflC
MITEC 104e 02382
Technical Feasibility The no-action alternative is technically feasible
bull Ability to Construct the Alternative The no-action alternative requires no
construction
bull Reliability ofthe Technology No technology would be applied under the no-
action alternative
bull Ease of Undertaking Additional Remedial Actions The no-action alternative
would not prevent future remedial actions
Administrative Feasibility The no-action alternative is administratively feasible
Availability of Services and Materials No services or materials are required to carry out
the no-action alternative
417 COSTS
There are no costs associated with the no-action alternative The no-action alternative is
shown on Table 41 for purposes of comparison
4 2 A L T E R N A T I V E 2 M O N I T O R I N G INSTITUTIONAL C O N T R O L S AND
H Y D R A U L I C C O N T A I N M E N T
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull institutional controls would be implemented to restrict construction of any
buildings with basements within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull groundwater extraction and treatment would be done to contain the region of
VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753laquo000WJJNoFS9JXI10030929wro 4 - 5 HSI GSOTraDS JllC
MITEC 104e 02383
Groundwater pumping is an effective technology for hydraulic containment of
contaminated groundwater Hydraulic containment can be used if the region of VOC-
contaminated groundwater is impacting a sensitive receptor or is expanding is size The risk
assessment (Menzie Cura 2000a and 2000b) showed that groundwater was not impacting any
receptors to a degree that would represent a human health risk or risk to the environment There
is not sufficient temporal data however to confirm that the region of VOC-contaminated
groundwater is not expanding is size Therefore an analysis of hydraulic containment has been
included in this Corrective Action Feasibility Investigation in the event that future monitoring
shows the region of VOC-contaminated groundwater is expanding and that containment is
necessary
If monitoring indicates that natural attenuation is not causing the region of VOC-
contaminated groundwater to be stable in size or to shrink then an active containment remedy
may be required Under this scenario a groundwater pump-and-treat system would be installed
and operated in the Study Area to hydraulically contain contaminated groundwater and prevent
expansion ofthe region of VOC-contaminated groundwater Pumping wells would be installed
in the overburden silts and sands to the clay layer Wells would be installed in the downgradient
portions of contaminated groundwater to the southeast and southwest Extracted groundwater
would be treated before discharge to surface water The primary treatment operation will be air
stripping with a low-profile stripper for the removal of VOCs primarily TCE Depending on
treatment efficiencies secondary treatment with granular activated carbon may be required In
addition a particulate filter may be added to remove iron prior to treatment and reduce iron
fouling ofthe air stripper and carbon Extracted and treated groundwater would be discharged to
surface water via an outfall Compliance sampling can be conducted at the outfall or at a
sampling point within the treatment building The outfall should be constructed to minimize
hydraulic impacts on the receiving water body
The number and location of pumping wells that may be required to capture and contain
the region of TCE-contaminated groundwater has been investigated using the two-dimensional
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9JXA10030929WO 4-6 HSI GSOTfanS IdC
MITEC 104e 02384
analytical element simulation code TWODAN (Fitts 1997) TWODAN is a commercially
available copyrighted program The input parameters to the model are based on the values
reported in the SIR (HSI GeoTrans 2000) Input data sets for the analyses contained in this
report are included in Appendix A The bottom elevation ofthe model is 306 ft which is
representative ofthe top ofthe continuous clay layer beneath the site The model represents the
interbedded silts and fine sand layer and the overlying medium to fine sand surficial unit as one
layer The hydraulic conductivity ofthe modeled layer is 184 ftday The estimated areal
recharge for the model is 10 inyr The basement sump at Lot 3-30 on South Browneil Road
pumps groundwater year round The resulting depression ofthe water table is represented by a
constant head of 33128 ft which is approximately 8ft below ground surface at that location
Groundwater elevations used in the model were based on an average ofthe July 1999 and
December 1999 potentiometric surface in wells with screened intervals intersecting the water
table The model representation of current hydrologic conditions at the Study Area is shown in
Figure 4-1 Groundwater elevations are shown in meters on this figure
Two containment scenarios were evaluated The first was a source control application in
which the TWODAN model was used to determine the number of wells and pumping rates
required to contain the 10000 to 20000+ ugL TCE concentration zone as shown in Figure 1-2
In this scenario pumping would contain the contaminated groundwater nearest the source(s)
Over time if new contamination is not allowed to migrate from the source(s) the VOC
concentrations in the rest ofthe region of contaminated groundwater would attenuate The
second scenario was a containment application in which the TWODAN model was used to
determine the number of wells and pumping rate required to contain the 1000 to 10000 (igL
TCE concentration zone as displayed in Figure 1-2 In this scenario pumping occurs in the
downgradient portions ofthe contaminated groundwater
Each recovery well was assumed to be 4 inches in diameter fully screened and have a
pumping rate of 5 gpm The pumping rate was based on the aquifer testing results reported in the
SIR (HSI GeoTrans 2000) applied to a fully screened extraction well The results ofthe model
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000A1XINOFS9JX)10030929WPD 4-7 HSI GSOTraDS IflC
MITEC 104e 02385
analyses indicate that a minimum of three 4-inch diameter recovery wells pumping at 5 gpm are
required to contain the 10000 to 20000+ ugL TCE concentration zone The results of this
model simulation are shown on Figure 4-2 The model analyses also indicated that a minimum
often 4-inch diameter recovery wells pumping at 5 gpm are required to contain the 1000 to
10000 ugL TCE concentration zone Figure 4-3 shows the results of this model simulation
Figures 4-2 and 4-3 also show that groundwater extraction for hydraulic containment may induce
infiltration of surface water in response to pumping thereby reducing the amount of water
flowing in the brook
421 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 2 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with extraction well construction and treatment plant construction Access by
unauthorized personnel would be restricted by fencing temporary barriers andor warning signs
The groundwater treatment building would be locked and secured A health and safety plan
(HASP) would be prepared for the remedial activities In conformance with Occupational Safety
and Health Administration (OSHA) regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative Suitable dust control measures would be implemented during
construction ofthe groundwater treatment system Additionally the treatment process is
expected to be relatively simple with a low potential for exceedance of discharge limitations
Monitoring ofthe treatment process would be performed
Time to Achieve Remedial Action Objectives The time estimated for well installation
system debugging and establishing hydraulic gradient control is three to six months The RAOs
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^XM0030929wro 4-8 HSI GSOTraOS IIIC
MITEC 104e 02386
for groundwater would be achieved when monitoring results indicated that VOC concentrations
had attenuated and groundwater standards had been met It is estimated that attenuation of VOC
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of recovered groundwater would remove some ofthe VOCs from
the aquifer This treatment would generate residuals such as used filters and spent carbon This
process is irreversible
Reduction in Toxicity Mobility or Volume Treatment ofthe extracted groundwater
would reduce its toxicity prior to surface water discharge Contaminants adsorbed to any
secondary carbon would ultimately be destroyed during the process of regenerating the carbon
Contaminants adsorbed to any particulate filters would be landfilled or incinerated along with the
filters The toxicity and volume of contamination in groundwater are nominally reduced by
extraction and treatment but effectiveness is limited as discussed in Section 421 above
Modeling shows that groundwater extraction would be effective in reducing the mobility ofthe
dissolved phase contamination
Amount of Material Contained or Treated The volume of contaminated groundwater
that would be treated on a long-term basis is estimated at about 8 million gallons per year for the
source containment option and about 26 million gallons per year for containment of all dissolved
TCE concentrations greater than 1000 ugl
423 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
FOR ALLING INDUSTRIAL PARK MWPJXXTSN75320(XAAUJNOFS9-OCM0030929WKgt 4-9 HSI GSOTrSDS IDC
MITEC 104e 02387
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Groundwater pumping would control any risks caused by expansion ofthe
region of contaminated groundwater Residual risk to human health would be controlled through
institutional controls
Adequacy and Reliability of Controls Extracted groundwater would be treated on-site to
standards required for discharge to surface water The extraction well pumps and groundwater
treatment equipment would require maintenance on a long-term basis Groundwater monitoring
to ensure that the contamination was being adequately contained by the groundwater extraction
would be necessary on a long-term basis
Permanence of Remedy The groundwater treatment plant would be enclosed and
designed as a modular system and its equipment would be readily replaceable if required The
extraction wells may need to be rehabilitated andor replaced during the life ofthe remedy
424 COMPLIANCE WITH A R A R S
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to return the
remaining groundwater to below Groundwater Enforcement Standards Groundwater extraction
would also eventually return the areas of highest groundwater contamination to below
Groundwater Enforcement Standards
Surface Water Quality Standards Hydraulic control of the groundwater migration would
interrupt and remove contaminates from groundwater thereby preventing discharge to the
unnamed brook resulting in achievement of Water Quality Criteria for the protection of human
health and aquatic organisms (VTDEC 2000)
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200OALUNoFS9^Kgtl0030929wro 4-10 HSI GOOTrSDS IDC
laquoTEC I04e 02388
425 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The hydraulic containment alternative would offer protection to both human health and
the environment if expansion ofthe region of contaminated groundwater were identified Since
the risk assessment (Menzie Cura 2000a) found that under current conditions groundwater and
surface water concentrations are below levels which constitute a risk to human health and since
hydraulic containment would ensure the region of VOC-contaminated groundwater remained in
the current configuration hydraulic containment would be protective of human health and the
environment This alternative assumes institutional controls will be in place to continue sump
venting in the basement at Lot 3-30 on South Browneil Road restrict the installation of
basements below the water table within the region of VOC-contaminated groundwater and
prevent potable use of groundwater within the region of VOC-contaminated groundwater
Protection would be achieved at the end ofthe construction period of three to six months The
residual risks posed by contaminated material remaining within the groundwater would not be
significant because all potential exposure routes would be addressed
426 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction which would present no special problems
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AUB4CFS9^10l0030929wro 4 - 1 1 HSI GGOTrdDS IDC
MITEC 104e 02389
bull Reliability ofthe Technology Hydraulic gradient control is a frequently used
alternative that has proven effective in preventing further expansion of areas with
- contamination in groundwater Filtration air stripping and carbon absorption
have frequently been used and proven effective in treating groundwater in other
applications
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the
gradient control system was inadequate to restrict the expansion ofthe region of
contaminated groundwater implementation of additional resources would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
operate maintain and monitor the well head portions ofthe treatment system Institutional
controls would also be needed to implement institutional controls to continue sump venting in
the basement at Lot 3-30 on South Browneil Road The town must pass zoning restriction which
would prevent construction of basements below the water table and potable use of groundwater
within the region of contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor the groundwater treatment system associated with the hydraulic containment option
are available
427 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 2 The
capital costs would be $207000 for the source control application and $732000 for the
containment option OampM costs include groundwater monitoring and maintenance ofthe
groundwater extraction and treatment system These are $77000 per year for the source control
application and $139000 per year for the containment option The present worth analysis
(calculated at a 7 discount rate interest for 30 years) yields a total of $1085403 for the source
control application and $2287474 for the plume containment option
FOR ALLING INDUSTRIAL PARK MWPJXXSN753U0OOALUNGFS9-tfW0030929wro 4-12 HSI GSOTrailS IRC
MITEC 104e 02390
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS AND
PERMEABLE REACTIVE BARRIER
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull and a permeable reactive barrier would be installed and maintained at a
downgradient location to reduce concentrations of TCE dissolved in groundwater
as it flows under natural gradient flow conditions if groundwater monitoring
shows the region of VOC-contaminated groundwater is expanding in size
PRBs consist of a permeable region of chemically reactive materials constructed to
intercept the path of a dissolved groundwater contaminants Reactive materials may include
bull zero-valent iron for reductive dehalogenation
precipitation agents such as gypsum to create insoluble metal salts
bull sorptive agents such as granular activated carbon to capture and immobilize organics
bull reducing agents such as dithionite and hydrogen sulfide to reduce and insolubilize metals
and
bull biologic electron acceptors such as lactic acid or nitrate to enhance aerobic
biodegradation
FOR ALLING INDUSTRIAL PARK MAWPJX)CSVN7532000AmNOFS9-OOU0030929wpo 4-13 HSI GSOTrSDS IDC
MITEC 104e 02391
Zero-valent iron and granular activated carbon are both applicable for use in the treatment
of TCE in a PRB Granular zero-valent iron has been widely applied in PRB installations and
promotes reductive dehalogenation of TCE to chloride ion ethane and ethene Activated carbon
has been used in a limited number of field and lab studies to simply adsorb dissolved organic
constituents as they pass through thePRB
Because ofthe costs ofthe reactive or adsorptive material PRBs are generally
constructed as a funnel and gate system The funnel portion ofthe PRB is a typical vertical
barrier wall constructed of sheet piles bentonite or other impermeable material which is
designed to direct groundwater flow to the gate portion ofthe PRB containing the reactive or
adsorptive material Funnel and gate sections ofthe PRB are keyed together and generally to a
low permeablility zone located at depth
The use of permeable reactive barriers is not directly applicable to treatment of DNAPL
The mechanism for groundwater remediation using a PRB would include
bull dissolution ofthe DNAPL into groundwater by natural processes
bull downgradient transport ofthe dissolved contaminants to the PRB location
artificial channeling ofthe contaminated groundwater to the reactive material located in
the gate by the barrier funnel and
bull reductive dehalogenation or adsorption of a portion ofthe VOC as is passes through the
gate
A variety of methods are available for emplacement ofthe PRB The most conventional
method includes excavation of a trench and backfill will a soilbentonite slurry for the funnel
portion and granular iron or carbon in the gate section Other methods such as sheet-piling jet
grouting continuous trenching fracturing and others are available For the subject site because
ofthe presence of sand in the formation it is likely that a continuous trenching method would be
the most applicable and cost effective
FOR ALLING INDUSTRIAL PARK MWPJX)CSN7S320O0ALUNGFSraquo-O0U0030929wro 4-14 HSI GGOTfaDS IOC
MITEC 104e 02392
Operation maintenance and monitoring ofthe PRB is relatively simple Groundwater
samples would be periodically collected from locations upgradient and downgradient ofthe gate
section(s) ofthe PRB to monitor its effectiveness Media installed in the gate (iron or carbon)
would require periodic replacement probably on a annual basis for carbon and every 5 to 10
years for iron
The placement depth width and length ofthe PRB would depend on the region of
VOC-contaminated groundwater that was desired to be intercepted the depth to the underlying
low permeability layer and the desired TCE concentration reduction (which determines resident
time required in the gate) As wilh hydraulic containment two scenarios were investigated The
first a source control option would intercept VOC-contaminated groundwater with TCE
concentrations greater than 10000 ugL A PRB of approximately 1200 feet in length would be
required The second a region of contaminated groundwater containment option would
intercept VOC-contaminated groundwater with TCE concentrations in excess of 1000 ugL A
PRB of approximately 2200 feet in length would be required The depth ofthe PRB in both
cases would likely extend from ground surface to about 40 feet below ground surface The PRB
would be installed into the underlying areally-extensive clay layer Figure 4-4 shows the
placement ofthe PRB under each opinion
431 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 3 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with PRB construction since either conventional or continuous trenching methods
would be employed during its construction However exposure hazards during construction
would be considerable since the emplacement requires excavation and handling of a large
volume of potentially contaminated soils During construction access by unauthorized personnel
would be restricted by fencing temporary barriers andor warning signs Following
FOR ALLING INDUSTRIAL PARK
MWP_DOCSN753 2000 AUJNCFS9^10 10030929 WPD 4-15 HSI GSOTrSPS IDC
MITEC 104e 02393
construction little to no hazards should be expected from the long-term operation ofthe PRB A
HASP would be prepared for the construction activities In conformance with OSHA
regulations site workers would be trained required to wear appropriate protective equipment
and as applicable would be enrolled in a medical monitoring program Groundwater monitoring
wells would be sampled to determine changes in VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative with proper controls Suitable dust control vapor monitoring and
stormwater runoff measures would be implemented during construction ofthe PRB
Time to Achieve Remedial Action Objectives The time estimated for PRB emplacement
is four to six months The RAOs for groundwater would be achieved when monitoring results
indicated that the VOC concentrations have attenuated and groundwater standards have been
met It is estimated that attenuation of contaminant concentrations to ARARS will significantly
exceed the two-year time frame for short-term effectiveness This is because the application of a
PRB at the site would not significantly alter groundwater flow or TCE dissolution from within
the source area Therefore it would not increase the rate at which concentrations of residual
DNAPL or dissolved constituents of DNAPL (TCE) were removed from the source area It
would however limit the size ofthe region of VOC-contaminated groundwater
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of groundwater flowing through the permeable sections ofthe PRB
would remove the dissolved TCE as is flows under natural gradient conditions from the source
area
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNGFS9^X)10030929WPO 4-16 HSI G G O T T S O S jflC
MITEC 104e 02394
Reduction in Toxicity Mobility or Volume Treatment ofthe groundwater would reduce
its toxicity Contaminants adsorbed to carbon (if used as the treatment media in the gate sections
ofthe PRB) would be excavated on a periodic basis and ultimately be destroyed during the
process of regenerating the carbon
Amount of Material Contained or Treated The volumetric flux of contaminated
groundwater through the PRB is estimated to be approximately two million gallons per year for
the 10000 (igL source containment option and approximately four million gallons per year for
containment of all dissolved TCE concentrations greater than 1000 ugL
433 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Treatment of groundwater intersecting the PRB would control any risks
caused by expansion ofthe region of contaminated groundwater to the southeast Residual risk
to human health would be controlled through institutional controls
Adequacy and Reliability of Controls Performance of PRBs in reducing concentrations
of chlorinated organics such as TCE using zero-valent iron has been mixed Most ofthe PRB
performance demonstrations indicate that a concentration reduction of 60 to 90 percent can be
expected Some applications however have been much less successful at reducing VOC
concentrations Although little experience is available for PRBs using activated carbon the
removal efficiency should be expected to be greater and more reliable than zero-valent iron but
far more costly Groundwater monitoring would ensure that the contamination was being
adequately contained by the PRB and would be necessary on a long-term basis
Permanence of Remedy Installation of a PRB would be considered a permanent remedy
although periodic maintenance and replacement of reactive material in the gate would be
required for both carbon and iron-based systems
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9^X)l0030929wro 4-17 HSI GGOTfSnS IDC
MITEC 104e 02395
434 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to reduce VOC
concentrations in the remaining groundwater to below Groundwater Enforcement Standards
Natural gradient flushing would also eventually reduce the areas of highest groundwater
contamination to below Groundwater Enforcement Standards
Surface Water Quality Standards VOC concentrations in groundwater discharging to the
unnamed brook would be reduced significantly Thus operation ofthe PRB would result in
achievement of Water Quality Criteria for the protection of human health and aquatic organisms
(VTDEC 2000)
435 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This downgradient containment alternative would offer protection to both human health
and the environment if VOC concentrations in groundwater discharging to the unnamed brook
were to increase or if the region of contaminated groundwater were to expand in size This
alternative assumes institutional controls will be in place to continue sump venting in the
basement at Lot 3-30 on South Browneil Road restrict installation of new basements below the
water table within the region of VOC-contaminated groundwater and prevent potable use of
groundwater within the contaminated region Protection relative to the risks posed by expansion
ofthe region of contaminated groundwater to the unnamed brook would be achieved at the end
ofthe construction period of four to six months The residual risks posed by contaminated
material remaining within the groundwater would not be significant because all potential
exposure routes would be addressed
FOR ALLING INDUSTRIAL PARK MWP JX3CSN753V2000AIXINOFS90Crl0O30929wPD 4-18 HSI GCOTtSHS IRC
MITEC 104e 02396
436 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
bull Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction Removal and handling of contaminated soils
presents potential risks to construction workers during construction which could
be minimized through health and safety controls
bull Reliability of the Technology Although many full-scale applications of this
approach have been conducted they have been relatively recent Long-term
reliability and effectiveness of PRBs has not been established
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the PRB
was inadequate to prevent expansion ofthe region of VOC-contaminated
groundwater implementation of additional resources would not be hampered by
this alternative
Administrative Feasibility Installing and maintaining the PRB will require access to
properties overlying the region of VOC-contaminated groundwater Additionally property
owner cooperation would be needed to operate maintain and monitor wells located upstream
and downstream ofthe gate sections ofthe PRB system Restrictions would also be needed to
implement institutional controls to continue sump venting in the basement at Lot 3-30 on South
Browneil Road restrict the construction of basements below the water table within the region of
VOC-contaminated groundwater and prevent potable use of groundwater within the region of
VOC contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UO(XAAUJNOFS9-O0 10030929 WPO 4-19 HSI GGOTrSMS IDC
MITEC 104e 02397
Availability of Services and Materials The materials equipment and personnel required
to design install and maintain the PRB are readily available
437 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 3 The
capital costs would be $572000 for the source control application and $1022000 for the
containment option OampM costs include groundwater monitoring and periodic replacement of
the permeable barrier These average $64000 per year for the source control application and
$112000 per year for the containment option The present worth analysis calculated at a 7
discount rate over a 30-year duration yields a total of $1277356 for the source control option
and $2248691 for the containment option
4 4 A L T E R N A T I V E 4 M O N I T O R I N G I N S T I T U T I O N A L C O N T R O L S AND
N A T U R A L A T T E N U A T I O N
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water
The chief mechanisms contributing to reduction of contaminant concentrations in
groundwater by natural attenuation include biotransformation dilution dispersion and discharge
through advective flow and volatilization (EPA 1998) Volatilization is not likely a major
mechanism at the Study Area since contaminated groundwater is located at depth below the
FOR ALLING INDUSTRIAL PARK
MWP_DOCSW7S3U000WXINoFS9-001003O929wro 4-20 HSI GGOTfaDS IDC
MITEC 104e 02398
water table A natural attenuation evaluation will be conducted to better identify the mechanisms
contributing to concentration reduction through natural attenuation Monitoring to be completed
for this evaluation is included in Section 62 EPAs Technical Protocol for Evaluating Natural
Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) was used as the basis for the
design ofthe natural attenuation evaluation
441 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community A HASP would be prepared for the remedial
activities In conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Groundwater monitoring wells would be sampled to determine changes in
VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative
Time to Achieve Remedial Action Objectives The RAOs for groundwater would be
achieved when monitoring results indicated that the region of contaminated groundwater had
naturally attenuated and groundwater standards had been met It is estimated that natural
attenuation of contaminants to ARARS will exceed the two-year time frame for short-term
effectiveness
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0ALUNOFS9^X)M0030929wro 4-21 HSI GGOTfaflS jflC
MITEC 104e 02399
Treatment This alternative involves only natural in-situ processes No remediation
wastes would be generated
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area
Amount of Material Contained or Treated Natural attenuation may serve to contain the
region of VOC-contaminated groundwater at the Study Area Treatment may be accomplished
through biotransformation ofthe contaminants to environmentally acceptable compounds
443 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation of VOC-contaminated groundwater at the Study Area
would eventually achieve the ARARs Residual risk to human health would be controlled
through institutional controls Implementing institutional controls to maintain the sump venting
at Lot 3-30 on South Browneil Road restrict the construction of basements below the water table
within the region of VOC-contaminated groundwater and to control the use of groundwater
within the region of VOC-contaminated groundwater for potable purposes would provide
protection against the potential for exposure
Adequacy and Reliability of Controls Monitoring for VOC concentration reductions in
groundwater and institutional controls would be the main controls of this alternative Sump
venting at Lot 3-30 on South Browneil Road would prevent indoor air impacts at this location
and restrictions on construction of basements below the water table would prevent future indoor
air impacts Control ofthe use of groundwater within the region of VOC-contaminated
groundwater for potable purposes would minimize potential use of groundwater with VOCs
above federal and state drinking water standards Groundwater monitoring would ensure that
attenuation of VOC concentrations was proceeding and provide for periodic assessment ofthe
region of VOC-contaminated groundwater in the Study Area
FOR ALLING INDUSTRIAL PARK bull MWPJXXSN7532000AUINOFS9-00I0O30929WPD 4 - 2 2 HSI GGOTPaMS IRC
MITEC 104e 02400
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time
444 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
445 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
446 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK _
M W P _ D O C S N 7 5 3 U O O O A L U N O F S 9 - O O U 0 0 3 0 9 2 9 W P O 4-23 HSI GGOT 13118 IflC
MITEC 104e 02401
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
bull Ability to Construct the Alternative No major construction is included in this
alternative
bull Reliability ofthe Technology Ongoing monitoring and evaluation on would
ensure that natural attenuation was controlling and remediating the contaminated
groundwater
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation was not restricting the size ofthe region of VOC-contaminated
groundwater implementation of additional remedial actions would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
sample and maintain monitoring wells Restrictions would also be needed to implement
institutional controls to continue sump venting in the basement at Lot 3-30 on South Browneil
Road restrict construction of basements below the water table in VOC-contaminated
groundwater and prevent potable use of groundwater within the region of VOC-contaminated
groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor natural attenuation are also available
447 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 4 The
capital costs would be $55000 and include the initial natural attenuation evaluation and the
implementation of institutional controls OampM costs include groundwater monitoring These are
$9000 per year The present worth analysis yields a total of $163083 for this 30-year
alternative
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0AUJNOFS9^X)10030929wro 4-24 HSI GGOTraDS 1110
MTECl04e 02402
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water and
phytoremediation would be used to intercept TCE-contaminated groundwater
where it discharges to the unnamed brook
In this alternative all components of Alternative 4 would be implemented and
phytoremediation would be implemented in the area where TCE- contaminated groundwater
intersects the unnamed brook to intercept the contaminated groundwater and reduce the amount
of VOCs reaching the brook Phytoremediation of VOCs is still an experimental technology
Several field studies have used hybrid poplars (EPA 2000) to extract TCE- contaminated
groundwater It has been shown that TCE is removed along with groundwater by the trees and
metabolized as well as transpired from the leaves The rate of TCE contaminant removal from
the groundwater and its discharge to air by transpiration varies based on site specific conditions
and season Therefore contaminant or groundwater removal rates are impossible to predict at
this time without field studies Trees may be subject to destruction by natural disasters and pests
Their condition must be monitored and they may require replacement
F O R ALLING INDUSTRIAL PARK MWPJXXSN7532OOOWXINGFS9JraquoIOO30929WPO 4 - 2 5 H S I G G O T r S D S IOC
MITEC 104e 02403
In order for interception ofthe region of contaminated groundwater to be effective the
trees must be planted so that the root zone intercepts the contaminated groundwater Due to the
depth ofthe higher VOC concentrations in most areas ofthe site phytoremediation would be
ineffective in containing expansion ofthe region of contaminated groundwater An exception to
this is the area near the unnamed brook According to the SIR (HSI GeoTrans 2000) VOC-
contaminated groundwater appears to be discharging upward in groundwater into the unnamed
brook Trees planted along the border ofthe brook may help to intercept this contaminated
groundwater before it discharges into the brook
451 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 5 are as follows
Protection of Workers and the Community Normal landscaping hazards would be
associated with installation ofthe trees A HASP would be prepared for the remedial activities
In conformance with OSHA regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative Suitable dust control measures would be implemented during
planting of trees
Time to Achieve Remedial Action Objectives The time required for maximum
interception ofthe contaminated groundwater by the trees would depend on site specific
conditions such as root growth rate and tree survival rate The RAOs for groundwater would be
achieved when monitoring results indicated that VOC concentrations had attenuated and
groundwater standards had been met It is estimated that natural attenuation of contaminant
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
FOR ALLING INDUSTRIAL PARK MWP J X 3 C S N 7 5 3 2 0 0 0 A U J N O F S 9 ^ ) 0 1 0 0 3 0 9 2 9 W P D 4-26 HSI G G O T H S I I S IDC
MITEC 104e 02404
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment This alternative involves only in-situ treatment ofthe groundwater Plant
tissue would be analyzed for the presence of VOCs Plant materials can bio-accumulate metals
present in soil and groundwater If concentrations are high enough dead plant matter may have
to be disposed in an appropriate manner
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area Phytoremediation may
metabolize some ofthe VOCs
Amount of Material Contained or Treated Natural attenuation and phytoremediation
may serve to prevent expansion ofthe region of VOC-contaminated groundwater at the Study
Area Treatment is accomplished with biotransformation ofthe contaminants to environmentally
acceptable compounds
453 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation ofthe region of VOC-contaminated groundwater and
phytoremediation at the Study Area would eventually achieve the ARARs Implementing
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil Road
restrictions on construction of basements below the water table in regions of VOC-contaminated
groundwater and to control the use of groundwater for potable purposes within the region of
VOC-contaminated groundwater would provide protection against the potential for exposure
FOR ALLING INDUSTRIAL PARK MWP_IXXSW532000ALL1NOFS9^)0I0030929WTO 4-27 HSI GCOTraDS IflC
M l T E C l 0 4 e 0240S
Therefore despite the fact that an extended time period may be required to reduce VOC
concentrations to an acceptable level the residual risk associated with this alternative would be
minimal Trees planted near the unnamed brook may serve to intercept contaminated
groundwater before it discharges to this receptor
Adequacy and Reliability of Controls Groundwater monitoring for natural attenuation
institutional controls and interception of contaminated groundwater before it reaches the
unnamed brook would be the main controls of this alternative Sump venting at Lot 3-30 on
South Browneil Road would prevent indoor air impacts at this location and restriction on the
construction of new basements below the water table within the region of VOC-contaminated
groundwater would prevent future indoor air impacts at other locations Control ofthe use of
groundwater for potable purposes within the region of VOC-contaminated groundwater would
minimize potential use of groundwater with VOCs above federal and state drinking water
standards Groundwater monitoring would ensure that natural attenuation of contaminants was
proceeding and provide for periodic assessment ofthe region of VOC-contaminated groundwater
in the Study Area Groundwater and surface water monitoring would also be conducted to
monitor success ofthe phytoremediation in intercepting contaminated groundwater before it
reaches the unnamed brook
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time Trees must be monitored and will be replaced in
the event of destruction by severe weather pests or other reasons
454 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUINOFS9-00I0030929WPD 4-28 HSI GGOTraflS IllC
MITEC 104e 02406
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
Phytoremediation at the edge ofthe unnamed brook would further reduce the VOC
concentrations in groundwater discharging to the brook
455 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
456 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
Ability to Construct the Alternative Installation of this alternative requires
landscaping skills which are readily available
bull Reliability ofthe Technology Ongoing monitoring and evaluation would ensure
that natural attenuation was controlling and remediating the contaminated
groundwater Ongoing monitoring ofthe condition ofthe trees would also be
required to ensure they are continuing to grow and do not need replacement
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^)OM0030929WPD 4-29 HSI GGOTfaDS jflC
MITEC 104e 02407
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation and phytoremediation were not restricting the size ofthe region of
VOC-contaminated groundwater implementation of additional resources would
not be hampered by this alternative
Administrative Feasibility Planting trees and if necessary installing and monitoring
additional wells might require access to private property Additionally property owner
cooperation would be needed to sample and maintain monitoring wells Restrictions would also
be needed to implement institutional controls to continue sump venting in the basement at Lot 3shy
30 on South Browneil Road restrict construction of new basements below the water table in
regions of VOC-contaminated groundwater and prevent potable use of groundwater within the
region of VOC-contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to plant the trees and monitor natural attenuation are also available
457 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 5 The
capital costs would be $80000 and include the initial natural attenuation evaluation the
implementation of institutional controls and installation of a phytoremedial barrier of poplars
OampM costs include groundwater monitoring and maintenance ofthe phytoremedial barrier
These are $11000 per year The present worth analysis yields a total of $209397 for this 30shy
year alternative
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000ALLINOFS9^)0I0030929WPD 4-30 HSI GGOTfaDS IPC
MITEC 104e 02408
r TI Table 41 Cost estimates for remedial alternatives i deg 5 70
8 P
QUANTITY UNITS UNIT C O S T CAPITA L C O S T ANNUAL
OampM C O S T
5 n Alternative I No Action 8 O a Q
na na $0 $0 $0 a sect
Total $0 $0
Alternative 2 Monitoring Institutional Controls and Hydraulic Containment
1) Implement Institutional Controls 32 properties $10000 $32000
2) Groundwater Monitoring $9000
3) Pumping System
Option 1 Source Containment
Extraction wellspiping $50000 $15000
Electrical distributioncontrol $25000 $8000
Construction oversight $25000
Groundwater treatment system $75000 $45000
Total Option 1 $207000 $77000
Option 2 region of contaminated
groundwater Containment
Extraction wellspiping $175000 $35000
w Electrical distributioncontrol $50000 $20000
O
o H mO Construction oversight $125000
o n gt Groundwater treatment system $350000 $75000
o z 0) Tolal Option 2 $732000 $139000
i deg QUANTITY UNITS UNI T C O S T
5 so
Alternative 3 Monitoring Institutional Controls and Permeable Barrier
m t - 1) Implement Institutional Controls 32 properties $10000
9 O 2) Groundwater Monitoring
| o 3) Permeable Harrier
Option I Source Containment
Barrier installation 1200 feel $450
Total Option 1
Option 2 region of contaminated
groundwater Containment
Barrier Installation 2200 feet $450
w Total Option 2 NJ
Alternative 4 Monitoring Institutional Controls and Natural Gradient Flushing
1) Implement Institutional Controls 32 properties $10000
2) Groundwater Monitoring
3) Natural Attenuation Evaluation
Total
Alternative 5 Monitoring Institutional Controls Natural Gradient Flushing and Phytoremediation
1) Implement Institutional Controls 32 properties $10000 X (A 2) Groundwater Monitoring
reg 3
o m O H
3) Natural Attenuation Evaluation
4) Phytoremediation
gt z Total (A
Notes na = not applicable
CAPITAL C O S T
$32000
$540000
$572000
$990000
$1022000
$32000
$23000
$55000
$32000
$23000
$25000
$80000
ANNUAL
OampM C O S T
$9000
$55000
$64000 1
$103000
$112000
$9000
$9000
$9000
$2000
$11000
MODEL CALCULATED GROUNDWATER CONTOUR IN FEET ABOVE MEAN SEA LEVEL
APPROXIMATE PROPERTY BOUNDARY
M6-2 raquo EXISTING MONITORING WELL
CP-6 bull EXISTING SOIL BORING
M 8 - 2 raquo MONITORING WELL (RESAMPLED)
bull SMALL DIAMETER BORING - BELOW CLAY
bull BEDROCK MONITORING WELL
A S I - 2 I H S I GEOTRANS WELL CLUSTER LOCATION
U-TRIB-8a SURFACE WATER SAMPLING LOCATION R S - U
a PASSIVE SAMPLER LOCATION
T2-2 PROFILE SAMPLE LOCA1ION (JOHNSON COMPANY 1999)
WELL DESTROYED
TEF Concentrat ions ( u g A l
1000 - 10000
iry IOOOO - 20000
bull 20000 + NOTES AREA WHERE TCE CONCENTRATION IS
M l LOCATIONS APPROXIMATE INTERPOLATED THERE IS NO TCE
BASE PUN DEVELOPED FROM DATA FROM THESE AREAS
1 TOWN OF WUUSION PARCEL BOUNOART MAP (SHIPPED 121597) PROVIDED ST (VS (BURUNCTON VT) IN DXF FORMAT
2 PLAN DEVELOPED BT HEINDEL AND NOTES (BURUNCTON VT) FOR THE BATES PROPER1Y 1NVESIBAT10N AND PROVIDED TO THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION HASTE MANAGEMENT DIVISION 1997
3 ORTHOPHOTO SHEET 100216 VERMONT STATE MAPPING PROJECT 1988
4 TORN OF WIUJSTON ASSESSORS MAP 1997
5 VARIOUS SITE PUVQ CN RLE WITH THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION WASTE HMUGElENr OOVBON
6 DM FROM JOHNSON DD REPORT UNTIED GROUNDWXIER IHVESI1CAH0M ALLWC INDUSTRIAL PARK DATED 7 W FDR THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Modeled Site - Existing Conditions copy H
pound n Williston Vermont o CHECKED MS HSI
DRAFTED RMK GEOTRANS FU fa-Site-mod-ECdwg 4 - 1 A TITIA T t n HBVAIT
DATE 10600
5 COMPARATIVE EVALUATION OF ALTERNATIVES
The purpose of this section is to compare the remedial alternatives on the basis ofthe
evaluation criteria developed and discussed in Section 4 and provide a recommended alternative
These criteria include overall protection of human health and the environment short-term
effectiveness reduction of toxicity mobility or volume long-term effectiveness and
permanence compliance with ARARs implementability and cost
The comparative analysis is conducted to highlight significant differences between
identified alternatives All alternatives for the Study Area groundwater except the no-action
alternative include the following
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater and
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
The no-action alternative is not included in the comparison provided in the following
sections since it would not meet the RAOs All four ofthe remaining alternatives would meet
the RAOs stated in Section 32
51 SHORT-TERM EFFECTIVENESS
Protection of Workers and the Community Groundwater would be monitored under all
scenarios to look for any changes in VOC concentration which might result in increased risk
The containment options in Alternatives 2 3 and 5 would be more protective ofthe community
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320MAUINOFSWWI0030929WPD 5 - 1 HSI GSOTrSflS IflC
MITEC 104e 02415
if the region of VOC-contaminated groundwater were shown to be expanding and presenting
increased risk However in the event that the region of VOC-contaminated groundwater is not
expanding Alternative 4 would be equally protective Under all options a HASP would be
prepared and in conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Alternatives 2 3 and 5 would involve normal construction hazards during
installation of pumping wells piping trenches treatment enclosures permeable reactive barrier
trenches or planting of trees In addition under Alternative 5 release of VOCs to air through
transpiration may need to be measured to prevent creation of a new exposure pathway and health
risk through air
Environmental Impacts Minor additional impacts may occur during installation of
Alternatives 2 3 and 5 due to dust and sediment production Groundwater would need to be
treated to regulatory discharge limits before discharge under Alternative 2 and treatment may be
temporarily hampered in the event of treatment system mechanical failure Because ofthe
experimental nature of phytoremediation greater uncertainty exists that the trees will be effective
in acting as a barrier to expansion ofthe region of contaminated groundwater to the unnamed
brook under Alternative 5 If it is shown that expansion ofthe region of contaminated
groundwater toward the unnamed brook poses a future health risk additional measures may
become necessary to contain the contaminated groundwater
Time to Achieve Remedial Action Objectives None ofthe alternatives has an appreciably
shorter time frame than the others in reducing groundwater concentrations to VT Groundwater
Enforcement Standards and VT Water Quality Criteria This is because while Alternatives 2 3
and 5 rely on engineered remedies to contain the region of contaminated groundwater residual
TCE DNAPL and geologic heterogenieties will cause the contaminant source to persist for an
extended time As discussed in Section 34 active DNAPL removal alternatives were removed
during the preliminary screening DNAPL has never been directly observed at the Study Area
and is assumed to be present based on dissolved concentrations of TCE DNAPL distribution is
FOR ALLING INDUSTRIAL PARK MWP_DOCSW753200OALLINOFS9-00M0O30929wPD 5-2 HSI GGOTr3nS IflC
MITEC 104e 02416
expected to occur heterogeneously at residual saturation and it is infeasible to locate the DNAPL
to treat it directly Because of this each ofthe remedies is expected to exceed the two-year time
frame for short term effectiveness
52 R E D U C T I O N O F T O X I C I T Y M O B I L I T Y O R V O L U M E T H R O U G H
T R E A T M E N T
Treatment All ofthe proposed alternatives would treat the residual DNAPL source of
contamination through dissolution and natural gradient flushing While Alternatives 2 3 and 5
are intended primarily for containment and not groundwater restoration these alternatives would
actively treat some concentrations in groundwater
Reduction in Toxicity Mobility or Volume The containment Alternatives 2 3 and 5
may result in decreased mobility ofthe region of contaminated groundwater However
groundwater monitoring may show that the region of contaminated groundwater is not
expanding under existing conditions If this were the case containment would not result in any
additional decrease in size ofthe region of VOC-contaminated groundwater
Since Alternatives 2 3 and 5 treat concentrations in groundwater without treating the
residual DNAPL source and the amount of contaminants that can be removed from groundwater
by these methods would likely equal the amount added by continued dissolution ofthe DNAPL
sources alternatives 2 3 and 5 would not result in a greater reduction in the total volume of
contaminant than Alternative 4
Amount of Material Contained or Treated As described above the amount of material
contained under Alternatives 2 3 and 5 would not be any greater than under Alternative 4 unless
the size ofthe region of VOC-contaminated groundwater is not presently contained by natural
attenuation If natural attenuation is currently controlling the size ofthe region of VOC-
contaminated groundwater then the amount of contaminants being removed by natural processes
equals the amount added by dissolution of residual DNAPL In this case intercepting and
removing contaminants from the groundwater using one ofthe containment alternatives will not
result in a significant increase in the amount of contaminant treated
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000ALUNOFS9-OOUM30929WPD 5-3 HSI GGOTrdHS jflC
MITEC 104e 02417
53 LONG-TERM EFFECTIVENESS
Residual Risk Implementing institutional controls to maintain the sump venting at Lot 3shy
30 on South Browneil Road to restrict construction of buildings with basements below the water
table within the region of VOC-contaminated groundwater and to control the use of groundwater
for potable purposes within the region of VOC-contaminated groundwater would provide
protection against the potential for exposure to existing concentrations in groundwater
Therefore despite the fact that some ofthe remedial alternatives may be required to operate for
an extended time the residual risk associated with any ofthe alternatives would be minimal
Adequacy and Reliability of Controls Alternative 5 has the least reliable controls
because ofthe difficulty in predicting the effectiveness of phytoremediation The second least
reliable alternative would be Alternative 2 because of its reliance on mechanical equipment to
maintain containment and to meet discharge standards
Permanence of Remedy All ofthe proposed alternatives would rely on permanent
destruction of contaminants through natural attenuation over time If one ofthe containment
technologies are required maintenance and periodic replacement would be necessary to ensure
containment was maintained until expansion ofthe region of VOC-contaminated groundwater
was no longer a threat This maintenance would be straight-forward and easy to continue for any
of the containment alternatives
54 COMPLIANCE WITH ARARs
All ofthe alternatives would eventually reduce contaminant concentrations within the
current region of contaminated groundwater to below VT Groundwater Enforcement Standards
and VT Water Quality Criteria
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Each ofthe alternatives would rely on groundwater monitoring and institutional controls
on venting basement sumps at Lot 3-30 on South Browneil Road restrictions on the construction
of new basements below the water table within the region of VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWPJX3CSN7S3UOOOAUJNGFS9-OOUM30929wro 5-4 HSI GOTr3nS IflC
MITEC 104e 02418
and potable use of groundwater from within the region of VOC-contaminated groundwater to
maintain conditions protective of human health and the environment If monitoring shows that
natural attenuation is not restricting the size ofthe region of VOC-contaminated groundwater
then one ofthe containment alternatives would be more protective than Alternative 4
56 IMPLEMENTABILITY
The most easily implemented alternativewould be Alternative 4 as it would not require
any installation but only groundwater monitoring to gauge the progress of natural attenuation
Alternative 5 requires all the components of Alternative 4 and adds trees along the unnamed
brook Alternatives 2 and 3 are the most difficult to implement as they require disruptive and
invasive installation techniques However the necessary equipment materials workers and
specialists required to implement all the alternatives are available
57 COSTS
The present worth costs range form a low of $163083 for Alternative 4 to a high of
$2287474 for the containment option of Alternative 3 These present worth costs were based on
a 30-year service period and an annual discount rate of seven percent
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALLINOFS9-OOM0030929WPD 5-5 HSI GGOTfaDS IflC
MITEC 104e 02419
6 PREFERRED REMEDY
61 PREFERRED REMEDY
Alternatives 2 34 and 5 are all protective of human health and the environment and rely
on the following technologies
bull groundwater monitoring to evaluate spatial and temporal trends in VOC
concentration
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil
Road
restrictions on the construction of new buildings within the region of VOC-
contaminated groundwater to prevent unacceptable concentrations of volatile
compounds in indoor air and
institutional controls to restrict the use of groundwater for potable purposes within
the region of VOC-contaminated groundwater
All ofthe alternatives rely on dissolution and natural gradient flushing to treat the
residual DNAPL source of groundwater contamination Therefore none ofthe alternatives has
an appreciably shorter time frame than the others in reducing groundwater concentrations to VT
Groundwater Enforcement Standards and VT Water Quality Criteria
Alternative 4 includes remediation by natural attenuation There is no active containment
technology associated with Alternative 4 As such it is simpler less costly and easier to
implement than Alternatives 2 3 and 5 which include some form of active containment ofthe
region of VOC-contaminated groundwater Containment could become necessary under
Alternative 4 if future groundwater quality monitoring indicates the region of VOC-contaminated
groundwater is impacting a sensitive receptor or is expanding in size and not contained by natural
attenuation The SIR (HSI GeoTrans 2000) risk assessment (Menzie Cura 2000a and 2000b)
showed that under current conditions groundwater was not impacting any receptors to a degree
FOR ALLING INDUSTRIAL PARK MWPJXXrSN7532000ALUNcFS9-OOU0030929WO 6 - 1 HSI GSOTraflS jflC
MITEC 104e 02420
that would represent a human health risk or risk to the environment Therefore containment is
not necessary to protect any sensitive receptors currently being impacted by the region of
contaminated groundwater Continued groundwater monitoring is required to demonstrate
whether the region of VOC-contaminated groundwater is stable in size or expanding
Alternative 4 has been selected as the preferred remedy On-going monitoring ofthe
effectiveness of natural attenuation in containing and remediating the region of VOC-
contaminated groundwater is part ofthe remedy Further details on this proposed monitoring are
provided in Section 62 If monitoring shows that size ofthe VOC-contaminated region is not
contained by natural attenuation then one ofthe other technologies could be used to supplement
Alternative 4 based on the nature ofthe expansion ofthe region of contaminated groundwater
If monitoring data indicates that VOC concentrations in the groundwater discharging to the
unnamed brook have increased and pose an unacceptable risk to human health and the
environment then phytoremediation could be considered in this location Phytoremediation
would be less costly than installation of a permeable reactive barrier or active groundwater
extraction system Phytoremediation would be ineffective in containing expansion ofthe region
of contaminated groundwater in the rest ofthe Study Area however because contaminated
groundwater is further below ground surface in these regions and phytoremediation is limited by
the depth ofthe roots ofthe selected plant If monitoring data indicates that the southwestern
portion ofthe region of VOC-contaminated groundwater is expanding then Alternative 4 could
be supplemented with extraction wells or a PRB for hydraulic containment
62 MONITORING PROGRAM
In its guidance document Use of Monitored Natural Attenuation at Superfund RCRA
Corrective Action and Underground Storage Tank Sites (EPA 1999) EPA states that long-term
performance monitoring will be a fundamental component of any remedy which relies on
monitored natural attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000 A1XINOFS9-00 I0030929 WPO 6-2 HSI GSOTrSDS IMC
MITEC 104e 02421
The SIR (HSI GeoTrans 2000) concluded that there were not sufficient temporal data to
determine whether the region of VOC-contaminated groundwater was stable in size or
expanding Continued monitoring for the compounds of concern will be necessary to confirm
that the region of VOC-contaminated groundwater is not expanding Table 6-1 identifies
locations which are proposed to be monitored annually to evaluate spatial and temporal trends in
VOC concentration These locations are shown in Figure 6-1
There are several mechanisms by which natural attenuation occurs These include
dilution of contaminant concentrations sorption ofthe contaminant onto the soil matrix and
biodegradation ofthe contaminant to a less toxic form Further study is necessary to determine
the contribution of each of these mechanisms to overall attenuation ofthe area of VOC
contamination
Evidence of biodegradation can be obtained by collecting three types of data of increasing
complexity (National Research Council 1993)
bull documentation of contaminant loss or transformation in the field
bull the presence of electron donors and acceptors andor alteration of groundwater
chemistry consistent with intrinsic biodegradation processes and
microcosm studies which provide direct microbiological evidence that indigenous
bacteria are capable of mediating the contaminant transformations observed
Microcosm studies are typically not employed unless the contaminant is unique or the
transformation which is being observed is not well documented in the literature For the
transformations anticipated in the Study Area numerous laboratory and field studies have
established that naturally-occurring bacteria are capable of mediating the contaminant
transformations of contaminants of concern For that reason microcosm studies will not be
performed as part of this study
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^)OM0030929 WPO 6-3 HSI GSOTrSHS jflC
MITEC 104e 02422
Of particular concern to the determination of biodegradation is the delineation of aerobic
and anaerobic zones within the contaminant area because these zones dictate the types of
biological degradation that would be expected to occur Oxygen is the primary electron acceptor
during aerobic oxidation Anaerobic processes including denitrification iron-reduction sulfate-
reduction and methanogenesis occur in the absence of oxygen and use nitrate iron (III) sulfate
and carbon dioxide respectively as primary electron acceptors Reductive dehalogenation of
TCE has been observed under iron-reducing sulfate-reducing and methanogenic conditions
although very low redox (ie methanogenic) conditions may be necessary for production of
ethene and ethane
Further sampling and analysis of selected parameters in groundwater will be conducted to
assess the potential for biodegradation in accordance with EPAs Technical Protocol for
Evaluating Natural Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) The
twelve sampling locations shown in Table 6-1 used to monitor ofthe area of VOC contamination
will also be sampled for parameters used to evaluate biodegradation The parameters include
compounds of concern and compounds which are degradation products ofthe compounds of
concern shown in Table 6-2 Table 6-3 lists parameters chosen to evaluate the presence of
electron donors and a groundwater chemical environment conducive to biologic reductive
dechlorination These parameters will be sampled once unless evaluation ofthe data indicates
that further sampling would be beneficial to calculate a rate of attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000ALUNCFS9JraquoM0030929 WPD 6-4 HSI GSOTfaHS IDC
MITEC 104e 02423
Table 6-1 Sampling locations
LOCATION
ID
ASI-32D2
RB-1
ASI-26D2
ASI-I6D2
ASI-13D2
ASI-23D2
ASI-18D2
ASI-12D2
ASI-01D2
ASI-09D2
U-TRIB-5
SW-I
Notes BGS =
SCREENED
INTERVAL
DEPTH BGS
35-40
35-40
35-40
30-35
31-36
25-30
32-37
35-40
31-36
31-36
surface
surface
Below Ground Surface
RATIONALE
Upgradient of region of highest VOC concentrations
Closest to lot 19-11 former lagoon and septic leach field source areas
Within area of highest concentrations
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient ofthe region of VOC concentrations in the southwest direction
Downgradient of source area within region of VOC concentrations in southeast direction
Downgradient of source area within region of VOC concentrations in southeast direction
At downgradient edge of region of VOC concentrations in southeast direction
Stream upgradient of VOC discharge from groundwater
Stream at location of VOC discharge from groundwater
(
FOR ALLING INDUSTRIAL PARK MWP DOCSN7532000ALUNCFS9^X)VI0030929WPO 6-5 HSI GeoTrans inc
MITEC 104e 02424
Table 6-2 VOC analytes
PARAMETER
TCE
PCE
11-DCE
cis 12-DCE
trans 12-DCE
Vinyl Chloride
Benzene
Toluene
Ethylbenzene
Xylenes
ANALYTICAL METHOD
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
8260A
8260A
8260A
8260A
RATIONALE |
Contaminant of Concern
Contaminant of Concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
Notes SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical
Methods SW-846 US EPA 3ri edition 1986
TCE = Trichloroethene
PCE = Tetrachloroethene
11-DCE = 11-Dichloroethene
cis 12-DCE = cis 12-Dichloroethene
trans 12-DCE = trans 1 2-Dichloroethene
FOR ALLING INDUSTRIAL PARK MAWP DOCSN75320laquoMLUNOFS9^XM0030929WPO 6-6 HSI GeoTrans inc
MITEC 104e 02425
Table 6-3 Parameters to evaluate biodegradation
PARAMETER ANALYTICAL METHOD RATIONALE
Field Parameters
Alkalinity as CaCO Hach Alkalinity Test Kit Model ALP Positive correlation between microbial activity and
MG-L alkalinity Measures the buffering capability of
groundwater
Total Ferrous Iron Hach Method 8146 May indicate anerobic degradation
Dissolved Hydrogen Reducing Gas Detector Predicts possibility for reductive dechlorination
Dissolved Oxygen Direct Meter Reading Indicates probability of aerobic vs aerobic
degradation
PH Direct Meter Reading Aerobic and anaerobic biological processes are pH
sensitive
Redox potential (Eh) A2580B An indicator ofthe relative tendency of a solution
to accept or transfer electrons
Specific Conductivity Direct Meter Reading Used to determine when purging of a well for
sampling is complete
Temperature Direct Meter Reading Affects the metabolic activity of bacteria and the
solubility of dissolved gasses
Laboratory Analyses
Dissolved Organic Carbon SW 9060 Carbon and energy source which can drive
dechlorination
Nitrate-N IC Method E300 At higher concentrations may compete with
reductive pathway
Total Manganese EPA 2007 or 2009 To determine if anaerobic biological activity is
solubilizing Mn for the aquifer matrix
Chloride SW 9250 Can be used as a conservative tracer to estimate
biodegredation rates
Sulfate IC Method E300 May be used as an electron acceptor for
biodegradation after dissolved oxygen and nitrate
are depleted
Sulfide IC Method E300 Indicates if reductive pathway is possible
Ethane SW 3810 Modified Daughter product of Ethene
Ethene SW 3810 Modified Daughter product of Vinyl Chloride
Methane SW 3810 Modified Ultimate reductive daughter product
Notes Rationales taken from USEPA 1998
Hach refers to Hach Company Catalogue
A refers to Standard Methods for the Examination of Water and (fostewater 18 edition 1992
E refers to Methods for Chemical Analysis of Water and Wastes US EPA 1983
SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical Methods SW-846 US EPA 31 edition
1986
FOR ALLING INDUSTRIAL PARK | C I nr A^Twmrmr bullbullltlaquo MWP DOCSN7532000ALLINCFS9-0Ol0030929wro 6-7
MITEC 104e 02426
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REFERENCES
Brinkerd 1996 Site Investigation Ailing Industrial Park Williston Vermont April to
September 1996 October 1996
Fitts C R 1997 TWODAN documentation prepared by Dr Charles Fitts Scarborough Maine
Griffin 1995 Monitor Well Log (MW-4) and Analytical Data Bove-Fagan Ice Cream
Distribution Investigation Williston VT Griffin International Inc
HSI GeoTrans Inc 2000 Site Investigation Report June 15 2000
Johnson 1999 Limited Groundwater Investigation N753 July 6 1999
Menzie Cura 2000a Screening Level Risk Characterization April 2000
Menzie Cura 2000b Addendum to Screening Level Risk Characterization June 1 2000
NRC 1993 National Research Council Committee on Bioremediation In Situ Bioremediation
When Does it Work Washington DC National Academy Press 1993
TRC 1993 Site Inspection-Ailing Industrial Park Williston Vermont VTD982748477 Final
Report
US EPA 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies
Under CERCLA OSWER Directive 93553-01
U S EPA 1992 Estimating Potential for Occurrence of DNAPL at Superfund Sites OSWER
Number 93554-07FS 9p
FOR ALLING INDUSTRIAL PARK MWP_DOCSW75JV20(XKALUNOFS9-0(AI0030929WPD 7 - 1 HSI GeOTTSHS irtC
MITEC 104e 02428
US EPA 1993 Guidance for Evaluating the Technical Impractibility of Groundwater
Restoration EPA540-R-93-080
US EPA 1998 Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents
in Ground Water EPA600R-9812~8
US EPA 1999 Use of Monitored Natural Attenuation at Superfund RCRA Corrective Action
and Underground Storage Tank Sites EPA Directive 92004-17P
US EPA 2000 Introduction to Phytoremediation EPA600R-99107
VTDEC 1996 Site Investigation Guidance August 1996
VTDEC 1997 Chapter 12 Groundwater Protection Rule and Strategy October 1997
VTDEC 2000 Vermont Water Quality Standards March 2000
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(AAUJNGFS9^)OM0030929WPD 7-2 HSI GSOTfanS tC
MITEC I04e 02429
APPENDIX A
TWODAN INPUT FILES
FOR ALUNG INDUSTRIAL PARK MWP_DOCSVN7S3200(AALUNOFS9-0(AI0030929WPO HSi GfiOTfanS WC
MITEC 104e 02430
i - i i a a o U 0 t A X H i d t l Z 018J UaiUEAJJLKATia Htj v j pound
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MITEC 104e 02431
15
6 Lancaster County Road HSI Harvard Massachusetts
GEOTRANS 01451 A TETRA TECH COMPANY 97^772-7557 FAX 978-772-6183
R E C E i ^ D PNN753-001
CUTLER A8TANPIELD Campltf December 11997
Mr Michael Smith Vermont Department of Environmental Conservation Waste Management Division 103 South Main Street Waterbury VT 05671-0404
Subject Proposed Surface Water Sampling MITEC Site Williston VT
Dear Michael
This letter describes the proposed surface water sampling at the MITEC site that we discussed during our meeting of November 201997 Our intention is to complete this work as soon as possible to avoid the complications of colder weather and possible freezing ofthe stream My understanding is that you are prepared to review and approve this plan fairly quickly and also to assist us with obtaining property access and appropriate maps to locate these sampling sites We appreciate this help In future we anticipate that the constraints of weather will not require such an expedited field mobilization process and that we will all have more time to prepare
Purpose and Extent of Sampling
The purpose ofthe surface water sampling is to further assess impacts to the unnamed tributary and to make preliminary inferences regarding the extent ofthe TCE plume currently migrating to the southeast across the Ailing Industrial Park by measuring the effects of its discharge to the stream To this end sampling locations have been chosen to 1) provide better spatial resolution in the area east of Commerce Street toward its southern end (SW-1 SW-2 SW-3 and S W-5) 2) assess the quality of surface water contributed by other tributaries (SW-4 SW-6) and 3) make preliminary estimates ofthe downgradient extent of impacts (SW-7 and SW-8) Samples from previously established sampling locations UTrib-6 7 8 1014 and 18 will also be obtained A total of 14 samples will be collected The proposed sampling locations
L-W7jni20iiooonl
MITEC 104e 02432
Michael Smith 2 December 11997
are indicated on the attached maps which depict the site at two different scales The first is a site map taken from the Binkerd report and shows the previous sampling locations east of Commerce Street as well as proposed new locations SW-1 SW-2 and SW-3 The second map shows the site and the surrounding area including the more downstream locations
Methods
At each proposed location a number of water quality indicators will be measured including temperature pH redox potential dissolved oxygen and conductivity Samples for volatile organic compound (VOC) analysis will be obtained in triplicate using a stainless steel sampling container samples will be transferred immediately to 40 mL glass vials with teflon septa and preserved with hydrochloric acid Each sample will be submitted to a local analytical laboratory for a screening level analysis of VOCs Three selected samples will also be analyzed using EPA Method 8260 The appropriate level of documentation will be generated for these samples such that laboratory analytical results can be validated to EPA Region 1 level Tier II This will require the collection and analysis of a duplicate sample a trip blank a field blank and matrix spikematrix spike duplicate samples
Sincerely
f i t mdash Peter ZeebPhD Senior Hydrogeologist
cc Sandy Feldman Sheila Jones
PZmm
m w MITEC 104e 02433
HSI GEOTRANS
LEGEND O Honrtorog Veil
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Figure 11 Station location map O Surface Water
Qfor monitoring wells borings and surface water MITEC 104e
02434
HD BINKERD ENVIRONMENTAL
HSI bull bull
GEOTRANS if prsTAOC
6 Cancaster County Road
A TETRA TECH COMPANY
Harvard Massachusetts 01451 faL32 HMETER 3 4 r t
Sheila Jones Esq Cutler and Stanfield 700 Fourteenth Street NW Washington DC 200052010
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Harvard Massachusetts 01451 GEOTRANS
A T E T R A T E C H C O M P A N Y 978-772-7557 FAX 978-772-6183
PN N753-002
May 111999 RECEIVED
MAY t 3 1999 Mr Michael Smith
CUTLER ampSTANrlc-uAgency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Dear Mike
Based on the site walkover and well inventory ofthe existing monitoring well network completed on April 201999 HSI GeoTrans determined that several monitoring wells proposed for sampling and monitoring in the Work Plan are not accessible or are damaged or missing Outlined below are the actions we will undertake to resolve the outstanding issues with the monitoring well network
As ofthe date of this letter access to the Bates well network has not been obtained The Work Plan identified eleven off property well clusters installed by the Bates and two wells installed by the State on the Bates property to be included in the sampling and monitoring activities for the Site Investigation (BW-2 BW-5 BW-7 BW-8 BW-9 BW-11 BW-12 BWshy13 BW-17 BW-18 BW-19) Ten ofthe off property clusters were included in the sampling plan and all eleven were included in the site water level round The wells installed by the State on the Bates property were included in the both sampling and water level rounds Replacement of eight ofthe well clusters slated for groundwater sampling is recommended (BW-5 BW-8 BW-9 BWshy12 BW-13 BW-17 BW-18 BW-19) The remaining Bates wells do not require replacement in order to achieve the goals ofthe Site Investigation Note that two ofthe original well clusters in the Work Plan BW-17 and BW-18 have been destroyed and would require replacement even if access is granted by Bates In addition HSI GeoTrans well clusters had already been proposed adjacent to BW-2 BW-7 and BW-11 and will provide the required data at these locations
It is our understanding that the two monitoring wells installed by the State on the Bates property JB-1 and JB-2 are accessible to the State for sampling and water level monitoring and that the State will sample and monitor these wells to fulfill the goals ofthe Site Investigation IF this is not the case please let me know at your earliest convenience
M WP DOCS NT^VWMiSimbW wpd
MITEC 104e 02438
Mr Michael Smith 2 May 11 1999
Several ofthe remaining wells (BF-1 BF-3 NO-2 and OE-1) were observed to be damaged during the inspection We propose to repair the wells which have been damaged The repairs will involve installation of protective casing or road boxes re-development and reshysurveying of the new measuring points The other wells are missing and presumed destroyed (ARC-2 ARC-3 BF-2 BM-2 MB-1 PO-SOUTH and RB-1) We believe that only monitoring wells MB-1 and MB-1 A require replacement The remaining wells that could not be located during the site inspection do not require replacement in order to achieve the goals ofthe Site Investigation
Based on our telephone conference on May 10 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MWgt_DOCSN753l9Wlaquo310l600raquopd M l 1 XA ~r
02439
HSI GEOTRANS
Mr Michael Smith 3 May 11 1999
bcc Sheila Jones
snwp_DocjN7sni9wcmoi6i)iraquoplti TVflTEC 1046
02440
HSI GEOTRANS
X_l ^ T 6 Lancaster Countv Road
Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-11 i 5
PN N753-002
June 25 1999
Mr Michael Smith Agency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Work Plan Modifications Ailing Industrial Park Site Williston VT
Dear Mike
This letter documents changes to the work plan for the Ailing Industrial Park Site in accordance with a telephone conference between you myself and Peter Zeeb On the results of the Site Investigation to date as well as additional data collection by the DEC we agreed that several revisions to the work plan are warranted The revisions for the work plan include the location and method of installation for the bedrock monitoring wells and the sampling of shallow monitoring wells recently installed Outlined below are the revisions to the specific tasks that we will undertake
Re-location of Bedrock Monitoring Weil BR-1
The DECs Source Area investigative work in the original location of BR-1 identified high levels (100 mgL) of VOCs present at or near the silt clay interface DEC believes that drilling through the clay layer in this location creates an unacceptable risk ofthe migration of contaminants into the underlying units HSI GeoTrans will relocate the bedrock well BR-1 adjacent to ASI-16 as located on the attached site plan
Bedrock Well Installation Method
Geophysical work at the site has refined our estimation of the depth to bedrock Depth to bedrock was initially anticipated to be greater than 150 feet below ground surface We currently anticipate bedrock at 100 to 140 feet below ground surface The shallower depth to Bedrock will
M AWPDOCStfnSIMnWUJIIW mft
MITEC 104e 02441
Mr Michael Smith 2 June 25 1999
enable us to reduce the size ofthe pilot hole needed for the well installation At locations BR-1 and BR-2 drillers will advance and set 4 in casing several feet into the clay unit and chop and wash the annulus ofthe casing All cuttings and wash water will be contained for proper disposal The casing will be refilled with potable water and the hole will be advanced with a 3 in roller bit When telescoping becomes necessary to prevent caving 3 in casing will be installed The 3 in casing will be advanced to the bedrock surface and seated The coring of bedrock will follow the original work plan specifications
Shallow Monitoring Well Sampling
The field GC water quality data obtained during small diameter installation at the site has demonstrated that contaminant concentrations in the upper portion ofthe aquifer to be low (lt 10 MgL) or non-detect in most locations This has led to the revision of our sampling plan Select shallow wells will be sampled to confirm the field GC data If these data are confirmed the low level and none detect shallow wells will not be sampled The shallow wells to be used for confirmation sampling are listed below
ASI-01 ASI-02 ASI-03 ASI-05 ASI-08 ASI-10 ASM 2 ASI-08
Based on our telephone conference on June 24 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MXTECl04e 02442
HSI GEOTRANS
Mr Michael Smith 3 June 25 1999
bcc Sheila Jones
MITEC I04e
02443
HSI GEOTRANS
1 0 T 2 shyCylty
T-TCT 6 Lancaster County Road _ _ _ Harvard Massachusetts
GEOTRANS OH 5 1
A TETRA TECH COMPANY 978-772-7557 FAX 978-772-6183
PN 753-010
July 9 1999
Mr Michael Smith Agency of Natural Resources Vermont Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Bedrock Monitoring Well Installation Ailing Industrial Park Site Williston VT
Dear Michael
On July 8 we became aware that a drill casing was advanced through the sand clay and till strata at the Ailing Industrial Park (site) without being sealed at the sandclay interface Although for the reasons described below we do not believe any vertical migration of contaminates occurred this method of drilling is contrary to the work plan for the site Therefore we are notifying you of this incident
On June 4 shallow direct push monitoring wells were installed at location ASI-06 where a deeper bedrock monitoring well is planned Groundwater quality profiling data from this location is provided on the attached boring log TCE is present in groundwater here at concentrations as high as 2270 ugl at 31 - 36 ft below ground surface (bgs) decreasing to 262 ugL at 41 - 44 ft bgs A soil boring (D-2) was advanced at this location on June 22 Field screening data from soil samples obtained in this boring are also provided on the attached log As apparent from the log fine to medium sand occurs to a depth of approximately 15 ft at this location grading to silt at depth A clay layer is encountered at 40 ft bgs Glacial till is present from 57 to 100 ft bgs where the bedrock surface is located Prior to drilling through the clay and glacial till a direct push well screen was advanced through the clay and into the till to a depth of 58 bgs and no groundwater recharge to the well screen occurred at any of five sampling depths
MWP_DOCSN753 199M7M1600 wpd
MITEC 104e 02444
Mr Michael Smith 2 July 9 1999
Drilling of bedrock monitoring well BR-2 began on June 29 Four inch casing was advanced to a depth of 44 ft and sealed within the clay layer Three inch casing was then advanced through the till layer to the bedrock surface During seating ofthe casing in the bedrock the casing was damaged and was subsequently withdrawn from the borehole
On July 7 a different drill rig was used to continue drilling the same location In accordance with both the drillers proposal to HSI GeoTrans and the work plan for the site investigation the driller was to seat a casing in the clay establish a seal and drill through the clay and till with smaller casing prior to coring bedrock Instead the drilling contractor withdrew the previously installed four inch casing without grouting it changed the drive shoe on the casing to a spin shoe and advanced the four inch casing directly to the bedrock surface Upon arrival at the site to log the coring of bedrock on July 8 HSI GeoTrans ascertained that the borehole had not been sealed at the clay surface prior to drilling deeper as was specified HSI GeoTrans then instructed the drilling contractor to immediately remove the casing and to seal the borehole with grout in the process
It is our intention to have a new drilling contractor complete the installation of BR-2 at an adjacent location in a manner that limits the potential for introducing contaminated unconsolidated deposits groundwater to the bedrock as specified in the work plan for this site investigation Within one week of completing the installation of BR-2 groundwater quality data collected from BR-2 will be evaluated with respect to the potential for contaminant migration along the unsealed borehole that existed at this location for approximately 24 hours As the casing was advanced by spinning providing a relatively good seal between the casing wall and the formation we do not anticipate that vertical migration along the casing was significant
If you have any questions regarding this letter please contact me at (978) 772-7557
Sincerely yours
Peter Zeeb PhD Senior Hydrogeologist
PZcas
MWP OOCSVN7S3M999070ll600wpri
MITEC 104e 02445
HSI GEOTRANS
1 HSI | 9pound9TPpoundSpound SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
LOCATION Williston VT CASING TYPEDIAMETER None
DRILUNG METHOD Drive and Wash Direct Push SCREEN TYPESLOT None
SAMPLING METHOD ss shelbv GRAVEL PACK TYPE None
GROUND ELEVATION GROUT TYPEQUANTITY Bentonite Portland Slurry
TOP OF CASING DEPTH TO WATER
LOGGED BY NSB GROUND WATER ELEVATION
REMARKS This log compiles the results o the all methods used to comolete the borehole over its entire depth
gtshyci IT UJ t o UJ E t shygt z L oi lti LITHOLOGIC DESCRIPTION 3Q O bdquo a UJ lt a ca sect 1a UJ
o amp UJ _ a 1 Oi i ai o UJ a E 03 5 1 - X X X
cc -S
Moderate olive Brown - Olive Grey m-f SAND w trace fines wet poorty graded
bull bull bull
- 5 shy
J
bull bull
- 1 0 shyD2-SS01 21 13 NO 7 NO 13
A12 7
bull bull
Light olive Brown SILT w trace fine sand wet poorly - 1 5 shy graded
O2-SS02 4 7 11 8
A7
6 7
- 2 0 shy Dark greenish Grey SILT wet poorly graded
O2-SS03 2 0 41 1
WOR WOR l
D2-SS04 2 4 2 X - 2 5 shy4
D2 13 1159
3
1 D2-SS05 2 5 39 v
WOR AWOR WOR - 3 0 shyD2-SS06 4 921 WOR
XWOR WOR
02-SS07 8 2270 1
X1 2 3
Continued Next Page 1 OF 3 02446
HSI GEOTRANS SOIL BORING LOG BR-02 A T E T R A T E C H C O M P A N Y
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
9 gtshyOC
UJ - j a
UJ gt o ^ r-6 LITHOLOGIC DESCRIPTION
ui
CD U UJ S oc =
o o
uj _ Q pound iT O
o
Medium Grey dayey SILT wet poorly graded
D2-SS09 4 S
28 1572
3 6
D2-SS10 WOR 1 18 13
4 6
D2-SS11 3 3 20 NO Medium Grey CLAY wet poorly graded 262
4 5
BR2-SS01 1 2 20 ND Soft Olive Grey CLAY moist laminated coheisive 2 4
BR2-SS02 20 NO
- 5 0 -
BR2-SS03 20 NO - 5 5 -
Dense Light olive Grey sandy GRAVEL w few fines
BR2-SS04 16 19 24
ND
bull60
moist poorly graded
21
Very dense Light olive Grey gravelly SAND w little fines moist well graded angular
BR2-SS05 40 51
13 ND 6 5 shy
60 66
I-7 0 shySO BR2-SS06 11 ND 50 100
5000
MITEC 104e 02447
Continued Next Page PAGE 2 OF 3
HSI GEOTRANS A T E T R A T E C H C O M P A N Y SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
a UJ
Q
05
i i m u
gt ac ui gtO bdquo UJ 3 oc S
o o
0 CO UJ _ Q pound LL C5
LITH0L0GIC DESCRIPTION 9 LU O
BR2-SS07 81 1004
10 NO E 8 0 shy
BR2-SS08 30 59 68
16 ND w8 5 shy
BR2-SS09 1005 NO 9 0 shy
BR2-SS10 89 1944
ND E bull95shy
- 1 0 0 shyND
Limestone
MITEC 104e 02448
PAGE 3 OF 3
Mr Michael Smith 3 July 9 1999
bcc Sheila Jones bcc Jerry Amman
MWPJXXSN753M9MW70J160Owpd
MITEC 104e 02449
6 Lancaster Countv Road HSI Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6 I i 5
PN N753-014
Septembers 1999
Mr Michael Smith Agency of Natural Resource Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in die Site Investigation Ailing Industrial Park Williston IT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and die Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation ore outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste waler lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot IV-11 using small-diameter wells and afield GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
bull perform one day ofwellpoint permeability testing at selected monitoring wells
mwFDocwsiMwwwnoootd MITEC 104e 02450
Mr Michael Smith September 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
M l T ECl04e 02451
U laquo OOCTN791Mtm01IOOOraquofrl
HSI GEOTRANS
HSI GEOTRANS
6 Lancaster County Road Harvard Massachusetts
01451
A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6183
PNN753-014
Septembers 1999 amp y gt
Mr Michael Smith D oJ Agency of Natural Resource Km Jt Department of Environmental Conservation i j f i l Waste Management Division ft y^y( 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park ft Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and the Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation are outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
bull perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste water lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot 19-11 using small-diameter wells and a field GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
MITEC 104e perform one day ofwellpoint permeability testing at selected monitoring wells 02452
000060 MlWP_OOCSN73Iirmraquo01|rngtlaquo|gtl
Mr Michael Smith Septembers 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
MITEC 104e 02453
000061 Mwr_cocS4miinmogtmoltsri
HSI GEOTRANS
T T Q T 6 Lancaster County Road ^ Harvard Massachusetts
GEOTRANS laquolaquo A TETRA TECH-COMPANY 978-772-7557 FAX 978-772-6183
PNN753-014
October 151999
Mr Michael Smith vZ Agency of Natural Resource J Department of Environmental Conservation Waste Management Division I 103 South Main StreetWest Building j Waterbury VT 05671-0404
Re Ailing Industrial Park Source Area Investigation
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants Evaluation of field data has determined the extent ofthe dissolved phase contamination migrating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) HSI GeoTrans will begin a Source Area Investigation on October 181999 to determine the nature and areal extent ofthe suspected contaminant source The investigation will be undertaken to gather the data necessary to complete the Site Investigation Report and the Feasibility Study which was set forth by the Agreement Between Mitec Telecom INC and Vermont Concerning the Ailing Industrial Park (1999) The Source Investigation will focus on the property owned by Beatrice Ailing and former MITEC lease hold (Lot 19-11 Williston plat map) and the area ofthe Ailing Industrial Park which has exhibited elevated contaminant concentrations during Site Investigation activities We are submitting this letter to The Vermont Department of Conservation(VTDEC) as an addendum to the approved Site Investigation Work Plan The addendum Source Investigation Work Plan will outline the tasks and methodologies to be utilized during the investigative work
Jack Guswa and I met with you on September 101999 to present the plans to investigate the suspected source area in the Ailing Industrial Park You agreed with the additional work as presented with the addition of two upgradient wells to be located to the west ofthe suspected source area (Figurel-1 ASI-30 and ASI-31) The VTDEC also agreed during the meeting to arrange access to the property for the Source Area Investigation The VTDEC and HSI GeoTrans were subsequently granted access to the property on September 111999 In addition to the work presented at the meeting it is necessary to preform a 72 hour pump test to characterize the
000054 MwrDOCSW79JimMOUIIOOpd
MITEC 104e 02454
Mr Michael Smith 2 October 151999
hydrologic conditions at the site The additional Source Area Investigation activities to be undertaken are presented below
Site Reconnaissance Ground Penetrating Radar (GPR) Survey Monitoring Well and Soil Boring Installation Low Flow Groundwater Sampling Hydraulic Characterization
The additional field work attributed to the Source Area Investigation will follow the standard operating procedures presented in the approved Site Investigation Work Plan (HSI GeoTrans 1999) The locations ofthe proposed well cluster installations and GPR survey are presented on Figure 1-1 The well cluster locations presented in Figure 1-1 were finalized during the September meeting between HSI GeoTrans and the VTDEC The GPR survey and hydraulic characterization tasks are presented below The Source Area Investigation field work will be completed within two week after its initiation The task specific outlines are presented below
Site Reconnaissance
The monitoring wells to be included in the site reconnaissance are monitoring wells MI-1 MI-2 MI-6 and RB-2 The monitoring wells on Lot 19-11 will be surveyed to a common datum with the existing site wide survey data Well integrity testing consisting of depth to bottom water level and visual inspection ofthe wells will be preformed Groundwater samples will be collected from selected monitoring wells based on the integrity testing Samples will be collected by the Low Flow Protocol set forth in the Site Investigation Work Plan (HSI GeoTrans 1999)
GPR Survey
A GPR survey will be preformed to identify on-site leach field septic tank or cesspool location remnants of waste water lagoon and any other subsurface anomalies We propose to use a 5 foot by 5 foot orthogonal grid survey to detect any near surface anomalies which exist on Lot 19-11 Geophysics GPR International will be performing the survey and will be utilizing a GSSI SR10 ground penetrating radar system with a high resolution 500 MHz antenna and a deep-penetration 100 MHZ antenna Any GPR response which indicate buried metal objects will be investigated with a Fisher TW6 pipe locator to augment the radar data All data will be analyzed in the field by GPR personnel and presented to HSI GeoTrans field personnel to determine the optimal location for well cluster ASI-28 If several anomalies are detected the VTDEC and HSI GeoTrans will evaluate the anomalies and modify the work plan accordingly
Well Installation and Soil Boring Advancement MITEC 104e 02455
The well clustes will consist of a small diameter shallow monitoring well and a deeper conventional well screened across the zone of highest concentration Well cluster installation will be performed in accordance with the Site Investigation Work Plan (HSI GeoTrans 1999) yjth 0 0 5 5
MWP_DOCSK731IW9M OOSIIOOprl
HSI GEOTRANS
Mr Michael Smith 3 October 151999
the exception ofthe deep wells The site conditions observed during previous field work prohibit the use of standard commercially available screen slot sizes The deep wells will be advanced by a large diameter Geoprobereg rod and installed using an outer filter sock to prohibit the infiltration offine sediments in to the well The well cluster installations will be performed jointly by Checkpoint Environmental and Twin State Environmental HSI GeoTrans will be provide oversite ofthe contractors and analysis of groundwater samples using afield Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999) The rationale for the selected well cluster locations is presented below
Monitoring well clusters ASI-25 through ASI-27 are located down gradient ofthe suspected source area The well clusters will be installed to more adequately define the areal extent ofthe concentrated portion ofthe contaminant plume A single soil boring will be advanced at location ASI-26 The soil boring will be screened as it is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-28 will be located after the GPR survey has been completed shyThe cluster will help define the suspected source area and the vertical migration of contaminants in the area The location will be determined in thefield after review ofthe GPR survey is completed The location will be based on any anomalies observed in the GPR data A single soil boring will be advanced at location ASI-28 The soil will be screened with a Flame Ionization Detector as the soil boring is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-29 will be located upgradient ofthe suspected source area The cluster will define the upgradient boundary andor any additional upgradient source areas The ASI-29 well will be paired with the existing shallow monitoring well AL-14
Monitoring well clusters ASI-30 and ASI-31 will be installed to the west cross gradient from the suspected source area to document the areal distribution of dissolved phase contamination emanatingfrom the Ailing Industrial Park The locations selected for these wells should define the northwestern and western extent of contamination
Low Flow Sampling
The additional monitoring well clusters will be sampled in accordance with the approved Site Investigation Work Plan (HSI GeoTrans 1999) Lowflow sampling procedures will be used to sample the newly installed deep wells in their respective clusters ASI-25 through ASI-31
MITEC 104e 02456
000056 MWP_DOCSgtK15JlWMOWllltraquoraquoprl
HSI GEOTRANS
Mr Michael Smith 4 October 151999
Hydraulic Characterization
HSI GeoTrans will conduct a 72 hour pumping test on the deep well at cluster ASM 2 The test is being undertaken to more adequately characterize hydraulic conditions at the site The data from this test will be used in the evaluation of remedial alternatives in the Feasibility Study The pump test will be performed as a step-drawdown test The pumping rates will ultimately be determined in the field from observed conditions Preliminary calculations indicate that pumping rates of 2 5 and 10 gallons per minute will be necessary to achieve the desired drawdown at observation wells The water level data will be recorded at observation wells ASI-06 ASI-13 ASI-25 ASI-26 NO-1 NO-2 and NO-3 The water level data will be recorded using pressure transducers and dataloggers
The effluent water from the pumping test will be treated by liquid phase granular activated carbon filters provided by Carbtrol Inc Two 175 pound carbon filters will be connected in series to treat the pump test effluent The effluent will be discharged to the unnamed brook upon approval from Randy Bean ofthe VTDEC The effluent will be periodically sampled between the carbon units and at the discharge point to detect break through ofthe carbon units The effluent samples will be analyzed utilizing a field Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999)) If the effluent sample between the carbon canisters exceeds 1000 ugL Trichloroethene (TCE) the discharge point sample will be analyzed If concentration of TCE in the discharge point sample exceed 300 ugl the test will be discontinued
We hope that this letter addendum to the Site Investigation Work Plan for the Source Investigation is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJmm MITEC I04e
02457
000057 MWFDOCSN731imu00SI 100 bullpd
HSI GEOTRANS
JHSTUART March 1 1985
Agency of Environmental Conservation D e partment of Water Resources und
E nvironmental Engineering H a z a r d o u s Materials Management Program A t t n John A m i d o n H y d r o g e o l o g i s t M o n t p e l i e r Vermont 05602
R e M I T E C Systems Corp W i l liston
Dear J o h n
During our meeting at MITEC on February 20th you noted that some additional information was needed to c omplete the initial phase of testing as well as the d o c umentation of the activities under takentodate Outline d~ beTow-Ts ~t h e~1 n f o r m a ti o n t h a t y o u r e q u e s t shyed
1 Attac hed here to is the plan used to install the grou ndwat er moni t o r s collection and analysis of the grou ndwa t er samp les for metals and organics and the extr actio n of and testing of soils from the area of the dispo sal site 2 A rev ised sit e pla n has been incl uded refl ecting the new well posi tions and the e leva t ions of t he top of t he mo ni to r s and th e groundwa ter 1e vels as of F e shybr ua ry 0th As note d in our m ost r ecent tel ephone conv i on th e lat ter have r isen 14-15 inc hes as er sa t the It o f th e rec ent thaw Two copie s of the resu plan be f orw ar ded to Winslo w Lad ue as req uested will and pla ns t 0 sur vey all ho uses on Br owne 11 Rd MITEC _tp tain if there are ajiy shallo w wel I sources ltis ce r with e dr aina ge ar ea a f fecte d by the 1agoo n in th 3 ngla nd Ma r ine C o m r a c t o r has been con tacted New E for remo va 1 of th e lagoon soil a nd co ntra c tural the ar ra nts wil 1 be concluded du r ing t he comi ng ngeme week if ic at io n of work comme nceme nt wi II be proshy Not vide your off ice i n advance d to t m Resul t s of th e met als and or genies are expected shor tiy
f rom IEA and will be fo rwarded to your ofshyf ice oon as a va i la ble as s 5 R esul t
s fr om t he pr e vious soi 1 and water sampling have inc 1 ude d bee n
CIVIL 4 EfViROUMEI-L pound l j i t fcHpound P ) OGA lt i f r l h r l h w i l l n-- i i U - iO l i l ) bU i l I
MITEC 104e 02458
s
MITEC Page 2 March 1 1985
If you have any questions please do not hesitate to contact me
Stuart PE
JHSocc
MITEC 104e 02459
MITEC Systems Corporation Williston Vermont
Soil and Water Sampling Program
1 Install groundwater monitors at nine (9) locashytions consisting of two (2) inch inside diameter PJpound with ten (10) feet of factory slotted pipe extending into the groundwater and terminating with a minimum of two (2) feet above ground level and capped
2 Establish elevations of the groundwater monitors for the top of each pipe and the groundwater elevashytion for each for a specific date Due to the shalshylow depth to groundwater from 51-112 inches the level is established by graduated tape and a light Each measurement will be performed a minimum of three times to assure accuracy to within one-eighth inch The location of each well and the established elevations will be represented on a general site plan showing the MITEC property
3 Groundwater samples are to be collected from each well on the same date by pump or baling Prior to - k ~ -~-|1bdquo--bdquobdquo f bdquo k bdquobdquobdquobdquobullbdquo ltv~ 11 1 1 v bdquo bdquo bdquo
acidification for metals preservation to assure ac curacy of the test results All samples are to be analyzed for copper cadmium nickel cyanide pH conductivity total chromium and hexavalent chrome
U Soil samples are to be collected as follows
GWM09 Saturated zone (aaprox 5) Overburden East side lagoon Composite from
two holes 5 apart-at-1 bullbull2 bullbull A below the-sur=mdash face and one in the saturated zone
North wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface 1 into the saturated zone
South wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface I1 into the saturated zone
Bottom of lagoon Composite offour test holes 8 apart one in the unsaturated zone
MITEC 104e 02460
MITEC Sampling Program
All samples are to be analyzed for the same constituents as required of the water testing
5 Collect separate samples of the groundwater after the above referenced purging process for storage in air-tight vials The samples which are to be colshylected from wells A-9 with only 5 and 7 analyzed initially by the GCMS- EPA method 62A If organics are detected in the first samples testing must be performed on 4 and 8 as well
6 All sampling will be performed with a State repshyresentative on-site and results of the testing to be forwarded to the State as soon as available
7 The contaminated soil within the lagoon will be removed by a Vermont certified contractor for disposhysal in an approved wastedepository The top one (1) foot of soil from the flood level and below will be extracted during the process
MITEC 104e 02461
i
o H
ON f J
o
bull I I bull
HA
OOO
x x z
bull
MITEC 104e 02463
WK miui w ci ivnui II i ici ILUI ujiyitb inc iii PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5108
ANALYSIS REPORT
Customer j H S c u a r t Associates Date 26 February 1985
Address P gt 0 gt B o x 3 6 7 Date Samples Received
Ci ty S t a t e Zip Essex Center VT 05A15 20 February^1985
Customer Order Nomber
Attent ion J o h n S t u a r t
Station 9
J
2
3
A
5
6
7
8
9
poundH
5A
58
52
5A
A5
53
53
55
59
j MITEC
Conductivity U mbos ( 25degC)
206
A18
21A
176__
208
230
205
16A
265
GROUNDWATER ANALYSIS
O01 0 OS bull
Cadmium Total Chromium (mRl) (mRl)
0A1 lt0025
006- 270
00A 012
bull005 189
005 023
001 lt0025
lt0C Hexavalent Chromium (mKI)
bull
lt0025
239
005
183
lt0025
lt0025
ampo
Zinc (mKl)
005
0A0
032
015
OU
003
Note Organic analyses to follow in two weeks
cc John Amadon
Signature jJfcrryyS 7lrifrylC
Offices ond loborotones located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02464
if jsznoi U hnvironmentol jiolysts Inc PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5138
ANALYSIS REPORT
Customer J H Stuart Associates Date 21 December 1984
Address PO Box 367 Date Samples Received 14 December 1984
City State Zip Essex Center VT 05451 Customer Order Number
Attention John Stuart
WATER ANALYSIS
PH 52 57 50 53 45 34
Conductivity (pmhos 25degC) 213 420 152 167 202 bull 225
O l Cadmium (mgl) lt001 lt001 001 v 028 bull 005 003
o pound Chromium Total (ng1) lt0025 lt0025 lt0025 lt0025 2-35 v 014 - -bullbull - bull - -bull V 013 bull^Chromium Hexavalent (mgl)1 0 11
gt1p Copper (mgl) lt002 lt002 lt002 lt002 bull 084 004
Q Cyanide (mgl) lt0005 lt0005 lt0005 lt0005 bull -lt0005 lt000E
Z Nickel (mgl) lt0025 lt0025 lt0025 lt0025 bull 010 003
fO 2inc (mgl) 0J1 UU1 0U3 001 038 030
Hexavalent chromium was only analyzed when total chromium was present
Signature fmnigt Mji fnt f VncL 7
Offices and laboratories located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02465
bull i
ANALYSIS REPORT
Customer J H Stuart Associates Date 22 January 1985
Address PO Box 367 Date Samples Received 14 December 1984
Ci ty State Zip Essex Center VT 05415 Customer Order Number
Attent ion John Stuart
bull shy
bull bull mdash bull bull bull bull bull - bull bull bull bull shy SOIL ANALYSIS1
Hexavalent Cyanide Chromium Chromium Cadmium Copper Nickel Zinc
poundH bull (mgl) (mgl) (mq1) bull (mq1) (mq1) (mgl) (bullmgl) -
2 442 lt0005 lt0025 lt0025 lt 001 lt 002 015 006
4 402 lt0005 lt0025 lt0025 lt 001 lt 002 lt002 001
7 504 lt0005 lt0025 lt0025 lt001 lt002 lt002 001
8 486 lt0005 lt0025 lt0025 lt001 lt002 lt002 bull 008
9 441 lt0005 lt0025 lt0025 lt001 lt602 lt002 004
10 444 0005 lt0025 lt0025 lt001 lt002 lt002 006
11 498 lt0005 lt0025 lt0025 lt001 003 lt002 009
30 532 lt0005 lt0025 008 lt001 005 lt002 010
31 544 lt0005 lt0025 lt0025 lt001 002 056 003
32 472 lt0005 lt0025 lt0025 lt001 lt002 024 003
36 536 0008 lt0025 011 lt001 005 lt002 011
37 490 lt0005 lt0025 lt0025 lt001 021 lt002 009
38 391 lt0005 0276 032 lt001 050 lt002 011
41 416 lt0005 0108 018 001 229 lt002 o5i
42 395 lt0005 0399 041 lt001 039 lt002 014
i
Signature Ltrf(7( ni W0 6M Analysis of EP toxicity extract
Offices ond loborotoriei locoted in Essex Junction Vermont Reseorch Triongle Pork North Corolino
MITEC 104e 02466
JHSTUART
A p r i l 2 9 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Hazardous Waste Materials Program Attn Cedric Sanborn Environmental Engineer Montpelier Vermont 05602
Re Mitec Systems Williston
Dear Cedric
I was phoned by David Gee today and informed that a truckload of the contaminated material was removed from the lagoon area as the result of a previous commitment entered into by Mitec Due to conflicting information about Mitecs responsibilities at this juncture I am recommending that any further work cease until a realistic program be agreed to by both parties I base that on the following
1 Following the trial pre-hearing the State was inshystructed to contact Mitec to develop a schedule for further dialogue and actions connected with the reshyhabilitation of the lagoon site To my knowledge there has not been any such attempt made on the part of the State to resolve issues that need clarificashytion
2 On April 18th I forwarded a letter to you outlinshying some new information with recommendations That correspondence has not been addressed yet Mitec has been ordered to continue with the soil removal
3 A letter from John Amadon on April 23rd notes the organic sampling to be invalid due to the time lapse and the method of storing the samples We do not take issue with this position however there is apshyparently some question about the validity of the GCMS method of analysis We have been instructed to re-sample but now there is a question about whether we should employ GC or GCMS
A On numerous occasions we have expressed the deshysire to tailor the soil removal process to a minimum
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 3C7 ESSEX CTR VERMONT 05451 TELEPHONE 802 876 bull 5171
MITEC 104e 02467
L
Mitec Page 2 April 29 1985
2- bull number of truckloads as they are projected to cost about $4000 for each load Mitec being in a startshyup phase of their operation cannot approach this operation with a blank check Chris Stone who was on hand today to represent the State indicated that many more loads may be necessary to effectively rid the site of contamination
Too many questions surround this project for my clishyent to understand his responsibilities and ultimate costs The requirements issued by your office either in writing or verbally on-site have changed repeatshyedly and unless we can mutually agree to a reasonshyable program that is connrifpH rnmdashyr r i ng Mitec has no other option but to let the court decide the isshysue
Again keep in mind there are questions that we feel must be resolved in order to reach a satisfactory conclusion
1 Provided that all Browneil Road houses are connected to the CWD system and thereby reshymoved from any threat of groundwater conshy
- p tamination what level of soil contamination is permissible From this limitation provishyded we concur as to its reasonableness an approximation can be developed as to how many loads of soil must be removed
2 If the soil is to be removed why is it neshyy cessary to conduct organics sampling unless
i t~ i s tne ulterior motive ot the State to direct renovation of the groundwater as well If that is the case the process will now be more expensive than at the outset due to the mobilization of the contaminants
3 If the contaminated soil is to be removed whv is additional groundwater monitoring
pound bull necessary Documentation of the degree of dilution is not considered acceptable
A If organic testing is to be performed y_hich -- method of analysis is to be used
As soon as we can receive a response to the quest-
MITEC 104e 02468
I um laquoi i laquo m mdash n r r j mdash i mdash
Mitec Page 3 April 29 1985
ions at hand then further discussion with the State will dnsue Also please be advised that at the dishyrection of Mitec all future correspondence communishycations requests for information or notification of site vists are to be forwarded to my office We also request that one person in your office be designated to process such information
tuart PE
JHSocc cc Mitec
Robert Cronin Esq
MITEC 104e 02469
jmfMraquoi w i f u m i
A u u raquo laquo F pound raquo laquobull= -
B C f U S t B C INC ENVIRONv i bullbullbull bullbull
5 GREEN MOUNTAIN DRIVE SOUTH BURLINGTON VERMONT 05401 TELEPHONE (802) 658-1074
February 17 1984
I I Mr Cedric Sanborn i
of Environmental Conservationi AgencAgencyy ox ampnvifoiuneniai Lonservdciun I i Dept of Water Resources and
Environmental Engineering Montpelier VT 05602
Dear Mr Sanborn j i
RE Mitec Clean-Up 84011 j
I am writing this letter to inform you of the work that has been completed thus far at Mitec Systems Corp The discharge of i rinsewater into the lagoon has stopped and the rinsewater is being batched and treated at Aquatec as I described in my letter to Stan Corneille dated February 3 1984
Although the chemical reduction and precipatation process works bull bull
very well we have found that the cost for design installation j septic design and installation and permit reviews is far above | Mitecs budget Aquatec has looked at a second alternative for bull the treatment and reduction of rinsewater that being ion exchange J The ion exchange system will be purchased from a vendor and will bull be installed by Aquatec to accomodate Mitecs rinsewater volumes i The rinsewater will be recirculated and will not require any discharge hence there will be no need for subsurface disposal [ permits I will send you specifications on the system and resins j that will be used I
The proposal for the out-door clean up work is enclosed Mr Kucer is currently discussing the cost estimate with his Montreal office I see no reason to intiate this work as soon as I get formal approval from your office and from Mitec
Please feel free to call me if you should have any questions
Sincerely
liytrl Zi [U$) John R Deigo Project Engineer
Enclosure cc Mr Steven Kucer
Hydrographic Studies and Analyses bull Water Quality Studies raquo Analytical Laboratories Ecological Studies bull Aquatic Nuisance Control - Industrial Waste Surveys
MITEC 104e 02472
Recommended Treatment of Rinsewater
Mitec System Corporation
Prepared By
Aquatec Inc
South Burlington Vermont
January 23 1984
MITEC 104e 02473
RE Mitec Groundwater Cleanup - 84011
The treatment of rinsewater will consist of a three stage rinse system with a batch chemical reduction treatment process Parts submersed in chromic acid solutions will be rinsed in a primary rinse bath The primary rinse bath will be a closed system and considered a rough rinse
The secondary rinse bath will also be a closed rinse system The third and final rinse will be a continuous overflow system Effluent from the tertiary system will flow directly into the septic system Tertiary effluent limits must be less than 005 mgl (ppm) before entering an underground septic system
The primary rinse bath will eventually become saturated with chromic acid solutions and require periodic batch treatment When the primary rinse water becomes spent it will be transferred into a 250 gal polyethylene plating tank The rinse water from the secondary rinse bath will be transferred into the primary rinse bath and the secondary bath will be refilled with fresh rinse water
When the tank reaches 80 of its capacity treatment will be initiated The treatment will consist of reducing hexavalent chromium to trivalent chromium by the addition of anhydrous sodium sulfite to a pH of lt2 The amount of sodium sulfite added will depend on the concentration and volume of rinsewater to be treated A portable electric mixer will be attached to the tank to ensure proper mixing The rinsewater in the reduced form will be gravity fed into a second 250 gallon polypropylene plating tank where lime will be added precipatlng out trivalent chromium as well as other heavy metals The mixer should be used to agitate the solution when the lime is added The mixer should be removed and the solids allowed to settle Once the solids have completely settled the treated water will be pumped into the tertiary effluent to allow for further dilution before it is discharged into a septic system
Periodic sampling of effluent waters should be incorporated to ensure that rinsewater discharged does not exceed 005 mgl (ppm)
Sludge will be properly stored and eventually disposed of by a certified hazardous waste carrier
MITEC 104e 02474
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Wildlife and Department of Forests Parks and Recreation Environmental Engineering Department of Water Resources amp Environmental Engineering Natural Resources Conservation Council State Geologist
January 4 1984
3 2ampov~ loo Mr J H Stuart
f i 2 Sm ^
P O Box 3 67 - - l ^ J ^ S M J Essec Center Vt 05451
SUBJECT Mitec Z 0~npJ^
1 o
Dear J o h n
I appreciate your sending me a copy of the recent Mitec water quality results It appears that there remains a detrimenshytal affect of the lagoon on the downgradient groundwater quality This is best demonstrated with the pH and chrome data While it appears that the downgradient well 5 has higher metalic concenshytration then well 6 in the middle of the lagoon I believe the Well 5 results are anamously high due to the turbidity or solids that we saw in the sample In talking with Cathy Cutting of IEA sample 5 was not filtered prior to acid digestion for the AAS analysis ^^
I would suggest that well s 4 5 and 6be resampled and analyzed along with the wells installed on CecT 17 amp 18 We would like to have a representative of our office on site when the sampling is performed so please contact me when a purging and sampling date is set in the near future The groundwater sample from test well 6 that you helped me obtain on December 17 with the teflon bailer was confirmed by our laboratory to contain volatile organics Therefore you must include the volatile orshyganics assay done by JGCMSjas a part of your analysis plan Adshyditionally I would suggest that you review the appropriate protocol for groundwater sampling and obtain the necessary equipshyment A sampling and analysis plan must be submitted for our apshyproval prior to commencing this second round of sampling The plan should be submitted by January 18 1985 with the sampling done within one month of our approval Please feel free to conshytact me with any comments or questions you may have
R f n r mdash i 1 Off ices - BarreEssex J c t P i t t s f o r d N Spr ing f ie ld S t Johnsbury
MITEC 104e 02844
J H Stuart Page 2
I do look forward to reviewing the results of the soils asshysays along with your report outlining the sampling protocol sampling locations data interpretations and projected course of action based on the results
Very truly yours
John F Amadon Hydrogeologist Hazardous Materials Management Program
JFAkp
cc Meredith Wright AG
MITEC 104e 02845
b v
HSTUART ASSOCIATES September 10 1984
Agency of Environmental Conservation Department of Water Resources and Environmental Engineering Air and Solid Waste Programs Attn Cedric Sanborn Air Pollution Control Engineer Montpelier Vermont 05602
Re M I T E C Corporation Williston Vermont
Dear Cedric
As Che result of our conversation on September 7th I am forwarding the information Chat we discussed
The CesCing program format was prepared prior Co our disshycussion and will be altered slightly based on some inforshymation that was collected
A boring was established in the cencer of Che disposal pic and Che wacer Cable as well as che Impeding layer were found to be located at 29 Inches below the surface The shallow depth will allow us co place addicional wells in che area co accuracely depicc Che groundwacer copography
The plan submiCCed herewith provides general information abouc che locaclon of che plane propercy lines and sugshygested positions for Che monitors The final location of che laccer will be decermined in che field once we collect more data on water table elevations
As we are most anxious to proceed with the program your expeditious review and responsewill be most appreciated
SCuart PE
JHSadt
cc David Gee MITEC
CIVIL ENVIRONMENTAL ENGINEERS 120 LAKE STREET BURLINGTON VERMONT 0S401 TELEPHONE 802-8640094
MITEC 104e 02846
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Game and Department of Forests Parks and Recreation
Department of Water Resources amp Environmental Engineering Environmental Engineering Natural Resources Conservation Council
September 19 1984
Mr John H Stuart PE JH Stuart Associates 120 Lake Street Burlington Vermont 05401
RE MITEC Project
Dear Mr Stuart
Chris Stone and I have reviewed the proposed soil sampling and groundwater monitoring plan for Mitec A summary of comments follows
1) The site plan did not show the location of the soil sampling sites Also we felt that additional boringmonitoring sites should be made closer to the facility The map has been re-marked to reflect these additional sites
2) It was not clear as to why the monitoring wells are to be installed 5 feet into the impeding layer However at least one boring should be made into the impeding layer to detershymine its thickness
3) Permeability tests should be performed on at least four of the test holes to determine aquifer characteristics
4) Since the water table is apparently close to the surface we feel that factory slotted pipe would be appropriate for the final monitoring wells
5) All soil1 ft 5 ft
samples 10 ft or
shouldto imp
be eding
takenlayer
at whic
depthshever
of comes
first
MITEC 104e 02847
Mr JH Stuart -2- September 19 1984
6) In addition to the soil sample in the center of the former lagoon four other locations within 2 feet of the edge of the lagoon must be sampled These locations are marked on the enclosed map
7) The State regulations do not address a level below which the metals are no longer hazardous as is done by EPA Toxicity Levels The level of contamination that is acceptable to the State is determined on a case by case basis
8) The analysis for chromium should include both hexavalent and total chromium
If you have any questions regarding our comments do not hesitate to contact us at 828-3395shy
Sincere
Sanborn C h r i s t o p h e r T Stone Environmental Engineer Hydrogeo log i s t Hazardous M a t e r i a l s Hazardous M a t e r i a l s Management Program Management Program
c r s - c t s a d e n c l o s u r e
MITEC 104e 02848
JHSTUART November 9 1984
Agency of Environmencal Conservation Deparcmenc of Wacer Resources and
Environmencal Engineering Hazardous MaCerials Management Program Attn Cedric Sanborn Environmental Engineer Mnotpelier Vermont 05602
Re M I T E C Corporation Williston Vermonc
Dear Cedric
There has been an apparent misunderstanding regarding your letter of September 19 1984 as soil and wacer sampling has been commenced ac che above location A call was placed Co your office on October 30th or 31sc and a message lefc for you indicating that we would begin on November 6ch at 8 AM
In the afternoon of November 6th I telephoned Chris Scone co inform him of our progress On che following morning you notishyfied MITEC that approval to begin had not been granced and chac work musC cease AC chac point we had completed che installashytion of five monitors and had extracted Cwo soil samples from the botcom of che wasce pic
On November 8ch I met with you and Chris to oucline che reshysulCs from our effores I was informed Chat we may have to inshystall one or Cwo additional monitors and Chac all future work muse be performed wich an Agency represenCacive in accendance
LaCe that afternoon Gerry Adams phoned Co notify me chat on short notice he was leaving to begin a large contract in rUasashychusetts and that it was unlikely that he would be back in the area for an extended period Had we been permitted to continue ttith our work on the 7th his portion of the project vould have been concluded
Enclosed you will find an updated version of the site plan orishyginally submitced wich my leCCer of Sepcember lOch A new plan will be developed buc Chis drawing will serve the purpose of locating existing and proposed wells
Whereas I am now withouc a drilling concracCor I would like chu
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05461 TELEPHONE 802 878 5171
MITEC 104e 02849
M I T E C Page 2 November 9 1984
authorization to determine groundwater elevations by auger and then establish one more monitor in a location agreed to by all che parcles I feel chac we have developed sufficient information co date to proceed in this manner
Furcher since Adams will noc be available I would also like Co extract che remaining soil samples wich a bucket auger IC can demonstrated chac che sample collected in chls manner will provide a good represencacion of che soil ac che level desired in Che profile
We are prepared co conclude chls phase of che sice evaluacion Samples from Che groundwacer monitors can be secured in a few days and I would like co follow wich che soil samples using che method described above
Please contact me at 878-5171 if you need additional informashytion
H Stuart PE
JHSadt
cc David Gee MITEC
MITEC 104e 02850
JHSTUART December 19 1984
M I T E C Corporation AtCn David Gee Manager IS Commerce Way Wllliscon Vermonc 05495
Dear David
Under Che Cerms of our agreemenc daced 10584 I wish Co proshyvide you wish an up-daCe of the project status
At the completion of 1219 we will have completed Items 1-4 as specified in the agreement specifically the soils sampling and initial set of water samples will have been collected and submitted for analysis As of chls momenC we still do not know the extent of the problem but will have a better indication once the test results are available in about a week My feelshying Is chac the problem is noc severe
We have compleCed all wells as prescribed however Che State is opting for an additional well Although the contract provides for only six the costs to date are below my target and it does not appear Chac any exCra will be necessary provided ChaC che driller concludes his work coday
The only work remaining afCer chls dace will be che collecCion of che second baCch of waCer samples and discussions wich Che State about any remedial action if necessary
Feel free to contacC me if you have any quescions
Regards
John H Stuart PE
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 878 bull 5171
MITEC 104e 02851
JHSTUART
M I T E C Corporation December 20 1984 ACCn David Gee Manager 15 Commerce Way Willaton VT 05495
Dear David
During our investigations yesterday Che work was completed on the additional monitor well as invoiced as well as drilling to the impeding layer The State decided however that two addishytional wells are required both of which will be Installed toshyday west of the Industrial park boundary line
A major change developed In Che method of testing the soils in the vicinity of the disposal pit that is not covered by our contract Instead of the four peripheral borings and one in Che center of che pic which would have produced flfceen soil samshyples che StaCe representatives decided Co require a different CesC paCCern Chac produced thirty seven samples I have collectshyed all of the samples but have Instructed the Cest lab to hold until authorization Is received Co proceed on Chls change as it Is a subsCanClal cost and will cause Che contract limit to be exceeded
Included is an invoice reflecting the additional wells the cost Co sample the groundwater for those monitors and the additional funds needed to run the soil tests I do not believe that any further surprises are in order
Regards
John H Stuart PE
JHSadt
CIVIL ft ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 06451 TELEPHONE 802 878 5171
MITEC 104e 02852
JHSTUART
December 28 1984
M I T E C Corporation Attn David Gee Manager 15 Commerce Way Williston VT 05495
Dear David
Enclosed are the results from the water quality analyses of the samples submitted to our lab I have noted in the left hand column the allowable limits for each element A copy of this information has been forwarded to John Ami-don per his request
There are several readings that are suspicious according to John The cadmium level in 4 may be an error and Che chromium found in 5 mosc likely Includes che CurbldlCy measured only in ChaC well Both should be resampled to confirm The cadmium and chromium levels in 06 exceed che allowable llmlCs but not excessively so The soil tesCs which have begun will reveal more about the ultimate disshyposition of these elemenCs
On the sewer Issue I spoke wich Frank Ailing again and his plans are Co now develop Che design and receive approval chis wincer for consCrucCion of the required Improvements this spring
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 5171
MITEC 104e 02853
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MITEC 104e 02855
JHSTUART January 28 1985
M I T E C Corporation Attn David Gee Manager 15 Commerce Drive WillistonVermont 05495
Dear David
On January 25th I met with John Amadon and Cedric Sanborn to discuss the contents of my 12385 letshyter The following resulted subject to confirmation by more senior members of the AEC staff
1 The water samples to be collected from wells 45 and 6 are to be checked for cadmium both chromiums and conductivity Wells 1 2 and 3 will be tested for conductivity and pH only
2 Samples will be collected from wells 4-9 for orshyganics but only wells 56 and 9 are to be checked at this time to determine the scope of contaminatshyion
3 The material to be removed from the pit is conshysidered as a hazardous waste and there are not any disposal sites located within Vermont certified to receive it I did obtain a listing of contractors that are approved for handling the material and I will provide this during our next meeting
4 Attached is a copy of the State lab results that address the organics problem
5 Based on the above we will have to amend our ashygreement to include the $1150 additional costs for the testing connected with Items 1 and 2
Call me if you have any questions
John H Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 raquo 878 bull 5171
MITEC 104e 02856
JHSTUART January 30 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Attn John Amadon Hydrogeologist Montpelier Vermont 05602
Re M I T E C
Dear John
I have had several discussions with MITEC relative to our meeting of last Friday In essence they have agreed to the program that you defined but with several provisos
They would like a letter from your office detailing the additional measures to be implemented together wich specific instructions as to what steps must be taken in the process of removing the contaminated soil
Further their acceptance to collect and sample for volatile organics is limited Perchloroethylene as I had indicated is not and has not been used by MITEC The materials stored on the premises as well as the list of suppliers for paints and solvents are available for inspection co corroborate that position MITEC will provide a complete analysis of all organics for the specified wells however fushyture testing for TCE will not be at the expense of MITEC unless its presence can be attributed to their operation
We are prepared to proceed as soon as we receive the requested notification
Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 bull 5171
MITEC 104e 02857
CORRECTIVE ACTION FEASIBILITY INVESTIGATION EPA SITE NUMBER VTD-098353545 (LOT 19-11)
J - J C T October 5 2000
GEOTRANS A TETRA TECH COMPANY
6 Lancaster County Road Suite Four Harvard Massachusetts 01451 MITEC 104e
02352
CORRECTIVE ACTION FEASIBILITY INVESTIGATION
EPA SITE NUMBER VTD-098353545 (LOT 19-11)
PREPARED FOR
ALLING INDUSTRIAL PARK
PREPARED BY
HSI GEOTRANS INC
6 LANCASTER COUNTY ROAD
HARVARD MASSACHUSETTS 01451
HSI GEOTRANS PROJECT NO N753-016 OCTOBER 52000
HSI GeoTrans inc
MITEC 104e 02353
TABLE OF CONTENTS
PAGE
1 INTRODUCTION 1-1
2 STUDY AREA CONCEPTUAL MODEL 2-1 21 STUDY AREA LOCATION AND DESCRIPTION 2-1
22 STUDY AREA LAND USE 2-1
23 HYDROGEOLOGIC SETTING 2-1
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION 2-3
3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES 3-1 31 IDENTIFICATION OF ARAR S 3-1
32 REMEDIAL ACTION OBJECTIVES 3-1
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES 3-1
322 GROUNDWATER 3-1
323 SURFACE WATER 3-2
324 INDOOR AIR 3-3
33 INITIAL SCREENING 3-3
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES 3-4
4 DETAILED ANALYSIS OF ALTERNATIVES 4-1 41 ALTERNATIVE 1 NO ACTION 4-1
411 SHORT-TERM EFFECTIVENESS 4-1
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-2
413 LONG-TERM EFFECTIVENESS 4-2
414 COMPLIANCE WITH ARARS 4-3
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 4-4
416 IMPLEMENTABILITY 4-4
417 COSTS 4-5
42 ALTERNATIVE 2 MONITORING INSTITUTIONAL CONTROLS AND
HYDRAULIC CONTAINMENT 4-5 421 SHORT-TERM EFFECTIVENESS 4-8
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-9
423 LONG-TERM EFFECTIVENESS 4-9
424 COMPLIANCE WITH ARAR S 4-10
425 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-11
426 IMPLEMENTABILITY 4-11
427 COSTS 4-12
FOR ALLING INDUSTRIAL PARK MWP_DOCSW5J20OTALlIWFS9-00U0030929wro 11 HSI GSOTrflnS IflC
MITEC 104e 02354
TABLE OF CONTENTS (CONTINUED)
PAGE
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS
AND PERMEABLE REACTIVE BARRIER 4-13
431 SHORT-TERM EFFECTIVENESS 4-15
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-16
433 LONG-TERM EFFECTIVENESS 4-17
434 COMPLIANCE WITH ARARs 4-18 435 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-18
436 IMPLEMENTABILITY 4-19
437 COSTS 4-20
44 ALTERNATIVE 4 MONITORING INSTITUTIONAL CONTROLS
AND NATURAL ATTENUATION 4-20
441 SHORT-TERM EFFECTIVENESS 4-21
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-21
443 LONG-TERM EFFECTIVENESS 4-22
444 COMPLIANCE WITH ARARS 4-23
445 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-23
446 IMPLEMENTABILITY 4-23
447 COSTS 4-24
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION 4-25
451 SHORT-TERM EFFECTIVENESS 4-26
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-27
453 LONG-TERM EFFECTIVENESS 4-27
454 COMPLIANCE WITH ARARS 4-28
455 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-29
456 IMPLEMENTABILITY 4-29
457 COSTS 4-30
FOR ALLING INDUSTRIAL PARK MWPJXgtCSN7532000AUJNOFSlaquo)0I0030929WPD 111 HSI GeOTrSDS ItlC
MITEC 104e 02355
TABLE OF CONTENTS (CONTINUED)
PAGE
5 COMPARATIVE EVALUATION OF ALTERNATIVES 5-1 51 SHORT-TERM EFFECTIVENESS 5-1
52 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT 5 - 3 53 LONG-TERM EFFECTIVENESS 5-4
54 COMPLIANCE WITH ARARS 5-4
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 5-4
56 IMPLEMENTABILITY 5-5
57 COSTS 5-5
6 PREFERRED REMEDY 6-1 61 PREFERRED REMEDY 6-1
62 MONITORING PROGRAM 6-2
REFERENCES 7-1
APPENDIX A TWODAN INPUT FILES
FOR ALLING INDUSTRIAL PARK MWgt_DOCSW7532000WJJNGfS9^)0M00J(raquo9wpo I V H S I G S O T r a H S I n C
MITEC 104e 02356
LIST OF TABLES
PAGE
TABLE 3-1 REMEDIAL ACTION OBJECTIVES 3-7
TABLE 3-2 DESCRIPTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES 3-8
TABLE 3-3 SELECTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES
FOR DETAILED ANALYSIS 3-11
TABLE 41 COST ESTIMATES FOR REMEDIAL ALTERNATIVES 4-31
TABLE 6-1 SAMPLING LOCATIONS 6-5
TABLE 6-2 VOC ANALYTES 6-6
TABLE 6-3 PARAMETERS TO EVALUATE BIODEGRADATION 6-7
FOR ALLING INDUSTRIAL PARK MWP DOCSN7S32000AUJNOFS9-00I0030929 wro HSI GeoTrans inc
MITEC 104e 02357
LIST OF FIGURES
PAGE
FIGURE 1-1 STUDY AREA LOCATION MAP 1-2
FIGURE 1 -2 LATERAL BOUNDARIES OF REGION OF TCE-CONTAMINATED GROUNDWATER 1 -3
FIGURE 4-1 MODELED SITE-EXISTING CONDITIONS 4-33
FIGURE 4-2 MODELED SITE WITH THREE RECOVERY WELLS PUMPING AT 5 GPM 4-34
FIGURE 4-3 MODELED SITE WITH TEN RECOVERY WELLS PUMPING AT 5 GPM 4-35
FIGURE 4-4 ALTERNATIVE 3 PERMEABLE REACTIVE BARRIER 4-36
FIGURE 6-1 PROPOSED MONITORING LOCATIONS 6-8
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUUNOFS9-OOV 10030929 w r o VI HSI GeoTrans inc
MITEC 104e 02358
1 INTRODUCTION
This Corrective Action Feasibility Investigation is submitted on behalf of Mitec Telecom
Inc (Mitec) by HSI GeoTrans The investigation was done to evaluate potential remedial
alternatives for groundwater contaminated by trichloroethylene (TCE) and to a lesser extent
tetrachloroethylene (PCE) and petroleum related compounds (BTEX) at the Ailing Industrial
Park (the Study Area) A recently prepared Site Investigation Report (SIR) (HSI GeoTrans
2000) identified the nature and extent of contaminated groundwater within the Study Area
Figure 1-1 is a map ofthe Study Area and Figure 1-2 is a map that outlines the region of
contaminated groundwater for which potential remedial alternatives were evaluated
The SIR concluded that the TCE contamination was widespread across the Study Area
that residual TCE dense non-aqueous phase liquid (DNAPL) resulting from one or more releases
was a continuing source of contamination to groundwater and that under current conditions the
groundwater contamination does not pose an unacceptable risk to human health and the
environment Current conditions include the continued effective mitigation of indoor air vapors
at the residence at Lot 3-30 no other residences with basements below the water table and no
use of groundwater within the Study Area as a potable supply The SIR also concluded that if
groundwater were to be used as a potable supply a significant health risk would exist as a result
of exposure to groundwater through ingestion dermal contact and inhalation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^X)M0030929WPD 1 - 1 HSI GCOTrdnS ITC
MITEC 104e 02359
I - N -
Former Mitec Hold y
Meters
Explanation
Study Area TITLE
MITEC 104e 02360
Study Area Location Map
LOCATION
Williston Vermont CHECKED MS FIGURE HSI OfVFTED RMK
GEOTRANS RLE f s ~ Expa nd~S(tsdirq 1-1 A T I T M TICK C011irraquoraquoT DATE- 10600 ~
2 STUDY AREA CONCEPTUAL MODEL
The following discussion ofthe Study Area conceptual model is summarized from
information contained in the previously submitted SIR (HSI GeoTrans 2000)
21 STUDY AREA LOCATION AND DESCRIPTION
The Study Area is located at the Ailing Industrial Park and adjacent areas in Chittienden
County Williston VT The VT state plane coordinates for the Study Area are Northing
71210837 (44 27 T north latitude) and Easting 147576375 (73 7 50 west longitude) The
Study area is within the Winooski River watershed and has an elevation ranging from 330 to 350
feet above mean sea level (MSL) The ground surface has little relief and slopes gently to the
southwest A small unnamed brook flows in a southerly direction along the eastern edge of an
industrial park located within the Study Area There is unlimited public pedestrian access to the
Study Area
22 S T U D Y A R E A L A N D U S E
The land in the Study Area is currently zoned for mixed residential commercial and
industrial use The eastern portion ofthe Study area is primarily zoned for commercial use and
the western portion ofthe Study Area is predominantly residential The Study Area includes an
industrial park where there has been light industrial and commercial use since 1946 Three lots
in the industrial park have been previously identified as locations of former manufacturing andor
fabrication operations that resulted in release of contaminants to groundwater (Brinkerd 1996
TRC 1993 Griffin 1995)
23 HYDROGEOLOGIC SETTING
The unconsolidated geologic deposits beneath the Study Area consist of sand silt and
clay which were deposited in the former Champlain Sea overlying till The unconsolidated
deposits occur in four distinct layers The surficial deposits are medium to fine sand which
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000VALUNoFS9^X)10030929wro 2 - 1 H S I G e O T r a f l S J n C
MITEC 104e 02362
generally becomes finer-grained with depth and extend to approximately 20 feet below ground
surface (bgs) Interbedded silts and fine sands are present from approximately 20 to 40 feet bgs
An areally-extensive clay layer underlies the interbedded silt and fine sands at a depth of
approximately 32 to 60 feet bgs Beneath the clay layer is a dense till which extends from about
60 to 100 feet bgs The underlying bedrock is comprised of massive gray limestone gray
dolomite and white marble ofthe Beckman formation This bedrock is of lower Ordovician age
and is part ofthe Hinesburg Synclinorium structure
The aquifer in the Study Area and surrounding regions is primarily the surficial medium
and fine sands although some water is capable of being extracted from the lower silt and fine
sand The residences and businesses within the Study Area are currently serviced by a public
water supply and the aquifer is not used for potable water supply within the Study Area The
hydraulic conductivity ofthe medium to fine sands was determined from a slug test to be about
20 feetday (Johnson 1999) The hydraulic conductivity ofthe interbedded silt and fine sand as
determined from rising and falling head slug tests (HSI GeoTrans 2000) ranged from 1 to 20
ftday with a geometric mean of 38 ftday A pumping test of well NO-1 yielded a hydraulic
conductivity estimate of about 2 to 30 ftday for the combined medium to fine sands and
underlying silt and fine sand There are no hydraulic conductivity data for the underlying clay
and till layers It is believed that the clay and till act as a lower confining layers restricting the
vertical flow of water between the overlying sand and the underlying bedrock
Beneath the Study Area the depth to water generally ranges from 3 to 11 feet below
ground surface In general groundwater flow beneath the Study Area is from the north to the
southeast and southwest There is a groundwater divide in the water table that runs generally
parallel to Commerce Street East ofthe divide groundwater flows toward and discharges to the
unnamed brook West ofthe divide groundwater flows toward Muddy Brook which is located
about 300 meters or 1000 feet west ofthe Study Area Groundwater recharge within the Study
FOR ALLING INDUSTRIAL PARK MAWPJgtOCSN753UOOOWXINOFS9-O0l0030929wro 2-2 HSI GCOTrdnS IDC
MITEC 104e 02363
Area is primarily from infiltration of precipitation Prior to 1986 when a sewer line was
installed groundwater recharge also resulted from discharge to numerous on-site disposal
systems
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION
Figure 1-2 illustrates the 1999 distribution of TCE-contaminated groundwater within the
Study Area The lateral boundaries ofthe region of TCE-contaminated groundwater
approximately represent the lateral boundaries ofthe region of volatile organic compound
(VOC)-contaminated groundwater As discussed in the SIR (HSI GeoTrans 2000) VOCs
present in groundwater include TCE PCE and BTEX The compound detected at the highest
concentrations and over the largest portion ofthe Study Area is TCE PCE is generally detected
in the same area as TCE but at significantly lower concentrations BTEX compounds have been
detected in groundwater primarily in the eastern portion ofthe Study Area and are commingled
with but not coincident with TCE-contaminated groundwater The lateral boundaries shown in
Figure 1-2 approximately represent the lateral extent of groundwater contamination and are not
intended to indicate that all groundwater within those boundaries is contaminated This figure
includes data collected on behalf of Mitec as part ofthe SIR (HSI GeoTrans 2000) and data
collected in 1999 by the Johnson Company (Johnson 1999) Figure 4-2 A ofthe SIR (HSI
GeoTrans 2000) shows all TCE concentration data collected in 1999 as well as some data
collected in 1997 The SIR (HSI GeoTrans 2000) summarized previous investigations that
indicated that at least three properties have contributed to the region of VOC-contaminated
groundwater On Lot 19-11 there were a disposal lagoon and a leach field that resulted in the
release ofthe VOCs TCE and PCE (perhaps as an impurity in the TCE) Lot 19-12 once had
underground storage tanks from which a previous release of BTEX was discovered when the
tanks were removed Lot 19-2 contained a disposal pit and outfall pipe from which TCE was
reportedly released
Figure 1-2 of this report shows in plan view the areal distribution of TCE-contaminated
groundwater Where there were multiple 1999 data values for the same location preference was
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AL1JNOFS9-OOM0030929WPD 2-3 HSI GSOTraHS JHC
MITEC 104e 02364
given to samples collected by low-flow sampling done subsequent to well installation In
addition for those locations which had samples from different depths the sample with the
highest concentration was used Figure 1-2 illustrates that TCE-contaminated groundwater is
widespread beneath the Study Area and that the highest TCE concentrations are detected in
groundwater beneath the eastern portion ofthe Study Area The figure illustrates that TCE-
contaminated groundwater in the eastern portion ofthe Study Area discharges to the unnamed
brook No VOCs including TCE have been detected in groundwater samples collected from
wells on the eastern side of the unnamed brook Based on surface water and groundwater data
that have been collected the unnamed brook appears to limit the southeasterly extent ofthe
region of VOC-contaminated groundwater In the western portion ofthe Study Area the lateral
boundaries of contaminated groundwater were identified through vertical profile sampling at
several locations Figure 1-2 shows the location ofthe vertical profiling borings that define the
lateral extent of TCE-contaminated groundwater The SIR (HSI GeoTrans 2000) recommended
periodic sampling and analysis of wells in the western portion ofthe Study Area for the purpose
of determining whether this region of VOC-contaminated groundwater was stable or expanding
in size
While not evident from Figure 1-2 it was determined that throughout the Study Area the
highest TCE concentrations were detected in samples collected from the interbedded siltclay
layer As shown on Figure 4-2A ofthe SIR the higher TCE concentrations were generally
detected at a depth of about 35 feet below ground surface in the eastern portion ofthe Study
Area and at a depth of about 30 feet below ground surface in the western portion ofthe Study
Area It is believed that the current distribution of TCE contamination resulted from DNAPL
releases at one or more locations within the Study Area One such release area was at Lot 19-11
DNAPL migrated downward through the upper medium to coarse sands under the primary
influence of gravitational forces There would have been some lateral displacement along
preferential pathways provided by sloping unconsolidated deposits but the primary flow would
have been downward Upon encountering the more resistive capillary pressure forces associated
with the water-saturated finer-grained geologic units such as the interbedded silts and sands
FOR ALLING INDUSTRIAL PARK MVWP_DOCSN7532000ALUNCFS9J3010030929wro 2 - 4 H S I G C O T r d n S I r t C
MITEC 104e 02365
which exist beneath the upper medium to coarse sands the DNAPL downward migration would
have stopped The DNAPL would have accumulated on top ofthe capillary pressure barrier layer
and then would have spread laterally following preferential flow paths within the coarser-grained
geologic units above the interbedded silts and sands The amount of lateral spreading of
DNAPL from any release area would have been dependent upon the volume and frequency ofthe
releases As the DNAPL migrated it would have created a region of residual DNAPL This
region of residual DNAPL consists of isolated DNAPL droplets trapped within pore spaces ofthe
unconsolidated deposits The lateral migration ofthe DNAPL would have been affected by the
slope ofthe surface ofthe finer-grained units that halted downward migration ofthe DNAPL
and it would not necessarily have been coincident with the direction of hydraulic gradient or
groundwater flow The region of residual DNAPL is now a continuing source of contamination
to the groundwater which flows past and gradually dissolves the DNAPL The locations ofthe
residual DNAPL zones are not known
There were no direct observations of DNAPL during drilling and well installation but it
is expected that residual DNAPL generally exists within regions of higher concentration detected
in the eastern portion of the Study Area The residual DNAPL is not necessarily continuously
connected within that region Based on the vertical distribution of TCE concentrations it is also
expected that the residual DNAPL exists in a relatively thin zone within the interbedded silt and
clay Limited hydrodynamic dispersion within the interbedded silt and clay has resulted in a
relatively thin zone of relatively high TCE concentrations in groundwater The southeastward
and southwestward divergence of groundwater flow has resulted in a laterally extensive region of
TCE-contaminated groundwater
There has been no indication in any ofthe investigations done within the Study Area
including the SIR (HSI GeoTrans 2000) that there are locations within the Study Area where
DNAPL is present in sufficient volume to be recoverable in the DNAPL phase
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3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES
31 IDENTIFICATION OF ARARS
Two Applicable or Relevant and Appropriate Requirements (ARARs) were identified in
consultation with Mr Mike Smith ofthe Vermont Department of Environmental Conservation
(VTDEC) The first are the Groundwater Enforcement Standards as outlined in Appendix one of
the Chapter 12 Groundwater Protection Rule (VTDEC 1997) These standards apply to
concentrations of contaminants in groundwater in the Study Area (TCE PCE and BTEX) The
second are the Vermont Water Quality Criteria dated March 142000 (VTDEC 2000) which
specify surface water quality criteria and policy
32 REMEDIAL ACTION OBJECTIVES
The remedial action objectives (RAOs) for the Study Area are summarized in Table 3-1
and further described below
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES
One ofthe RAOs for the Study Area is the remediation of source areas Soil excavation
and removal has already occurred at the known release areas Not withstanding the fact that
previous DNAPL releases are suspected no areas of recoverable DNAPL have been detected in
the Study Area Concentrations of TCE in groundwater indicate it is present in some areas as
residual phase below the water table One purpose of this Corrective Action Feasibility
Investigation is to evaluate options for remediating residual DNAPL in the Study Area
322 GROUNDWATER
Attain VT Groundwater Enforcement Standards The ultimate goal of remediation is to
attain Groundwater Enforcement Standards for VOCs in groundwater This is in accordance
with the VT Groundwater Protection Rule and Strategy (VTDEC 1997) which states that If an
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(MUJNOFS9^)OM0030929WPD 3 - 1 HSI GCOTranS IttC
MITEC 104e 02367
enforcement standard has been reached or exceeded at a compliance point the goal is to take
appropriate action to retum the groundwater quality to below the enforcement standard if
possible
Prevent Expansion ofthe Dissolved Plume A risk assessment (Menzie Cura 2000a and
2000b) was included as part ofthe SIR (HSI GeoTrans 2000) The risk assessment concluded
that under current conditions concentrations of VOCs dissolved in groundwater in the Study Area
do not pose a risk to human health andor the environment The SIR (HSI GeoTrans 2000) also
indicated that the available monitoring data were not sufficient to determine whether the region
of VOC-contaminated groundwater in the southwestern portion ofthe Study Area was stable in
size or expanding This Corrective Action Feasibility Investigation explores options for
monitoring groundwater quality and preventing the region of VOC-contaminated groundwater
from expanding in size
Prevent Potable Use of Groundwater Within the Dissolved Plume Menzie Cura prepared
a June 1 2000 addendum (Menzie Cura 2000b) to the April 2000 risk assessment (Menzie Cura
2000a) The addendum evaluated risk posed by potable use of groundwater at the site The
addendum found there to be a human health risk associated with the use of groundwater at the
site for potable purposes One RAO of this Corrective Action Feasibility Investigation is to
propose institutional controls so that groundwater within the region of contaminated
groundwater would not be used as a potable supply until concentrations are suitable for such use
323 SURFACE WATER
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
under current conditions VOCs dissolved in surface water in the Study Area do not pose arisk to
human health or the environment Currently however surface water concentrations in the
unnamed brook exceed VT Water Quality Criteria (VTDEC 2000) One ofthe RAOs for the
site will be to meet these surface water quality standards in the unnamed brook
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324 INDOOR AIR
The VTDEC has conducted air sampling at several residences along Kirby Lane and
South Browneil Road The results have indicated the presence of TCE and PCE in indoor air at
some ofthe South Browneil Road residences (Brinkerd 1996) and unacceptable VOC
concentrations in the basement ofthe residence at Lot 3-30 on South Browneil Road The
presence of VOC vapors in the residence on Lot 3-30 is believed to have resulted from
volatilization of groundwater which infiltrated the basement through a continuously operating
sump pump The sump was vented to the exterior ofthe house as part of a state-sponsored
action and the indoor air concentration ofthe contaminants reduced to an acceptable
concentration Therefore one institutional control for the site will be to maintain the sump
venting as long as necessary to prevent health risks due to inhalation of VOC concentrations in
indoor air Also an institutional control in the form of a zoning restriction should be
implemented to prohibit the construction of new buildings with basements below the water table
in the region of contaminated groundwater The restriction should specify that in cases where it
is unavoidable to place the basement below the water table proper containment and venting of
the sump drainage system is required
33 INITIAL SCREENING
Four general categories of remedial technologies were evaluated The first monitoring
may be used alone or in conjunction with other remedies The second category includes
institutional controls to prevent exposure to contamination in groundwater and indoor air
Institutional controls could also be used alone or in conjunction with other remedies The third
category includes source removal technologies
The fourth category includes contaminated groundwater containment technologies such
as a hydraulic barrier or permeable reactive barrier Containment technologies can be applied in
two different ways Thefirst source control application would entail installing the containment
technology directly downgradient ofthe highest dissolved concentrations in an attempt to contain
the contaminated groundwater nearest the source Over time if new contamination is not
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MITEC 104e 02369
allowed to migrate beyond the source VOC concentrations in the downgradient region of
contaminated groundwater should attenuate
The second application would entail installing the containment technology at the
downgradient edge ofthe region of Contaminated groundwater The containment would protect
downgradient receptors from impacts by the region of contaminated groundwater
Both containment technology approaches were considered for use in the event additional
monitoring data shows that the region of VOC-contaminated groundwater is expanding in size
or if VOC concentrations in groundwater discharging to the unnamed brook are increasing
Table 3-2 identifies the remedial technologies considered and summarizes the results ofthe
initial screening for applicability to addressing the ARARs
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES
The list of potentially viable technologies shown in Table 3-2 was subjected to an initial
screening process The purpose ofthe initial screening was to identify those technologies that are
potentially feasible in the Study Area prior to performing a more detailed technology screening
Many ofthe source removal technologies were removed from further consideration because of
the impracticability of remediating residual DNAPL at the site
As described in the SIR (HSI GeoTrans 2000) DNAPL is likely present in the Study
Area Although present DNAPL has not been directly observed in any location and there has
been no indication that there is recoverable DNAPL present The failure to detect DNAPL
directly is not an uncommon situation at DNAPL sites and commonly results from its
heterogeneous distribution or its presence only at residual saturation (US EPA 1992)
Groundwater extraction and treatment is not an effective technology for remediation of residual
DNAPL due to limitations resulting from the limited solubility of most DNAPL compounds and
the heterogeneous distribution ofthe DNAPL (US EPA 1993) Designing remedial strategies
for DNAPL is made difficult by the inability to accurately locate the DNAPL sources This
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320(XAALlJNoFS9^)010030929wro 3 - 4 H S I G C O T r a n S I n C
MITEC 104e 02370
inability to locate the DNAPL renders the use of targeted source remedies that might be cost
effective for a small readily definable source area ineffective These targeted source remedies
include excavation air sparging chemical oxidation in-situ thermal desorption and chemical
flushing technologies
Subsurface deposits in the Study Area are heterogeneous due to the interbedded nature of
the sands and silts overlying an areally extensive clay The presence of such heterogeneity
creates extremely variable and unpredictable groundwater flow velocities as well as flow paths
for DNAPL migration The contrast in permeability and porosity between different lithologies
results in the development of preferential flow pathways While preferential flow through coarse
sand and gravel zones provides higher than average groundwater flow rates and contaminant
flushing less preferential flow pathways such as silty sands silts and clays remain poorly
flushed even under forced hydraulic gradients created by extraction wells Contaminants
however may have migrated to these areas of less preferential flow as DNAPLs under
gravitational influence or by diffusion over long periods of time The low permeability zones
even if addressed by localized extraction of groundwater will transmit only small quantities of
water and hence contaminant flushing is slow This is compounded by the low solubility of
DNAPL constituents and the tendency for them to become trapped in soils by capillary pressure
forces
Specific source removal technologies which have been screened out as ineffective at this
stage include air sparging groundwater amendments excavation and in-situ thermal desorption
Low permeability zones prevent the migration of soil vapors or sparged air to the near-surface for
recovery due to the preferential flow caused by heterogenieties it is not possible to determine if
amendments which can be added to the groundwater or chemical flushing compounds which
displace the groundwater and help liberate residual DNAPL such as oxidants alcohol polymers
andor surfactant would reach the DNAPL Excavation which has already been used to remove
impacted surface soils in known release areas is not practical for removing residual DNAPL
deep below the water table The in-situ thermal desorption can be useful in some environments
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MITEC 104e 02371
but can also induce downward DNAPL migration if hydraulic control ofthe system is not
complete Because the location of residual DNAPL is not known and because hydraulic control
ofthe underlying silt clay and till into which the DNAPL may migrate cannot be assured in-situ
thermal desorption is not feasible for this site
Monitoring and institutional controls are included in each option evaluated except for the
no-action alternative These are required to rule out possible future health risks due to expansion
ofthe region of VOC-contaminated groundwater or the creation of new contaminant exposure
pathways
The technologies remaining after the initial screening are presented in Table 3-3
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Table 3-1 Remedial action objectives
MEDIA REMEDIAL ACTION OBJECTIVE
Groundwater -Remove or control contaminant sources
bullAttain VT Groundwater Enforcement Standards
-Prevent expansion ofthe region of contaminated groundwater
-Prevent use of groundwater within the region of contaminated groundwater as a
potable water supply where contaminant concentrations exceed federal drinking
water standards
Surface Water -Attain VT Water Quality Criteria
Air -Prevent inhalation of concentrations in indoor air derived from groundwater
FOR ALLING INDUSTRIAL PARK MWP DOCSW7520(XMUJNOFS9^XM0030929WPO 3-7 HSI GeoTrans inc
MITEC 104e 02373
-n Table 3-2 Description of potentially viable remediation technologies o w o
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R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Basement Sump Venting
Restriction on new buildings with basements set below the water table
Restrict Potable Use of Groundwater
Excavation
Natural Gradient Flushing
Air Sparging
RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
PROCESS DESCRIPTION OPTIONS
No Action No Action
Monitor groundwater concentrations to confirm that region of VOC-contaminated groundwater is not expanding in size
Monitor surface water concentrations in unnamed brook to ensure concentrations remain below risk levels
Continue to vent the sumps at Lot 3-30 on South Browneil Road
Restrict construction of any new buildings with basements set below the water table within the area of dissolved VOC contamination and require basement sump venting in those where a below water table basement is unavoidable
Place restrictions on potable use of groundwater at properties overlying the region of VOCshy contaminated groundwater
Excavation and removal of soils containing residual DNAPL
Continued dissolution and natural attenuation of residual DNAPL
Injection of air beneath the water table to volatilize residual DNAPL and dissolved concentrations in groundwater
INITIAL SCREENING C O M M E N T
Used as a baseline for comparison No cost Long remediation time
Can be used in conjunction with other response actions Will be required in the southwest portion ofthe region of contaminated groundwater since existing data are inconclusive regarding this issue
Can be used in conjunction with other response actions
Will be required until data show there is no longer a risk to indoor air from groundwater in the basement
Will be required until data show there is no risk of migration of VOCs to indoor air from groundwater
Will be required at all properties in the area of VOC-contaminated groundwater to prevent a risk to human health
Has been used at the site to remove residual DNAPL in soils in the release areas Impractical to recover residual DNAPL at depth The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Intermediate cost Short time frame to cleanup if all residual source can be removed
Higher permeability zones are preferentially remediated On-going monitoring required No installation or on-going maintenance costs Long time frame to cleanup
Small-scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Intermediate installation and high on-going maintenance costs
MITEC 104e 02374
5 T l O Description of potentially viable remediation technologies (continued) PO
Table 3-2 O
RESPONSE REMEDIAL PROCESS g 5 ACTION TECHNOLOGY OPTIONS 5 m
r-m Source Chemical Ozone m Removal Oxidation Sparging q JO o n o
o
Potassium Permanganate Injection
Fentonss Reagent Injection
i co
Source In-Situ Steam Removal Thermal Stripping
Desorption
Electrical Resistance Heating
I Radio (pound Frequency
O m Heating OH 3) gt Z 0)
DESCRIPTION
Injection of air and encapsulated ozone beneath the water table to oxidize dissolved DNAPL constituents such as TCE
KMn04 is injected below the water table to oxidize dissolved DNAPL constituents
Fentons Reagent is injected below the water table to oxidize dissolved DNAPL constituents
Stream injected below the water table As the groundwater and soil are heated residual DNAPL is mobilized and collected by groundwater and soil vapor extraciion techniques
Low frequency alternating current is applied below the water table to cause resistive heating ofthe soil and groundwater As the groundwater and soil heat residual DNAPL is mobilized Groundwater and soil vapor extraction techniques are used to collect dissolved and vaporized DNAPL constituents
Electromagnetic radiation is applied below the water table As the groundwater and soil heat residual DNAPL is mobilized
INITIAL SCREENING COMMENT
Presence of DNAPL will potentially require large quantities of ozone The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Small scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Ozone is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of KMn04 The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of Fentons Reagent The exact location of the residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Fentons Reagent is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Small scale heterogenieties can result in channeling during steam injection and reduce the recovery efficiency Shallow depth of application may preclude effective steam control The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeneity has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeniety has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult so target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
_ mdash_ mdash _ _
MITEC I04e 02375
bulln Table 3-2 Description of potentially viable remediation technologies (continued) o
R E S P O N S E
A C T I O N
tn Source Removal
Source Containment Plume Management
co bull
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REMEDIAL
TECHNOLOGY
Chemical Flushing
Hydraulic Containment
Impermeable Barrier
Permeable Reactive Barrier
Phytoshyremediation
PROCESS
OPTIONS
bull
DESCRIPTION
Injection and recovery of alcohol polymers andor surfactant below the water table to enhance dissolution of residual DNAPL
Pump groundwater in downgradient portion of VOC-contaminated region groundwater to intercept contamination before it reaches a receptor or downgradient ofthe highest concentrations as source containment
Impermeable barrier is installed in the subsurface to contain groundwater and reduce the pumping rate needed for containment Can be installed upgradient of a receptor to prevent exposure or downgradient of the highest concentrations as source containment
Reactive material such as zero valent iron placed in flow path of contaminated groundwater Contaminants are treated as the natural gradient causes groundwater to flow through the barrier
Extracting of contaminated groundwater by evaporation from high water use trees Organic contaminants may also be biodegraded by the root system or may adsorb to living or dead root tissue and become immobilized
INITIAL SCREENING C O M M E N T
Higher permeability zones are preferentially remediated The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Groundwater extraction is required to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent fulfresidual DNAPL removal Very high installation and operation cost
Effective in containing dissolved concentrations Relatively low installation cost moderate on-going maintenance costs
Effective in containing dissolved concentrations Requires groundwater extraction and treatment Moderate installation cost moderate on-going maintenance costs
Moderate installation costs Lifetime of reactive material difficult to predict and reinstallation may become necessary No on-going maintenance costs prior to replacement
Still experimental Hard to confirm water usage rates and prove containment Trees may require ongoing monitoring and replacement Low installation and maintenance costs Only operates during the growing season
MITEC 104e 02376
1 T l Table 3-3 Selection of potentially viable remediation technologies for detailed analysis 1
rt g g g
5
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RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Indoor Air Monitoring
Basement Sump Venting
Potable Use of Groundwater
Restrict Basements Below Water Table
Excavation
Natural Gradient Flushing
Air Sparging
Chemical Oxidation
In-Situ Thermal Desorption
Chemical Flushing
PROCESS
OPTIONS
No Action
Ozone Sparging
Potassium Permanganate Injection
Fentonss Reagent Injection
Steam Stripping
Electrical Resistance Heating
Radio Frequency Heating
RETAINED
DISCARDED
Retained
Retained
Retained
Retained
Retained
Retained
Retained
Discarded
Retained
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
RATIONALE
Used as a baseline for comparison
Necessary to evaluate if the region of VOC-contaminated groundwater is expanding in size and if the VOC concentrations in groundwater discharging to the unnamed brook are increasing
Necessary to monitor that concentrations remain below health risk levels
May be required al new residences with basements below the water table built in Browneil Road area
The existing sump vents at Lot 3-30 on South Browneil Road will be required to mitigate indoor air risks
Restriction of potable use of groundwater at properties overlying the region of VOC-contaminated groundwater will be required to prevent dermal ingestion and inhalation exposure
Restriction of construction of new basements below the water table in the area of VOC-contamination will be required to prevent future inhalation risks
Residual DNAPL located too far below ground surface to make excavation feasible The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Excavation of known release areas has occurred
Longer time frame to clean up not a drawback at this site Lower cost is a benefit
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location of the residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL Steam control difficult
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
MITEC 104e 02377
2 Table 3-3 Selection of potentially viable of remediation technologies for detailed analysis (continued) a m RESPONS E R E M E D I A L PROCES S RETAINED RATIONALE
ACTION T E C H N O L O G Y OPTION S DISCARDED
Source Containment Hydraulic Containment Retained Proven effective at containing expansion ofthe region of contaminated groundwater Region of Contaminated
iisect
n n o
Groundwater Management
Impermeable Barrier Retained Proven effective at region of contaminated groundwater containment
Permeable Reactive Retained Proven effective at region of contaminated groundwater containment Barrier
Phyto-remediation Retained Experimental however there are no potential negative consequences in using the technology Low cost is a benefit
co i
IO
I (A O m OH 73 gtZ
MITEC 104e 02378
4 DETAILED ANALYSIS OF ALTERNATIVES
41 ALTERNATIVE 1 NO ACTION
The no-action alternative is included in accordance with EPAs Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA (EPA 1988) The no-action
alternative provides a baseline for comparison and involves taking no additional actions at the
Study Area This remedy assumes no continuing monitoring of dissolved concentrations in
groundwater surface water or concentrations in indoor air This remedy assumes no institutional
controls on basement sump venting at Lot 3-30 on South Browneil Road property no restrictions
on new buildings with basements set below the water table constructed within the area of VOC
concentrations in groundwater and no restrictions groundwater use for potable purposes within
the region of VOC-contaminated groundwater
411 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community The risk assessment completed for the SIR
(HSI GeoTrans 2000) concluded that current conditions at the Study Area do not pose a risk to
human health Current conditions include venting ofthe sump at Lot 3-30 on South Browneil
Road no buildings other than at Lot 3-30 with basements below the water table in VOC-
contaminated areas and no potable-use wells within the region of VOC-contaminated
groundwater Without institutional controls to ensure this there may be future risk The risk
evaluation indicated that concentrations in the unnamed brook resulting from contaminated
groundwater discharge while not above risk-based thresholds were close to levels that could
pose a risk to human health Therefore monitoring is advised to confirm that VOC
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7533000AUJNOFS9^010030929WPD 4 - 1 HSI GGOTrSOS jflC
MITEC 104e 02379
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of VOC-contaminated groundwater could result in health risks not
evaluated in the risk assessment
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative
Time to Achieve Remedial Action Objectives It is estimated that the time frame required
for natural attenuation of contaminants to meet the groundwater cleanup concentrations will
significantly exceed the two-year time frame used to evaluate short-term effectiveness
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment There is no treatment of contaminants under this option
Reduction in Toxicity Mobility or Volume Some reduction of residual DNAPL and
accompanying dissolved concentrations is expected through natural attenuation over time if no
action were pursued at the Study Area However no monitoring data would be available to
confirm the progress
Amount of Material Contained or Treated Natural attenuation may serve to contain the
entirety of the region of groundwater contaminated with dissolved VOCs
413 LONG-TERM EFFECTIVENESS
Residual Risk Therisk assessment completed for the SIR (HSI GeoTrans 2000)
concluded that current conditions at the Study Area do not pose a risk to human health
However the risk evaluation indicated that concentrations in the unnamed brook resulting from
contaminated groundwater discharge while not above risk-based thresholds were close to levels
that could pose a risk to human health Therefore monitoring is advised to confirm that VOC
FOR ALLING INDUSTRIAL PARK
M W P _ D O C S N 7 5 3 2 0 0 0 A L U N O F S W raquo I 0 0 3 0 9 2 9 W P D 4-2 HSI GeOTrdDS IflC
deg2380
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of contaminated groundwater could result in health risks not evaluated in
the risk assessment Without institutional controls to ensure basement sump venting at Lot 3-30
on South Browneil Road restrictions on new buildings with basements set below the water table
within the region of VOC-contaminated groundwater and prevention ofthe installation of wells
for potable supplies within the region of VOC concentrations in groundwater a residualrisk to
human health remains
Adequacy and Reliability of Controls This remedy does not assume the sump in the
basement ofthe residence at Lot 3-30 on South Browneil Road remains sealed and vented to the
outside and that the pump is maintained in operable condition to continue to keep groundwater
out ofthe basement Previous air sampling conducted by the VTDEC has confirmed that this is
necessary to control indoor air impacts to this residence This remedy relies on natural
attenuation to control the region of VOC-contaminated groundwater however there is no
continuing monitoring of dissolved VOC concentrations in groundwater Since monitoring to
date has not confirmed that the region of VOC-contaminated groundwater is not expanding in
size a remedy which has a natural attenuation component but does not include monitoring does
not provide adequate control
Permanence of Remedy In the very long-term natural gradient flushing should reduce
VOC concentrations in groundwater to acceptable levels
414 COMPLIANCE WITH ARARs
Groundwater Protection Rule and Strategy It is expected that natural attenuation would
over time reduce groundwater concentrations to below VT Groundwater Enforcement Standards
However a no-action response would not comply with VT Groundwater Protection Rule and
Strategy (VTDEC 1997) which allows for remediation of sites by natural attenuation if sufficient
monitoring is perfonned to document that expansion ofthe region of contaminated groundwater
is not occurring and that natural attenuation is occurring The no-action alternative would not
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AU1NGFS90010030929wro 4-3 HSI GSOTraFIS IflC
MITEC 104e 02381
allow for continued monitoring and would not meet this requirement
Surface Water Quality Standards It is expected that natural attenuation would over
time reduce surface water concentrations to below VT Water Quality Criteria for the protection
of human health and aquatic organisms (VTDEC 2000)
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
concentrations of VOCs adsorbed to soil and dissolved in groundwater in the Study Area do not
pose a risk to human health andor the environment under current uses There would be arisk if
groundwater within the region of VOC-contamination were used as a potable supply Therefore
if dissolved concentrations were not migrating beyond the limits ofthe region identified in the
SIR (HSI GeoTrans 2000) and groundwater were not used for potable purposes the no action
alternative would be protective of human health and the environment However there are not
sufficient data to determine whether the region of VOC-contaminated groundwater is stable or
decreasing in size If the region of contaminated groundwater were expanding beyond the limits
upon which the risk assessment was based there may be a future risk to human health and the
environment Also restrictions should be placed on properties overlying the region of VOC-
contaminated groundwater to prohibit construction of basements below the water table and the
use of groundwater as a potable supply and the venting ofthe sump at Lot 3-30 should continue
416 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000AlXINGFS900U0030929wro 4-4 HSI GGOTrdRS IflC
MITEC 104e 02382
Technical Feasibility The no-action alternative is technically feasible
bull Ability to Construct the Alternative The no-action alternative requires no
construction
bull Reliability ofthe Technology No technology would be applied under the no-
action alternative
bull Ease of Undertaking Additional Remedial Actions The no-action alternative
would not prevent future remedial actions
Administrative Feasibility The no-action alternative is administratively feasible
Availability of Services and Materials No services or materials are required to carry out
the no-action alternative
417 COSTS
There are no costs associated with the no-action alternative The no-action alternative is
shown on Table 41 for purposes of comparison
4 2 A L T E R N A T I V E 2 M O N I T O R I N G INSTITUTIONAL C O N T R O L S AND
H Y D R A U L I C C O N T A I N M E N T
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull institutional controls would be implemented to restrict construction of any
buildings with basements within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull groundwater extraction and treatment would be done to contain the region of
VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753laquo000WJJNoFS9JXI10030929wro 4 - 5 HSI GSOTraDS JllC
MITEC 104e 02383
Groundwater pumping is an effective technology for hydraulic containment of
contaminated groundwater Hydraulic containment can be used if the region of VOC-
contaminated groundwater is impacting a sensitive receptor or is expanding is size The risk
assessment (Menzie Cura 2000a and 2000b) showed that groundwater was not impacting any
receptors to a degree that would represent a human health risk or risk to the environment There
is not sufficient temporal data however to confirm that the region of VOC-contaminated
groundwater is not expanding is size Therefore an analysis of hydraulic containment has been
included in this Corrective Action Feasibility Investigation in the event that future monitoring
shows the region of VOC-contaminated groundwater is expanding and that containment is
necessary
If monitoring indicates that natural attenuation is not causing the region of VOC-
contaminated groundwater to be stable in size or to shrink then an active containment remedy
may be required Under this scenario a groundwater pump-and-treat system would be installed
and operated in the Study Area to hydraulically contain contaminated groundwater and prevent
expansion ofthe region of VOC-contaminated groundwater Pumping wells would be installed
in the overburden silts and sands to the clay layer Wells would be installed in the downgradient
portions of contaminated groundwater to the southeast and southwest Extracted groundwater
would be treated before discharge to surface water The primary treatment operation will be air
stripping with a low-profile stripper for the removal of VOCs primarily TCE Depending on
treatment efficiencies secondary treatment with granular activated carbon may be required In
addition a particulate filter may be added to remove iron prior to treatment and reduce iron
fouling ofthe air stripper and carbon Extracted and treated groundwater would be discharged to
surface water via an outfall Compliance sampling can be conducted at the outfall or at a
sampling point within the treatment building The outfall should be constructed to minimize
hydraulic impacts on the receiving water body
The number and location of pumping wells that may be required to capture and contain
the region of TCE-contaminated groundwater has been investigated using the two-dimensional
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9JXA10030929WO 4-6 HSI GSOTfanS IdC
MITEC 104e 02384
analytical element simulation code TWODAN (Fitts 1997) TWODAN is a commercially
available copyrighted program The input parameters to the model are based on the values
reported in the SIR (HSI GeoTrans 2000) Input data sets for the analyses contained in this
report are included in Appendix A The bottom elevation ofthe model is 306 ft which is
representative ofthe top ofthe continuous clay layer beneath the site The model represents the
interbedded silts and fine sand layer and the overlying medium to fine sand surficial unit as one
layer The hydraulic conductivity ofthe modeled layer is 184 ftday The estimated areal
recharge for the model is 10 inyr The basement sump at Lot 3-30 on South Browneil Road
pumps groundwater year round The resulting depression ofthe water table is represented by a
constant head of 33128 ft which is approximately 8ft below ground surface at that location
Groundwater elevations used in the model were based on an average ofthe July 1999 and
December 1999 potentiometric surface in wells with screened intervals intersecting the water
table The model representation of current hydrologic conditions at the Study Area is shown in
Figure 4-1 Groundwater elevations are shown in meters on this figure
Two containment scenarios were evaluated The first was a source control application in
which the TWODAN model was used to determine the number of wells and pumping rates
required to contain the 10000 to 20000+ ugL TCE concentration zone as shown in Figure 1-2
In this scenario pumping would contain the contaminated groundwater nearest the source(s)
Over time if new contamination is not allowed to migrate from the source(s) the VOC
concentrations in the rest ofthe region of contaminated groundwater would attenuate The
second scenario was a containment application in which the TWODAN model was used to
determine the number of wells and pumping rate required to contain the 1000 to 10000 (igL
TCE concentration zone as displayed in Figure 1-2 In this scenario pumping occurs in the
downgradient portions ofthe contaminated groundwater
Each recovery well was assumed to be 4 inches in diameter fully screened and have a
pumping rate of 5 gpm The pumping rate was based on the aquifer testing results reported in the
SIR (HSI GeoTrans 2000) applied to a fully screened extraction well The results ofthe model
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000A1XINOFS9JX)10030929WPD 4-7 HSI GSOTraDS IflC
MITEC 104e 02385
analyses indicate that a minimum of three 4-inch diameter recovery wells pumping at 5 gpm are
required to contain the 10000 to 20000+ ugL TCE concentration zone The results of this
model simulation are shown on Figure 4-2 The model analyses also indicated that a minimum
often 4-inch diameter recovery wells pumping at 5 gpm are required to contain the 1000 to
10000 ugL TCE concentration zone Figure 4-3 shows the results of this model simulation
Figures 4-2 and 4-3 also show that groundwater extraction for hydraulic containment may induce
infiltration of surface water in response to pumping thereby reducing the amount of water
flowing in the brook
421 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 2 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with extraction well construction and treatment plant construction Access by
unauthorized personnel would be restricted by fencing temporary barriers andor warning signs
The groundwater treatment building would be locked and secured A health and safety plan
(HASP) would be prepared for the remedial activities In conformance with Occupational Safety
and Health Administration (OSHA) regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative Suitable dust control measures would be implemented during
construction ofthe groundwater treatment system Additionally the treatment process is
expected to be relatively simple with a low potential for exceedance of discharge limitations
Monitoring ofthe treatment process would be performed
Time to Achieve Remedial Action Objectives The time estimated for well installation
system debugging and establishing hydraulic gradient control is three to six months The RAOs
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^XM0030929wro 4-8 HSI GSOTraOS IIIC
MITEC 104e 02386
for groundwater would be achieved when monitoring results indicated that VOC concentrations
had attenuated and groundwater standards had been met It is estimated that attenuation of VOC
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of recovered groundwater would remove some ofthe VOCs from
the aquifer This treatment would generate residuals such as used filters and spent carbon This
process is irreversible
Reduction in Toxicity Mobility or Volume Treatment ofthe extracted groundwater
would reduce its toxicity prior to surface water discharge Contaminants adsorbed to any
secondary carbon would ultimately be destroyed during the process of regenerating the carbon
Contaminants adsorbed to any particulate filters would be landfilled or incinerated along with the
filters The toxicity and volume of contamination in groundwater are nominally reduced by
extraction and treatment but effectiveness is limited as discussed in Section 421 above
Modeling shows that groundwater extraction would be effective in reducing the mobility ofthe
dissolved phase contamination
Amount of Material Contained or Treated The volume of contaminated groundwater
that would be treated on a long-term basis is estimated at about 8 million gallons per year for the
source containment option and about 26 million gallons per year for containment of all dissolved
TCE concentrations greater than 1000 ugl
423 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
FOR ALLING INDUSTRIAL PARK MWPJXXTSN75320(XAAUJNOFS9-OCM0030929WKgt 4-9 HSI GSOTrSDS IDC
MITEC 104e 02387
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Groundwater pumping would control any risks caused by expansion ofthe
region of contaminated groundwater Residual risk to human health would be controlled through
institutional controls
Adequacy and Reliability of Controls Extracted groundwater would be treated on-site to
standards required for discharge to surface water The extraction well pumps and groundwater
treatment equipment would require maintenance on a long-term basis Groundwater monitoring
to ensure that the contamination was being adequately contained by the groundwater extraction
would be necessary on a long-term basis
Permanence of Remedy The groundwater treatment plant would be enclosed and
designed as a modular system and its equipment would be readily replaceable if required The
extraction wells may need to be rehabilitated andor replaced during the life ofthe remedy
424 COMPLIANCE WITH A R A R S
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to return the
remaining groundwater to below Groundwater Enforcement Standards Groundwater extraction
would also eventually return the areas of highest groundwater contamination to below
Groundwater Enforcement Standards
Surface Water Quality Standards Hydraulic control of the groundwater migration would
interrupt and remove contaminates from groundwater thereby preventing discharge to the
unnamed brook resulting in achievement of Water Quality Criteria for the protection of human
health and aquatic organisms (VTDEC 2000)
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200OALUNoFS9^Kgtl0030929wro 4-10 HSI GOOTrSDS IDC
laquoTEC I04e 02388
425 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The hydraulic containment alternative would offer protection to both human health and
the environment if expansion ofthe region of contaminated groundwater were identified Since
the risk assessment (Menzie Cura 2000a) found that under current conditions groundwater and
surface water concentrations are below levels which constitute a risk to human health and since
hydraulic containment would ensure the region of VOC-contaminated groundwater remained in
the current configuration hydraulic containment would be protective of human health and the
environment This alternative assumes institutional controls will be in place to continue sump
venting in the basement at Lot 3-30 on South Browneil Road restrict the installation of
basements below the water table within the region of VOC-contaminated groundwater and
prevent potable use of groundwater within the region of VOC-contaminated groundwater
Protection would be achieved at the end ofthe construction period of three to six months The
residual risks posed by contaminated material remaining within the groundwater would not be
significant because all potential exposure routes would be addressed
426 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction which would present no special problems
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AUB4CFS9^10l0030929wro 4 - 1 1 HSI GGOTrdDS IDC
MITEC 104e 02389
bull Reliability ofthe Technology Hydraulic gradient control is a frequently used
alternative that has proven effective in preventing further expansion of areas with
- contamination in groundwater Filtration air stripping and carbon absorption
have frequently been used and proven effective in treating groundwater in other
applications
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the
gradient control system was inadequate to restrict the expansion ofthe region of
contaminated groundwater implementation of additional resources would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
operate maintain and monitor the well head portions ofthe treatment system Institutional
controls would also be needed to implement institutional controls to continue sump venting in
the basement at Lot 3-30 on South Browneil Road The town must pass zoning restriction which
would prevent construction of basements below the water table and potable use of groundwater
within the region of contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor the groundwater treatment system associated with the hydraulic containment option
are available
427 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 2 The
capital costs would be $207000 for the source control application and $732000 for the
containment option OampM costs include groundwater monitoring and maintenance ofthe
groundwater extraction and treatment system These are $77000 per year for the source control
application and $139000 per year for the containment option The present worth analysis
(calculated at a 7 discount rate interest for 30 years) yields a total of $1085403 for the source
control application and $2287474 for the plume containment option
FOR ALLING INDUSTRIAL PARK MWPJXXSN753U0OOALUNGFS9-tfW0030929wro 4-12 HSI GSOTrailS IRC
MITEC 104e 02390
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS AND
PERMEABLE REACTIVE BARRIER
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull and a permeable reactive barrier would be installed and maintained at a
downgradient location to reduce concentrations of TCE dissolved in groundwater
as it flows under natural gradient flow conditions if groundwater monitoring
shows the region of VOC-contaminated groundwater is expanding in size
PRBs consist of a permeable region of chemically reactive materials constructed to
intercept the path of a dissolved groundwater contaminants Reactive materials may include
bull zero-valent iron for reductive dehalogenation
precipitation agents such as gypsum to create insoluble metal salts
bull sorptive agents such as granular activated carbon to capture and immobilize organics
bull reducing agents such as dithionite and hydrogen sulfide to reduce and insolubilize metals
and
bull biologic electron acceptors such as lactic acid or nitrate to enhance aerobic
biodegradation
FOR ALLING INDUSTRIAL PARK MAWPJX)CSVN7532000AmNOFS9-OOU0030929wpo 4-13 HSI GSOTrSDS IDC
MITEC 104e 02391
Zero-valent iron and granular activated carbon are both applicable for use in the treatment
of TCE in a PRB Granular zero-valent iron has been widely applied in PRB installations and
promotes reductive dehalogenation of TCE to chloride ion ethane and ethene Activated carbon
has been used in a limited number of field and lab studies to simply adsorb dissolved organic
constituents as they pass through thePRB
Because ofthe costs ofthe reactive or adsorptive material PRBs are generally
constructed as a funnel and gate system The funnel portion ofthe PRB is a typical vertical
barrier wall constructed of sheet piles bentonite or other impermeable material which is
designed to direct groundwater flow to the gate portion ofthe PRB containing the reactive or
adsorptive material Funnel and gate sections ofthe PRB are keyed together and generally to a
low permeablility zone located at depth
The use of permeable reactive barriers is not directly applicable to treatment of DNAPL
The mechanism for groundwater remediation using a PRB would include
bull dissolution ofthe DNAPL into groundwater by natural processes
bull downgradient transport ofthe dissolved contaminants to the PRB location
artificial channeling ofthe contaminated groundwater to the reactive material located in
the gate by the barrier funnel and
bull reductive dehalogenation or adsorption of a portion ofthe VOC as is passes through the
gate
A variety of methods are available for emplacement ofthe PRB The most conventional
method includes excavation of a trench and backfill will a soilbentonite slurry for the funnel
portion and granular iron or carbon in the gate section Other methods such as sheet-piling jet
grouting continuous trenching fracturing and others are available For the subject site because
ofthe presence of sand in the formation it is likely that a continuous trenching method would be
the most applicable and cost effective
FOR ALLING INDUSTRIAL PARK MWPJX)CSN7S320O0ALUNGFSraquo-O0U0030929wro 4-14 HSI GGOTfaDS IOC
MITEC 104e 02392
Operation maintenance and monitoring ofthe PRB is relatively simple Groundwater
samples would be periodically collected from locations upgradient and downgradient ofthe gate
section(s) ofthe PRB to monitor its effectiveness Media installed in the gate (iron or carbon)
would require periodic replacement probably on a annual basis for carbon and every 5 to 10
years for iron
The placement depth width and length ofthe PRB would depend on the region of
VOC-contaminated groundwater that was desired to be intercepted the depth to the underlying
low permeability layer and the desired TCE concentration reduction (which determines resident
time required in the gate) As wilh hydraulic containment two scenarios were investigated The
first a source control option would intercept VOC-contaminated groundwater with TCE
concentrations greater than 10000 ugL A PRB of approximately 1200 feet in length would be
required The second a region of contaminated groundwater containment option would
intercept VOC-contaminated groundwater with TCE concentrations in excess of 1000 ugL A
PRB of approximately 2200 feet in length would be required The depth ofthe PRB in both
cases would likely extend from ground surface to about 40 feet below ground surface The PRB
would be installed into the underlying areally-extensive clay layer Figure 4-4 shows the
placement ofthe PRB under each opinion
431 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 3 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with PRB construction since either conventional or continuous trenching methods
would be employed during its construction However exposure hazards during construction
would be considerable since the emplacement requires excavation and handling of a large
volume of potentially contaminated soils During construction access by unauthorized personnel
would be restricted by fencing temporary barriers andor warning signs Following
FOR ALLING INDUSTRIAL PARK
MWP_DOCSN753 2000 AUJNCFS9^10 10030929 WPD 4-15 HSI GSOTrSPS IDC
MITEC 104e 02393
construction little to no hazards should be expected from the long-term operation ofthe PRB A
HASP would be prepared for the construction activities In conformance with OSHA
regulations site workers would be trained required to wear appropriate protective equipment
and as applicable would be enrolled in a medical monitoring program Groundwater monitoring
wells would be sampled to determine changes in VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative with proper controls Suitable dust control vapor monitoring and
stormwater runoff measures would be implemented during construction ofthe PRB
Time to Achieve Remedial Action Objectives The time estimated for PRB emplacement
is four to six months The RAOs for groundwater would be achieved when monitoring results
indicated that the VOC concentrations have attenuated and groundwater standards have been
met It is estimated that attenuation of contaminant concentrations to ARARS will significantly
exceed the two-year time frame for short-term effectiveness This is because the application of a
PRB at the site would not significantly alter groundwater flow or TCE dissolution from within
the source area Therefore it would not increase the rate at which concentrations of residual
DNAPL or dissolved constituents of DNAPL (TCE) were removed from the source area It
would however limit the size ofthe region of VOC-contaminated groundwater
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of groundwater flowing through the permeable sections ofthe PRB
would remove the dissolved TCE as is flows under natural gradient conditions from the source
area
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNGFS9^X)10030929WPO 4-16 HSI G G O T T S O S jflC
MITEC 104e 02394
Reduction in Toxicity Mobility or Volume Treatment ofthe groundwater would reduce
its toxicity Contaminants adsorbed to carbon (if used as the treatment media in the gate sections
ofthe PRB) would be excavated on a periodic basis and ultimately be destroyed during the
process of regenerating the carbon
Amount of Material Contained or Treated The volumetric flux of contaminated
groundwater through the PRB is estimated to be approximately two million gallons per year for
the 10000 (igL source containment option and approximately four million gallons per year for
containment of all dissolved TCE concentrations greater than 1000 ugL
433 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Treatment of groundwater intersecting the PRB would control any risks
caused by expansion ofthe region of contaminated groundwater to the southeast Residual risk
to human health would be controlled through institutional controls
Adequacy and Reliability of Controls Performance of PRBs in reducing concentrations
of chlorinated organics such as TCE using zero-valent iron has been mixed Most ofthe PRB
performance demonstrations indicate that a concentration reduction of 60 to 90 percent can be
expected Some applications however have been much less successful at reducing VOC
concentrations Although little experience is available for PRBs using activated carbon the
removal efficiency should be expected to be greater and more reliable than zero-valent iron but
far more costly Groundwater monitoring would ensure that the contamination was being
adequately contained by the PRB and would be necessary on a long-term basis
Permanence of Remedy Installation of a PRB would be considered a permanent remedy
although periodic maintenance and replacement of reactive material in the gate would be
required for both carbon and iron-based systems
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9^X)l0030929wro 4-17 HSI GGOTfSnS IDC
MITEC 104e 02395
434 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to reduce VOC
concentrations in the remaining groundwater to below Groundwater Enforcement Standards
Natural gradient flushing would also eventually reduce the areas of highest groundwater
contamination to below Groundwater Enforcement Standards
Surface Water Quality Standards VOC concentrations in groundwater discharging to the
unnamed brook would be reduced significantly Thus operation ofthe PRB would result in
achievement of Water Quality Criteria for the protection of human health and aquatic organisms
(VTDEC 2000)
435 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This downgradient containment alternative would offer protection to both human health
and the environment if VOC concentrations in groundwater discharging to the unnamed brook
were to increase or if the region of contaminated groundwater were to expand in size This
alternative assumes institutional controls will be in place to continue sump venting in the
basement at Lot 3-30 on South Browneil Road restrict installation of new basements below the
water table within the region of VOC-contaminated groundwater and prevent potable use of
groundwater within the contaminated region Protection relative to the risks posed by expansion
ofthe region of contaminated groundwater to the unnamed brook would be achieved at the end
ofthe construction period of four to six months The residual risks posed by contaminated
material remaining within the groundwater would not be significant because all potential
exposure routes would be addressed
FOR ALLING INDUSTRIAL PARK MWP JX3CSN753V2000AIXINOFS90Crl0O30929wPD 4-18 HSI GCOTtSHS IRC
MITEC 104e 02396
436 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
bull Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction Removal and handling of contaminated soils
presents potential risks to construction workers during construction which could
be minimized through health and safety controls
bull Reliability of the Technology Although many full-scale applications of this
approach have been conducted they have been relatively recent Long-term
reliability and effectiveness of PRBs has not been established
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the PRB
was inadequate to prevent expansion ofthe region of VOC-contaminated
groundwater implementation of additional resources would not be hampered by
this alternative
Administrative Feasibility Installing and maintaining the PRB will require access to
properties overlying the region of VOC-contaminated groundwater Additionally property
owner cooperation would be needed to operate maintain and monitor wells located upstream
and downstream ofthe gate sections ofthe PRB system Restrictions would also be needed to
implement institutional controls to continue sump venting in the basement at Lot 3-30 on South
Browneil Road restrict the construction of basements below the water table within the region of
VOC-contaminated groundwater and prevent potable use of groundwater within the region of
VOC contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UO(XAAUJNOFS9-O0 10030929 WPO 4-19 HSI GGOTrSMS IDC
MITEC 104e 02397
Availability of Services and Materials The materials equipment and personnel required
to design install and maintain the PRB are readily available
437 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 3 The
capital costs would be $572000 for the source control application and $1022000 for the
containment option OampM costs include groundwater monitoring and periodic replacement of
the permeable barrier These average $64000 per year for the source control application and
$112000 per year for the containment option The present worth analysis calculated at a 7
discount rate over a 30-year duration yields a total of $1277356 for the source control option
and $2248691 for the containment option
4 4 A L T E R N A T I V E 4 M O N I T O R I N G I N S T I T U T I O N A L C O N T R O L S AND
N A T U R A L A T T E N U A T I O N
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water
The chief mechanisms contributing to reduction of contaminant concentrations in
groundwater by natural attenuation include biotransformation dilution dispersion and discharge
through advective flow and volatilization (EPA 1998) Volatilization is not likely a major
mechanism at the Study Area since contaminated groundwater is located at depth below the
FOR ALLING INDUSTRIAL PARK
MWP_DOCSW7S3U000WXINoFS9-001003O929wro 4-20 HSI GGOTfaDS IDC
MITEC 104e 02398
water table A natural attenuation evaluation will be conducted to better identify the mechanisms
contributing to concentration reduction through natural attenuation Monitoring to be completed
for this evaluation is included in Section 62 EPAs Technical Protocol for Evaluating Natural
Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) was used as the basis for the
design ofthe natural attenuation evaluation
441 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community A HASP would be prepared for the remedial
activities In conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Groundwater monitoring wells would be sampled to determine changes in
VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative
Time to Achieve Remedial Action Objectives The RAOs for groundwater would be
achieved when monitoring results indicated that the region of contaminated groundwater had
naturally attenuated and groundwater standards had been met It is estimated that natural
attenuation of contaminants to ARARS will exceed the two-year time frame for short-term
effectiveness
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0ALUNOFS9^X)M0030929wro 4-21 HSI GGOTfaflS jflC
MITEC 104e 02399
Treatment This alternative involves only natural in-situ processes No remediation
wastes would be generated
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area
Amount of Material Contained or Treated Natural attenuation may serve to contain the
region of VOC-contaminated groundwater at the Study Area Treatment may be accomplished
through biotransformation ofthe contaminants to environmentally acceptable compounds
443 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation of VOC-contaminated groundwater at the Study Area
would eventually achieve the ARARs Residual risk to human health would be controlled
through institutional controls Implementing institutional controls to maintain the sump venting
at Lot 3-30 on South Browneil Road restrict the construction of basements below the water table
within the region of VOC-contaminated groundwater and to control the use of groundwater
within the region of VOC-contaminated groundwater for potable purposes would provide
protection against the potential for exposure
Adequacy and Reliability of Controls Monitoring for VOC concentration reductions in
groundwater and institutional controls would be the main controls of this alternative Sump
venting at Lot 3-30 on South Browneil Road would prevent indoor air impacts at this location
and restrictions on construction of basements below the water table would prevent future indoor
air impacts Control ofthe use of groundwater within the region of VOC-contaminated
groundwater for potable purposes would minimize potential use of groundwater with VOCs
above federal and state drinking water standards Groundwater monitoring would ensure that
attenuation of VOC concentrations was proceeding and provide for periodic assessment ofthe
region of VOC-contaminated groundwater in the Study Area
FOR ALLING INDUSTRIAL PARK bull MWPJXXSN7532000AUINOFS9-00I0O30929WPD 4 - 2 2 HSI GGOTPaMS IRC
MITEC 104e 02400
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time
444 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
445 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
446 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK _
M W P _ D O C S N 7 5 3 U O O O A L U N O F S 9 - O O U 0 0 3 0 9 2 9 W P O 4-23 HSI GGOT 13118 IflC
MITEC 104e 02401
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
bull Ability to Construct the Alternative No major construction is included in this
alternative
bull Reliability ofthe Technology Ongoing monitoring and evaluation on would
ensure that natural attenuation was controlling and remediating the contaminated
groundwater
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation was not restricting the size ofthe region of VOC-contaminated
groundwater implementation of additional remedial actions would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
sample and maintain monitoring wells Restrictions would also be needed to implement
institutional controls to continue sump venting in the basement at Lot 3-30 on South Browneil
Road restrict construction of basements below the water table in VOC-contaminated
groundwater and prevent potable use of groundwater within the region of VOC-contaminated
groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor natural attenuation are also available
447 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 4 The
capital costs would be $55000 and include the initial natural attenuation evaluation and the
implementation of institutional controls OampM costs include groundwater monitoring These are
$9000 per year The present worth analysis yields a total of $163083 for this 30-year
alternative
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0AUJNOFS9^X)10030929wro 4-24 HSI GGOTraDS 1110
MTECl04e 02402
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water and
phytoremediation would be used to intercept TCE-contaminated groundwater
where it discharges to the unnamed brook
In this alternative all components of Alternative 4 would be implemented and
phytoremediation would be implemented in the area where TCE- contaminated groundwater
intersects the unnamed brook to intercept the contaminated groundwater and reduce the amount
of VOCs reaching the brook Phytoremediation of VOCs is still an experimental technology
Several field studies have used hybrid poplars (EPA 2000) to extract TCE- contaminated
groundwater It has been shown that TCE is removed along with groundwater by the trees and
metabolized as well as transpired from the leaves The rate of TCE contaminant removal from
the groundwater and its discharge to air by transpiration varies based on site specific conditions
and season Therefore contaminant or groundwater removal rates are impossible to predict at
this time without field studies Trees may be subject to destruction by natural disasters and pests
Their condition must be monitored and they may require replacement
F O R ALLING INDUSTRIAL PARK MWPJXXSN7532OOOWXINGFS9JraquoIOO30929WPO 4 - 2 5 H S I G G O T r S D S IOC
MITEC 104e 02403
In order for interception ofthe region of contaminated groundwater to be effective the
trees must be planted so that the root zone intercepts the contaminated groundwater Due to the
depth ofthe higher VOC concentrations in most areas ofthe site phytoremediation would be
ineffective in containing expansion ofthe region of contaminated groundwater An exception to
this is the area near the unnamed brook According to the SIR (HSI GeoTrans 2000) VOC-
contaminated groundwater appears to be discharging upward in groundwater into the unnamed
brook Trees planted along the border ofthe brook may help to intercept this contaminated
groundwater before it discharges into the brook
451 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 5 are as follows
Protection of Workers and the Community Normal landscaping hazards would be
associated with installation ofthe trees A HASP would be prepared for the remedial activities
In conformance with OSHA regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative Suitable dust control measures would be implemented during
planting of trees
Time to Achieve Remedial Action Objectives The time required for maximum
interception ofthe contaminated groundwater by the trees would depend on site specific
conditions such as root growth rate and tree survival rate The RAOs for groundwater would be
achieved when monitoring results indicated that VOC concentrations had attenuated and
groundwater standards had been met It is estimated that natural attenuation of contaminant
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
FOR ALLING INDUSTRIAL PARK MWP J X 3 C S N 7 5 3 2 0 0 0 A U J N O F S 9 ^ ) 0 1 0 0 3 0 9 2 9 W P D 4-26 HSI G G O T H S I I S IDC
MITEC 104e 02404
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment This alternative involves only in-situ treatment ofthe groundwater Plant
tissue would be analyzed for the presence of VOCs Plant materials can bio-accumulate metals
present in soil and groundwater If concentrations are high enough dead plant matter may have
to be disposed in an appropriate manner
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area Phytoremediation may
metabolize some ofthe VOCs
Amount of Material Contained or Treated Natural attenuation and phytoremediation
may serve to prevent expansion ofthe region of VOC-contaminated groundwater at the Study
Area Treatment is accomplished with biotransformation ofthe contaminants to environmentally
acceptable compounds
453 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation ofthe region of VOC-contaminated groundwater and
phytoremediation at the Study Area would eventually achieve the ARARs Implementing
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil Road
restrictions on construction of basements below the water table in regions of VOC-contaminated
groundwater and to control the use of groundwater for potable purposes within the region of
VOC-contaminated groundwater would provide protection against the potential for exposure
FOR ALLING INDUSTRIAL PARK MWP_IXXSW532000ALL1NOFS9^)0I0030929WTO 4-27 HSI GCOTraDS IflC
M l T E C l 0 4 e 0240S
Therefore despite the fact that an extended time period may be required to reduce VOC
concentrations to an acceptable level the residual risk associated with this alternative would be
minimal Trees planted near the unnamed brook may serve to intercept contaminated
groundwater before it discharges to this receptor
Adequacy and Reliability of Controls Groundwater monitoring for natural attenuation
institutional controls and interception of contaminated groundwater before it reaches the
unnamed brook would be the main controls of this alternative Sump venting at Lot 3-30 on
South Browneil Road would prevent indoor air impacts at this location and restriction on the
construction of new basements below the water table within the region of VOC-contaminated
groundwater would prevent future indoor air impacts at other locations Control ofthe use of
groundwater for potable purposes within the region of VOC-contaminated groundwater would
minimize potential use of groundwater with VOCs above federal and state drinking water
standards Groundwater monitoring would ensure that natural attenuation of contaminants was
proceeding and provide for periodic assessment ofthe region of VOC-contaminated groundwater
in the Study Area Groundwater and surface water monitoring would also be conducted to
monitor success ofthe phytoremediation in intercepting contaminated groundwater before it
reaches the unnamed brook
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time Trees must be monitored and will be replaced in
the event of destruction by severe weather pests or other reasons
454 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUINOFS9-00I0030929WPD 4-28 HSI GGOTraflS IllC
MITEC 104e 02406
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
Phytoremediation at the edge ofthe unnamed brook would further reduce the VOC
concentrations in groundwater discharging to the brook
455 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
456 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
Ability to Construct the Alternative Installation of this alternative requires
landscaping skills which are readily available
bull Reliability ofthe Technology Ongoing monitoring and evaluation would ensure
that natural attenuation was controlling and remediating the contaminated
groundwater Ongoing monitoring ofthe condition ofthe trees would also be
required to ensure they are continuing to grow and do not need replacement
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^)OM0030929WPD 4-29 HSI GGOTfaDS jflC
MITEC 104e 02407
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation and phytoremediation were not restricting the size ofthe region of
VOC-contaminated groundwater implementation of additional resources would
not be hampered by this alternative
Administrative Feasibility Planting trees and if necessary installing and monitoring
additional wells might require access to private property Additionally property owner
cooperation would be needed to sample and maintain monitoring wells Restrictions would also
be needed to implement institutional controls to continue sump venting in the basement at Lot 3shy
30 on South Browneil Road restrict construction of new basements below the water table in
regions of VOC-contaminated groundwater and prevent potable use of groundwater within the
region of VOC-contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to plant the trees and monitor natural attenuation are also available
457 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 5 The
capital costs would be $80000 and include the initial natural attenuation evaluation the
implementation of institutional controls and installation of a phytoremedial barrier of poplars
OampM costs include groundwater monitoring and maintenance ofthe phytoremedial barrier
These are $11000 per year The present worth analysis yields a total of $209397 for this 30shy
year alternative
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000ALLINOFS9^)0I0030929WPD 4-30 HSI GGOTfaDS IPC
MITEC 104e 02408
r TI Table 41 Cost estimates for remedial alternatives i deg 5 70
8 P
QUANTITY UNITS UNIT C O S T CAPITA L C O S T ANNUAL
OampM C O S T
5 n Alternative I No Action 8 O a Q
na na $0 $0 $0 a sect
Total $0 $0
Alternative 2 Monitoring Institutional Controls and Hydraulic Containment
1) Implement Institutional Controls 32 properties $10000 $32000
2) Groundwater Monitoring $9000
3) Pumping System
Option 1 Source Containment
Extraction wellspiping $50000 $15000
Electrical distributioncontrol $25000 $8000
Construction oversight $25000
Groundwater treatment system $75000 $45000
Total Option 1 $207000 $77000
Option 2 region of contaminated
groundwater Containment
Extraction wellspiping $175000 $35000
w Electrical distributioncontrol $50000 $20000
O
o H mO Construction oversight $125000
o n gt Groundwater treatment system $350000 $75000
o z 0) Tolal Option 2 $732000 $139000
i deg QUANTITY UNITS UNI T C O S T
5 so
Alternative 3 Monitoring Institutional Controls and Permeable Barrier
m t - 1) Implement Institutional Controls 32 properties $10000
9 O 2) Groundwater Monitoring
| o 3) Permeable Harrier
Option I Source Containment
Barrier installation 1200 feel $450
Total Option 1
Option 2 region of contaminated
groundwater Containment
Barrier Installation 2200 feet $450
w Total Option 2 NJ
Alternative 4 Monitoring Institutional Controls and Natural Gradient Flushing
1) Implement Institutional Controls 32 properties $10000
2) Groundwater Monitoring
3) Natural Attenuation Evaluation
Total
Alternative 5 Monitoring Institutional Controls Natural Gradient Flushing and Phytoremediation
1) Implement Institutional Controls 32 properties $10000 X (A 2) Groundwater Monitoring
reg 3
o m O H
3) Natural Attenuation Evaluation
4) Phytoremediation
gt z Total (A
Notes na = not applicable
CAPITAL C O S T
$32000
$540000
$572000
$990000
$1022000
$32000
$23000
$55000
$32000
$23000
$25000
$80000
ANNUAL
OampM C O S T
$9000
$55000
$64000 1
$103000
$112000
$9000
$9000
$9000
$2000
$11000
MODEL CALCULATED GROUNDWATER CONTOUR IN FEET ABOVE MEAN SEA LEVEL
APPROXIMATE PROPERTY BOUNDARY
M6-2 raquo EXISTING MONITORING WELL
CP-6 bull EXISTING SOIL BORING
M 8 - 2 raquo MONITORING WELL (RESAMPLED)
bull SMALL DIAMETER BORING - BELOW CLAY
bull BEDROCK MONITORING WELL
A S I - 2 I H S I GEOTRANS WELL CLUSTER LOCATION
U-TRIB-8a SURFACE WATER SAMPLING LOCATION R S - U
a PASSIVE SAMPLER LOCATION
T2-2 PROFILE SAMPLE LOCA1ION (JOHNSON COMPANY 1999)
WELL DESTROYED
TEF Concentrat ions ( u g A l
1000 - 10000
iry IOOOO - 20000
bull 20000 + NOTES AREA WHERE TCE CONCENTRATION IS
M l LOCATIONS APPROXIMATE INTERPOLATED THERE IS NO TCE
BASE PUN DEVELOPED FROM DATA FROM THESE AREAS
1 TOWN OF WUUSION PARCEL BOUNOART MAP (SHIPPED 121597) PROVIDED ST (VS (BURUNCTON VT) IN DXF FORMAT
2 PLAN DEVELOPED BT HEINDEL AND NOTES (BURUNCTON VT) FOR THE BATES PROPER1Y 1NVESIBAT10N AND PROVIDED TO THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION HASTE MANAGEMENT DIVISION 1997
3 ORTHOPHOTO SHEET 100216 VERMONT STATE MAPPING PROJECT 1988
4 TORN OF WIUJSTON ASSESSORS MAP 1997
5 VARIOUS SITE PUVQ CN RLE WITH THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION WASTE HMUGElENr OOVBON
6 DM FROM JOHNSON DD REPORT UNTIED GROUNDWXIER IHVESI1CAH0M ALLWC INDUSTRIAL PARK DATED 7 W FDR THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Modeled Site - Existing Conditions copy H
pound n Williston Vermont o CHECKED MS HSI
DRAFTED RMK GEOTRANS FU fa-Site-mod-ECdwg 4 - 1 A TITIA T t n HBVAIT
DATE 10600
5 COMPARATIVE EVALUATION OF ALTERNATIVES
The purpose of this section is to compare the remedial alternatives on the basis ofthe
evaluation criteria developed and discussed in Section 4 and provide a recommended alternative
These criteria include overall protection of human health and the environment short-term
effectiveness reduction of toxicity mobility or volume long-term effectiveness and
permanence compliance with ARARs implementability and cost
The comparative analysis is conducted to highlight significant differences between
identified alternatives All alternatives for the Study Area groundwater except the no-action
alternative include the following
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater and
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
The no-action alternative is not included in the comparison provided in the following
sections since it would not meet the RAOs All four ofthe remaining alternatives would meet
the RAOs stated in Section 32
51 SHORT-TERM EFFECTIVENESS
Protection of Workers and the Community Groundwater would be monitored under all
scenarios to look for any changes in VOC concentration which might result in increased risk
The containment options in Alternatives 2 3 and 5 would be more protective ofthe community
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320MAUINOFSWWI0030929WPD 5 - 1 HSI GSOTrSflS IflC
MITEC 104e 02415
if the region of VOC-contaminated groundwater were shown to be expanding and presenting
increased risk However in the event that the region of VOC-contaminated groundwater is not
expanding Alternative 4 would be equally protective Under all options a HASP would be
prepared and in conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Alternatives 2 3 and 5 would involve normal construction hazards during
installation of pumping wells piping trenches treatment enclosures permeable reactive barrier
trenches or planting of trees In addition under Alternative 5 release of VOCs to air through
transpiration may need to be measured to prevent creation of a new exposure pathway and health
risk through air
Environmental Impacts Minor additional impacts may occur during installation of
Alternatives 2 3 and 5 due to dust and sediment production Groundwater would need to be
treated to regulatory discharge limits before discharge under Alternative 2 and treatment may be
temporarily hampered in the event of treatment system mechanical failure Because ofthe
experimental nature of phytoremediation greater uncertainty exists that the trees will be effective
in acting as a barrier to expansion ofthe region of contaminated groundwater to the unnamed
brook under Alternative 5 If it is shown that expansion ofthe region of contaminated
groundwater toward the unnamed brook poses a future health risk additional measures may
become necessary to contain the contaminated groundwater
Time to Achieve Remedial Action Objectives None ofthe alternatives has an appreciably
shorter time frame than the others in reducing groundwater concentrations to VT Groundwater
Enforcement Standards and VT Water Quality Criteria This is because while Alternatives 2 3
and 5 rely on engineered remedies to contain the region of contaminated groundwater residual
TCE DNAPL and geologic heterogenieties will cause the contaminant source to persist for an
extended time As discussed in Section 34 active DNAPL removal alternatives were removed
during the preliminary screening DNAPL has never been directly observed at the Study Area
and is assumed to be present based on dissolved concentrations of TCE DNAPL distribution is
FOR ALLING INDUSTRIAL PARK MWP_DOCSW753200OALLINOFS9-00M0O30929wPD 5-2 HSI GGOTr3nS IflC
MITEC 104e 02416
expected to occur heterogeneously at residual saturation and it is infeasible to locate the DNAPL
to treat it directly Because of this each ofthe remedies is expected to exceed the two-year time
frame for short term effectiveness
52 R E D U C T I O N O F T O X I C I T Y M O B I L I T Y O R V O L U M E T H R O U G H
T R E A T M E N T
Treatment All ofthe proposed alternatives would treat the residual DNAPL source of
contamination through dissolution and natural gradient flushing While Alternatives 2 3 and 5
are intended primarily for containment and not groundwater restoration these alternatives would
actively treat some concentrations in groundwater
Reduction in Toxicity Mobility or Volume The containment Alternatives 2 3 and 5
may result in decreased mobility ofthe region of contaminated groundwater However
groundwater monitoring may show that the region of contaminated groundwater is not
expanding under existing conditions If this were the case containment would not result in any
additional decrease in size ofthe region of VOC-contaminated groundwater
Since Alternatives 2 3 and 5 treat concentrations in groundwater without treating the
residual DNAPL source and the amount of contaminants that can be removed from groundwater
by these methods would likely equal the amount added by continued dissolution ofthe DNAPL
sources alternatives 2 3 and 5 would not result in a greater reduction in the total volume of
contaminant than Alternative 4
Amount of Material Contained or Treated As described above the amount of material
contained under Alternatives 2 3 and 5 would not be any greater than under Alternative 4 unless
the size ofthe region of VOC-contaminated groundwater is not presently contained by natural
attenuation If natural attenuation is currently controlling the size ofthe region of VOC-
contaminated groundwater then the amount of contaminants being removed by natural processes
equals the amount added by dissolution of residual DNAPL In this case intercepting and
removing contaminants from the groundwater using one ofthe containment alternatives will not
result in a significant increase in the amount of contaminant treated
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000ALUNOFS9-OOUM30929WPD 5-3 HSI GGOTrdHS jflC
MITEC 104e 02417
53 LONG-TERM EFFECTIVENESS
Residual Risk Implementing institutional controls to maintain the sump venting at Lot 3shy
30 on South Browneil Road to restrict construction of buildings with basements below the water
table within the region of VOC-contaminated groundwater and to control the use of groundwater
for potable purposes within the region of VOC-contaminated groundwater would provide
protection against the potential for exposure to existing concentrations in groundwater
Therefore despite the fact that some ofthe remedial alternatives may be required to operate for
an extended time the residual risk associated with any ofthe alternatives would be minimal
Adequacy and Reliability of Controls Alternative 5 has the least reliable controls
because ofthe difficulty in predicting the effectiveness of phytoremediation The second least
reliable alternative would be Alternative 2 because of its reliance on mechanical equipment to
maintain containment and to meet discharge standards
Permanence of Remedy All ofthe proposed alternatives would rely on permanent
destruction of contaminants through natural attenuation over time If one ofthe containment
technologies are required maintenance and periodic replacement would be necessary to ensure
containment was maintained until expansion ofthe region of VOC-contaminated groundwater
was no longer a threat This maintenance would be straight-forward and easy to continue for any
of the containment alternatives
54 COMPLIANCE WITH ARARs
All ofthe alternatives would eventually reduce contaminant concentrations within the
current region of contaminated groundwater to below VT Groundwater Enforcement Standards
and VT Water Quality Criteria
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Each ofthe alternatives would rely on groundwater monitoring and institutional controls
on venting basement sumps at Lot 3-30 on South Browneil Road restrictions on the construction
of new basements below the water table within the region of VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWPJX3CSN7S3UOOOAUJNGFS9-OOUM30929wro 5-4 HSI GOTr3nS IflC
MITEC 104e 02418
and potable use of groundwater from within the region of VOC-contaminated groundwater to
maintain conditions protective of human health and the environment If monitoring shows that
natural attenuation is not restricting the size ofthe region of VOC-contaminated groundwater
then one ofthe containment alternatives would be more protective than Alternative 4
56 IMPLEMENTABILITY
The most easily implemented alternativewould be Alternative 4 as it would not require
any installation but only groundwater monitoring to gauge the progress of natural attenuation
Alternative 5 requires all the components of Alternative 4 and adds trees along the unnamed
brook Alternatives 2 and 3 are the most difficult to implement as they require disruptive and
invasive installation techniques However the necessary equipment materials workers and
specialists required to implement all the alternatives are available
57 COSTS
The present worth costs range form a low of $163083 for Alternative 4 to a high of
$2287474 for the containment option of Alternative 3 These present worth costs were based on
a 30-year service period and an annual discount rate of seven percent
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALLINOFS9-OOM0030929WPD 5-5 HSI GGOTfaDS IflC
MITEC 104e 02419
6 PREFERRED REMEDY
61 PREFERRED REMEDY
Alternatives 2 34 and 5 are all protective of human health and the environment and rely
on the following technologies
bull groundwater monitoring to evaluate spatial and temporal trends in VOC
concentration
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil
Road
restrictions on the construction of new buildings within the region of VOC-
contaminated groundwater to prevent unacceptable concentrations of volatile
compounds in indoor air and
institutional controls to restrict the use of groundwater for potable purposes within
the region of VOC-contaminated groundwater
All ofthe alternatives rely on dissolution and natural gradient flushing to treat the
residual DNAPL source of groundwater contamination Therefore none ofthe alternatives has
an appreciably shorter time frame than the others in reducing groundwater concentrations to VT
Groundwater Enforcement Standards and VT Water Quality Criteria
Alternative 4 includes remediation by natural attenuation There is no active containment
technology associated with Alternative 4 As such it is simpler less costly and easier to
implement than Alternatives 2 3 and 5 which include some form of active containment ofthe
region of VOC-contaminated groundwater Containment could become necessary under
Alternative 4 if future groundwater quality monitoring indicates the region of VOC-contaminated
groundwater is impacting a sensitive receptor or is expanding in size and not contained by natural
attenuation The SIR (HSI GeoTrans 2000) risk assessment (Menzie Cura 2000a and 2000b)
showed that under current conditions groundwater was not impacting any receptors to a degree
FOR ALLING INDUSTRIAL PARK MWPJXXrSN7532000ALUNcFS9-OOU0030929WO 6 - 1 HSI GSOTraflS jflC
MITEC 104e 02420
that would represent a human health risk or risk to the environment Therefore containment is
not necessary to protect any sensitive receptors currently being impacted by the region of
contaminated groundwater Continued groundwater monitoring is required to demonstrate
whether the region of VOC-contaminated groundwater is stable in size or expanding
Alternative 4 has been selected as the preferred remedy On-going monitoring ofthe
effectiveness of natural attenuation in containing and remediating the region of VOC-
contaminated groundwater is part ofthe remedy Further details on this proposed monitoring are
provided in Section 62 If monitoring shows that size ofthe VOC-contaminated region is not
contained by natural attenuation then one ofthe other technologies could be used to supplement
Alternative 4 based on the nature ofthe expansion ofthe region of contaminated groundwater
If monitoring data indicates that VOC concentrations in the groundwater discharging to the
unnamed brook have increased and pose an unacceptable risk to human health and the
environment then phytoremediation could be considered in this location Phytoremediation
would be less costly than installation of a permeable reactive barrier or active groundwater
extraction system Phytoremediation would be ineffective in containing expansion ofthe region
of contaminated groundwater in the rest ofthe Study Area however because contaminated
groundwater is further below ground surface in these regions and phytoremediation is limited by
the depth ofthe roots ofthe selected plant If monitoring data indicates that the southwestern
portion ofthe region of VOC-contaminated groundwater is expanding then Alternative 4 could
be supplemented with extraction wells or a PRB for hydraulic containment
62 MONITORING PROGRAM
In its guidance document Use of Monitored Natural Attenuation at Superfund RCRA
Corrective Action and Underground Storage Tank Sites (EPA 1999) EPA states that long-term
performance monitoring will be a fundamental component of any remedy which relies on
monitored natural attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000 A1XINOFS9-00 I0030929 WPO 6-2 HSI GSOTrSDS IMC
MITEC 104e 02421
The SIR (HSI GeoTrans 2000) concluded that there were not sufficient temporal data to
determine whether the region of VOC-contaminated groundwater was stable in size or
expanding Continued monitoring for the compounds of concern will be necessary to confirm
that the region of VOC-contaminated groundwater is not expanding Table 6-1 identifies
locations which are proposed to be monitored annually to evaluate spatial and temporal trends in
VOC concentration These locations are shown in Figure 6-1
There are several mechanisms by which natural attenuation occurs These include
dilution of contaminant concentrations sorption ofthe contaminant onto the soil matrix and
biodegradation ofthe contaminant to a less toxic form Further study is necessary to determine
the contribution of each of these mechanisms to overall attenuation ofthe area of VOC
contamination
Evidence of biodegradation can be obtained by collecting three types of data of increasing
complexity (National Research Council 1993)
bull documentation of contaminant loss or transformation in the field
bull the presence of electron donors and acceptors andor alteration of groundwater
chemistry consistent with intrinsic biodegradation processes and
microcosm studies which provide direct microbiological evidence that indigenous
bacteria are capable of mediating the contaminant transformations observed
Microcosm studies are typically not employed unless the contaminant is unique or the
transformation which is being observed is not well documented in the literature For the
transformations anticipated in the Study Area numerous laboratory and field studies have
established that naturally-occurring bacteria are capable of mediating the contaminant
transformations of contaminants of concern For that reason microcosm studies will not be
performed as part of this study
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^)OM0030929 WPO 6-3 HSI GSOTrSHS jflC
MITEC 104e 02422
Of particular concern to the determination of biodegradation is the delineation of aerobic
and anaerobic zones within the contaminant area because these zones dictate the types of
biological degradation that would be expected to occur Oxygen is the primary electron acceptor
during aerobic oxidation Anaerobic processes including denitrification iron-reduction sulfate-
reduction and methanogenesis occur in the absence of oxygen and use nitrate iron (III) sulfate
and carbon dioxide respectively as primary electron acceptors Reductive dehalogenation of
TCE has been observed under iron-reducing sulfate-reducing and methanogenic conditions
although very low redox (ie methanogenic) conditions may be necessary for production of
ethene and ethane
Further sampling and analysis of selected parameters in groundwater will be conducted to
assess the potential for biodegradation in accordance with EPAs Technical Protocol for
Evaluating Natural Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) The
twelve sampling locations shown in Table 6-1 used to monitor ofthe area of VOC contamination
will also be sampled for parameters used to evaluate biodegradation The parameters include
compounds of concern and compounds which are degradation products ofthe compounds of
concern shown in Table 6-2 Table 6-3 lists parameters chosen to evaluate the presence of
electron donors and a groundwater chemical environment conducive to biologic reductive
dechlorination These parameters will be sampled once unless evaluation ofthe data indicates
that further sampling would be beneficial to calculate a rate of attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000ALUNCFS9JraquoM0030929 WPD 6-4 HSI GSOTfaHS IDC
MITEC 104e 02423
Table 6-1 Sampling locations
LOCATION
ID
ASI-32D2
RB-1
ASI-26D2
ASI-I6D2
ASI-13D2
ASI-23D2
ASI-18D2
ASI-12D2
ASI-01D2
ASI-09D2
U-TRIB-5
SW-I
Notes BGS =
SCREENED
INTERVAL
DEPTH BGS
35-40
35-40
35-40
30-35
31-36
25-30
32-37
35-40
31-36
31-36
surface
surface
Below Ground Surface
RATIONALE
Upgradient of region of highest VOC concentrations
Closest to lot 19-11 former lagoon and septic leach field source areas
Within area of highest concentrations
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient ofthe region of VOC concentrations in the southwest direction
Downgradient of source area within region of VOC concentrations in southeast direction
Downgradient of source area within region of VOC concentrations in southeast direction
At downgradient edge of region of VOC concentrations in southeast direction
Stream upgradient of VOC discharge from groundwater
Stream at location of VOC discharge from groundwater
(
FOR ALLING INDUSTRIAL PARK MWP DOCSN7532000ALUNCFS9^X)VI0030929WPO 6-5 HSI GeoTrans inc
MITEC 104e 02424
Table 6-2 VOC analytes
PARAMETER
TCE
PCE
11-DCE
cis 12-DCE
trans 12-DCE
Vinyl Chloride
Benzene
Toluene
Ethylbenzene
Xylenes
ANALYTICAL METHOD
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
8260A
8260A
8260A
8260A
RATIONALE |
Contaminant of Concern
Contaminant of Concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
Notes SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical
Methods SW-846 US EPA 3ri edition 1986
TCE = Trichloroethene
PCE = Tetrachloroethene
11-DCE = 11-Dichloroethene
cis 12-DCE = cis 12-Dichloroethene
trans 12-DCE = trans 1 2-Dichloroethene
FOR ALLING INDUSTRIAL PARK MAWP DOCSN75320laquoMLUNOFS9^XM0030929WPO 6-6 HSI GeoTrans inc
MITEC 104e 02425
Table 6-3 Parameters to evaluate biodegradation
PARAMETER ANALYTICAL METHOD RATIONALE
Field Parameters
Alkalinity as CaCO Hach Alkalinity Test Kit Model ALP Positive correlation between microbial activity and
MG-L alkalinity Measures the buffering capability of
groundwater
Total Ferrous Iron Hach Method 8146 May indicate anerobic degradation
Dissolved Hydrogen Reducing Gas Detector Predicts possibility for reductive dechlorination
Dissolved Oxygen Direct Meter Reading Indicates probability of aerobic vs aerobic
degradation
PH Direct Meter Reading Aerobic and anaerobic biological processes are pH
sensitive
Redox potential (Eh) A2580B An indicator ofthe relative tendency of a solution
to accept or transfer electrons
Specific Conductivity Direct Meter Reading Used to determine when purging of a well for
sampling is complete
Temperature Direct Meter Reading Affects the metabolic activity of bacteria and the
solubility of dissolved gasses
Laboratory Analyses
Dissolved Organic Carbon SW 9060 Carbon and energy source which can drive
dechlorination
Nitrate-N IC Method E300 At higher concentrations may compete with
reductive pathway
Total Manganese EPA 2007 or 2009 To determine if anaerobic biological activity is
solubilizing Mn for the aquifer matrix
Chloride SW 9250 Can be used as a conservative tracer to estimate
biodegredation rates
Sulfate IC Method E300 May be used as an electron acceptor for
biodegradation after dissolved oxygen and nitrate
are depleted
Sulfide IC Method E300 Indicates if reductive pathway is possible
Ethane SW 3810 Modified Daughter product of Ethene
Ethene SW 3810 Modified Daughter product of Vinyl Chloride
Methane SW 3810 Modified Ultimate reductive daughter product
Notes Rationales taken from USEPA 1998
Hach refers to Hach Company Catalogue
A refers to Standard Methods for the Examination of Water and (fostewater 18 edition 1992
E refers to Methods for Chemical Analysis of Water and Wastes US EPA 1983
SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical Methods SW-846 US EPA 31 edition
1986
FOR ALLING INDUSTRIAL PARK | C I nr A^Twmrmr bullbullltlaquo MWP DOCSN7532000ALLINCFS9-0Ol0030929wro 6-7
MITEC 104e 02426
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REFERENCES
Brinkerd 1996 Site Investigation Ailing Industrial Park Williston Vermont April to
September 1996 October 1996
Fitts C R 1997 TWODAN documentation prepared by Dr Charles Fitts Scarborough Maine
Griffin 1995 Monitor Well Log (MW-4) and Analytical Data Bove-Fagan Ice Cream
Distribution Investigation Williston VT Griffin International Inc
HSI GeoTrans Inc 2000 Site Investigation Report June 15 2000
Johnson 1999 Limited Groundwater Investigation N753 July 6 1999
Menzie Cura 2000a Screening Level Risk Characterization April 2000
Menzie Cura 2000b Addendum to Screening Level Risk Characterization June 1 2000
NRC 1993 National Research Council Committee on Bioremediation In Situ Bioremediation
When Does it Work Washington DC National Academy Press 1993
TRC 1993 Site Inspection-Ailing Industrial Park Williston Vermont VTD982748477 Final
Report
US EPA 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies
Under CERCLA OSWER Directive 93553-01
U S EPA 1992 Estimating Potential for Occurrence of DNAPL at Superfund Sites OSWER
Number 93554-07FS 9p
FOR ALLING INDUSTRIAL PARK MWP_DOCSW75JV20(XKALUNOFS9-0(AI0030929WPD 7 - 1 HSI GeOTTSHS irtC
MITEC 104e 02428
US EPA 1993 Guidance for Evaluating the Technical Impractibility of Groundwater
Restoration EPA540-R-93-080
US EPA 1998 Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents
in Ground Water EPA600R-9812~8
US EPA 1999 Use of Monitored Natural Attenuation at Superfund RCRA Corrective Action
and Underground Storage Tank Sites EPA Directive 92004-17P
US EPA 2000 Introduction to Phytoremediation EPA600R-99107
VTDEC 1996 Site Investigation Guidance August 1996
VTDEC 1997 Chapter 12 Groundwater Protection Rule and Strategy October 1997
VTDEC 2000 Vermont Water Quality Standards March 2000
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(AAUJNGFS9^)OM0030929WPD 7-2 HSI GSOTfanS tC
MITEC I04e 02429
APPENDIX A
TWODAN INPUT FILES
FOR ALUNG INDUSTRIAL PARK MWP_DOCSVN7S3200(AALUNOFS9-0(AI0030929WPO HSi GfiOTfanS WC
MITEC 104e 02430
i - i i a a o U 0 t A X H i d t l Z 018J UaiUEAJJLKATia Htj v j pound
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MITEC 104e 02431
15
6 Lancaster County Road HSI Harvard Massachusetts
GEOTRANS 01451 A TETRA TECH COMPANY 97^772-7557 FAX 978-772-6183
R E C E i ^ D PNN753-001
CUTLER A8TANPIELD Campltf December 11997
Mr Michael Smith Vermont Department of Environmental Conservation Waste Management Division 103 South Main Street Waterbury VT 05671-0404
Subject Proposed Surface Water Sampling MITEC Site Williston VT
Dear Michael
This letter describes the proposed surface water sampling at the MITEC site that we discussed during our meeting of November 201997 Our intention is to complete this work as soon as possible to avoid the complications of colder weather and possible freezing ofthe stream My understanding is that you are prepared to review and approve this plan fairly quickly and also to assist us with obtaining property access and appropriate maps to locate these sampling sites We appreciate this help In future we anticipate that the constraints of weather will not require such an expedited field mobilization process and that we will all have more time to prepare
Purpose and Extent of Sampling
The purpose ofthe surface water sampling is to further assess impacts to the unnamed tributary and to make preliminary inferences regarding the extent ofthe TCE plume currently migrating to the southeast across the Ailing Industrial Park by measuring the effects of its discharge to the stream To this end sampling locations have been chosen to 1) provide better spatial resolution in the area east of Commerce Street toward its southern end (SW-1 SW-2 SW-3 and S W-5) 2) assess the quality of surface water contributed by other tributaries (SW-4 SW-6) and 3) make preliminary estimates ofthe downgradient extent of impacts (SW-7 and SW-8) Samples from previously established sampling locations UTrib-6 7 8 1014 and 18 will also be obtained A total of 14 samples will be collected The proposed sampling locations
L-W7jni20iiooonl
MITEC 104e 02432
Michael Smith 2 December 11997
are indicated on the attached maps which depict the site at two different scales The first is a site map taken from the Binkerd report and shows the previous sampling locations east of Commerce Street as well as proposed new locations SW-1 SW-2 and SW-3 The second map shows the site and the surrounding area including the more downstream locations
Methods
At each proposed location a number of water quality indicators will be measured including temperature pH redox potential dissolved oxygen and conductivity Samples for volatile organic compound (VOC) analysis will be obtained in triplicate using a stainless steel sampling container samples will be transferred immediately to 40 mL glass vials with teflon septa and preserved with hydrochloric acid Each sample will be submitted to a local analytical laboratory for a screening level analysis of VOCs Three selected samples will also be analyzed using EPA Method 8260 The appropriate level of documentation will be generated for these samples such that laboratory analytical results can be validated to EPA Region 1 level Tier II This will require the collection and analysis of a duplicate sample a trip blank a field blank and matrix spikematrix spike duplicate samples
Sincerely
f i t mdash Peter ZeebPhD Senior Hydrogeologist
cc Sandy Feldman Sheila Jones
PZmm
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HSI GEOTRANS
LEGEND O Honrtorog Veil
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Figure 11 Station location map O Surface Water
Qfor monitoring wells borings and surface water MITEC 104e
02434
HD BINKERD ENVIRONMENTAL
HSI bull bull
GEOTRANS if prsTAOC
6 Cancaster County Road
A TETRA TECH COMPANY
Harvard Massachusetts 01451 faL32 HMETER 3 4 r t
Sheila Jones Esq Cutler and Stanfield 700 Fourteenth Street NW Washington DC 200052010
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Harvard Massachusetts 01451 GEOTRANS
A T E T R A T E C H C O M P A N Y 978-772-7557 FAX 978-772-6183
PN N753-002
May 111999 RECEIVED
MAY t 3 1999 Mr Michael Smith
CUTLER ampSTANrlc-uAgency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Dear Mike
Based on the site walkover and well inventory ofthe existing monitoring well network completed on April 201999 HSI GeoTrans determined that several monitoring wells proposed for sampling and monitoring in the Work Plan are not accessible or are damaged or missing Outlined below are the actions we will undertake to resolve the outstanding issues with the monitoring well network
As ofthe date of this letter access to the Bates well network has not been obtained The Work Plan identified eleven off property well clusters installed by the Bates and two wells installed by the State on the Bates property to be included in the sampling and monitoring activities for the Site Investigation (BW-2 BW-5 BW-7 BW-8 BW-9 BW-11 BW-12 BWshy13 BW-17 BW-18 BW-19) Ten ofthe off property clusters were included in the sampling plan and all eleven were included in the site water level round The wells installed by the State on the Bates property were included in the both sampling and water level rounds Replacement of eight ofthe well clusters slated for groundwater sampling is recommended (BW-5 BW-8 BW-9 BWshy12 BW-13 BW-17 BW-18 BW-19) The remaining Bates wells do not require replacement in order to achieve the goals ofthe Site Investigation Note that two ofthe original well clusters in the Work Plan BW-17 and BW-18 have been destroyed and would require replacement even if access is granted by Bates In addition HSI GeoTrans well clusters had already been proposed adjacent to BW-2 BW-7 and BW-11 and will provide the required data at these locations
It is our understanding that the two monitoring wells installed by the State on the Bates property JB-1 and JB-2 are accessible to the State for sampling and water level monitoring and that the State will sample and monitor these wells to fulfill the goals ofthe Site Investigation IF this is not the case please let me know at your earliest convenience
M WP DOCS NT^VWMiSimbW wpd
MITEC 104e 02438
Mr Michael Smith 2 May 11 1999
Several ofthe remaining wells (BF-1 BF-3 NO-2 and OE-1) were observed to be damaged during the inspection We propose to repair the wells which have been damaged The repairs will involve installation of protective casing or road boxes re-development and reshysurveying of the new measuring points The other wells are missing and presumed destroyed (ARC-2 ARC-3 BF-2 BM-2 MB-1 PO-SOUTH and RB-1) We believe that only monitoring wells MB-1 and MB-1 A require replacement The remaining wells that could not be located during the site inspection do not require replacement in order to achieve the goals ofthe Site Investigation
Based on our telephone conference on May 10 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MWgt_DOCSN753l9Wlaquo310l600raquopd M l 1 XA ~r
02439
HSI GEOTRANS
Mr Michael Smith 3 May 11 1999
bcc Sheila Jones
snwp_DocjN7sni9wcmoi6i)iraquoplti TVflTEC 1046
02440
HSI GEOTRANS
X_l ^ T 6 Lancaster Countv Road
Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-11 i 5
PN N753-002
June 25 1999
Mr Michael Smith Agency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Work Plan Modifications Ailing Industrial Park Site Williston VT
Dear Mike
This letter documents changes to the work plan for the Ailing Industrial Park Site in accordance with a telephone conference between you myself and Peter Zeeb On the results of the Site Investigation to date as well as additional data collection by the DEC we agreed that several revisions to the work plan are warranted The revisions for the work plan include the location and method of installation for the bedrock monitoring wells and the sampling of shallow monitoring wells recently installed Outlined below are the revisions to the specific tasks that we will undertake
Re-location of Bedrock Monitoring Weil BR-1
The DECs Source Area investigative work in the original location of BR-1 identified high levels (100 mgL) of VOCs present at or near the silt clay interface DEC believes that drilling through the clay layer in this location creates an unacceptable risk ofthe migration of contaminants into the underlying units HSI GeoTrans will relocate the bedrock well BR-1 adjacent to ASI-16 as located on the attached site plan
Bedrock Well Installation Method
Geophysical work at the site has refined our estimation of the depth to bedrock Depth to bedrock was initially anticipated to be greater than 150 feet below ground surface We currently anticipate bedrock at 100 to 140 feet below ground surface The shallower depth to Bedrock will
M AWPDOCStfnSIMnWUJIIW mft
MITEC 104e 02441
Mr Michael Smith 2 June 25 1999
enable us to reduce the size ofthe pilot hole needed for the well installation At locations BR-1 and BR-2 drillers will advance and set 4 in casing several feet into the clay unit and chop and wash the annulus ofthe casing All cuttings and wash water will be contained for proper disposal The casing will be refilled with potable water and the hole will be advanced with a 3 in roller bit When telescoping becomes necessary to prevent caving 3 in casing will be installed The 3 in casing will be advanced to the bedrock surface and seated The coring of bedrock will follow the original work plan specifications
Shallow Monitoring Well Sampling
The field GC water quality data obtained during small diameter installation at the site has demonstrated that contaminant concentrations in the upper portion ofthe aquifer to be low (lt 10 MgL) or non-detect in most locations This has led to the revision of our sampling plan Select shallow wells will be sampled to confirm the field GC data If these data are confirmed the low level and none detect shallow wells will not be sampled The shallow wells to be used for confirmation sampling are listed below
ASI-01 ASI-02 ASI-03 ASI-05 ASI-08 ASI-10 ASM 2 ASI-08
Based on our telephone conference on June 24 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MXTECl04e 02442
HSI GEOTRANS
Mr Michael Smith 3 June 25 1999
bcc Sheila Jones
MITEC I04e
02443
HSI GEOTRANS
1 0 T 2 shyCylty
T-TCT 6 Lancaster County Road _ _ _ Harvard Massachusetts
GEOTRANS OH 5 1
A TETRA TECH COMPANY 978-772-7557 FAX 978-772-6183
PN 753-010
July 9 1999
Mr Michael Smith Agency of Natural Resources Vermont Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Bedrock Monitoring Well Installation Ailing Industrial Park Site Williston VT
Dear Michael
On July 8 we became aware that a drill casing was advanced through the sand clay and till strata at the Ailing Industrial Park (site) without being sealed at the sandclay interface Although for the reasons described below we do not believe any vertical migration of contaminates occurred this method of drilling is contrary to the work plan for the site Therefore we are notifying you of this incident
On June 4 shallow direct push monitoring wells were installed at location ASI-06 where a deeper bedrock monitoring well is planned Groundwater quality profiling data from this location is provided on the attached boring log TCE is present in groundwater here at concentrations as high as 2270 ugl at 31 - 36 ft below ground surface (bgs) decreasing to 262 ugL at 41 - 44 ft bgs A soil boring (D-2) was advanced at this location on June 22 Field screening data from soil samples obtained in this boring are also provided on the attached log As apparent from the log fine to medium sand occurs to a depth of approximately 15 ft at this location grading to silt at depth A clay layer is encountered at 40 ft bgs Glacial till is present from 57 to 100 ft bgs where the bedrock surface is located Prior to drilling through the clay and glacial till a direct push well screen was advanced through the clay and into the till to a depth of 58 bgs and no groundwater recharge to the well screen occurred at any of five sampling depths
MWP_DOCSN753 199M7M1600 wpd
MITEC 104e 02444
Mr Michael Smith 2 July 9 1999
Drilling of bedrock monitoring well BR-2 began on June 29 Four inch casing was advanced to a depth of 44 ft and sealed within the clay layer Three inch casing was then advanced through the till layer to the bedrock surface During seating ofthe casing in the bedrock the casing was damaged and was subsequently withdrawn from the borehole
On July 7 a different drill rig was used to continue drilling the same location In accordance with both the drillers proposal to HSI GeoTrans and the work plan for the site investigation the driller was to seat a casing in the clay establish a seal and drill through the clay and till with smaller casing prior to coring bedrock Instead the drilling contractor withdrew the previously installed four inch casing without grouting it changed the drive shoe on the casing to a spin shoe and advanced the four inch casing directly to the bedrock surface Upon arrival at the site to log the coring of bedrock on July 8 HSI GeoTrans ascertained that the borehole had not been sealed at the clay surface prior to drilling deeper as was specified HSI GeoTrans then instructed the drilling contractor to immediately remove the casing and to seal the borehole with grout in the process
It is our intention to have a new drilling contractor complete the installation of BR-2 at an adjacent location in a manner that limits the potential for introducing contaminated unconsolidated deposits groundwater to the bedrock as specified in the work plan for this site investigation Within one week of completing the installation of BR-2 groundwater quality data collected from BR-2 will be evaluated with respect to the potential for contaminant migration along the unsealed borehole that existed at this location for approximately 24 hours As the casing was advanced by spinning providing a relatively good seal between the casing wall and the formation we do not anticipate that vertical migration along the casing was significant
If you have any questions regarding this letter please contact me at (978) 772-7557
Sincerely yours
Peter Zeeb PhD Senior Hydrogeologist
PZcas
MWP OOCSVN7S3M999070ll600wpri
MITEC 104e 02445
HSI GEOTRANS
1 HSI | 9pound9TPpoundSpound SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
LOCATION Williston VT CASING TYPEDIAMETER None
DRILUNG METHOD Drive and Wash Direct Push SCREEN TYPESLOT None
SAMPLING METHOD ss shelbv GRAVEL PACK TYPE None
GROUND ELEVATION GROUT TYPEQUANTITY Bentonite Portland Slurry
TOP OF CASING DEPTH TO WATER
LOGGED BY NSB GROUND WATER ELEVATION
REMARKS This log compiles the results o the all methods used to comolete the borehole over its entire depth
gtshyci IT UJ t o UJ E t shygt z L oi lti LITHOLOGIC DESCRIPTION 3Q O bdquo a UJ lt a ca sect 1a UJ
o amp UJ _ a 1 Oi i ai o UJ a E 03 5 1 - X X X
cc -S
Moderate olive Brown - Olive Grey m-f SAND w trace fines wet poorty graded
bull bull bull
- 5 shy
J
bull bull
- 1 0 shyD2-SS01 21 13 NO 7 NO 13
A12 7
bull bull
Light olive Brown SILT w trace fine sand wet poorly - 1 5 shy graded
O2-SS02 4 7 11 8
A7
6 7
- 2 0 shy Dark greenish Grey SILT wet poorly graded
O2-SS03 2 0 41 1
WOR WOR l
D2-SS04 2 4 2 X - 2 5 shy4
D2 13 1159
3
1 D2-SS05 2 5 39 v
WOR AWOR WOR - 3 0 shyD2-SS06 4 921 WOR
XWOR WOR
02-SS07 8 2270 1
X1 2 3
Continued Next Page 1 OF 3 02446
HSI GEOTRANS SOIL BORING LOG BR-02 A T E T R A T E C H C O M P A N Y
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
9 gtshyOC
UJ - j a
UJ gt o ^ r-6 LITHOLOGIC DESCRIPTION
ui
CD U UJ S oc =
o o
uj _ Q pound iT O
o
Medium Grey dayey SILT wet poorly graded
D2-SS09 4 S
28 1572
3 6
D2-SS10 WOR 1 18 13
4 6
D2-SS11 3 3 20 NO Medium Grey CLAY wet poorly graded 262
4 5
BR2-SS01 1 2 20 ND Soft Olive Grey CLAY moist laminated coheisive 2 4
BR2-SS02 20 NO
- 5 0 -
BR2-SS03 20 NO - 5 5 -
Dense Light olive Grey sandy GRAVEL w few fines
BR2-SS04 16 19 24
ND
bull60
moist poorly graded
21
Very dense Light olive Grey gravelly SAND w little fines moist well graded angular
BR2-SS05 40 51
13 ND 6 5 shy
60 66
I-7 0 shySO BR2-SS06 11 ND 50 100
5000
MITEC 104e 02447
Continued Next Page PAGE 2 OF 3
HSI GEOTRANS A T E T R A T E C H C O M P A N Y SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
a UJ
Q
05
i i m u
gt ac ui gtO bdquo UJ 3 oc S
o o
0 CO UJ _ Q pound LL C5
LITH0L0GIC DESCRIPTION 9 LU O
BR2-SS07 81 1004
10 NO E 8 0 shy
BR2-SS08 30 59 68
16 ND w8 5 shy
BR2-SS09 1005 NO 9 0 shy
BR2-SS10 89 1944
ND E bull95shy
- 1 0 0 shyND
Limestone
MITEC 104e 02448
PAGE 3 OF 3
Mr Michael Smith 3 July 9 1999
bcc Sheila Jones bcc Jerry Amman
MWPJXXSN753M9MW70J160Owpd
MITEC 104e 02449
6 Lancaster Countv Road HSI Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6 I i 5
PN N753-014
Septembers 1999
Mr Michael Smith Agency of Natural Resource Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in die Site Investigation Ailing Industrial Park Williston IT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and die Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation ore outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste waler lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot IV-11 using small-diameter wells and afield GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
bull perform one day ofwellpoint permeability testing at selected monitoring wells
mwFDocwsiMwwwnoootd MITEC 104e 02450
Mr Michael Smith September 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
M l T ECl04e 02451
U laquo OOCTN791Mtm01IOOOraquofrl
HSI GEOTRANS
HSI GEOTRANS
6 Lancaster County Road Harvard Massachusetts
01451
A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6183
PNN753-014
Septembers 1999 amp y gt
Mr Michael Smith D oJ Agency of Natural Resource Km Jt Department of Environmental Conservation i j f i l Waste Management Division ft y^y( 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park ft Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and the Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation are outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
bull perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste water lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot 19-11 using small-diameter wells and a field GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
MITEC 104e perform one day ofwellpoint permeability testing at selected monitoring wells 02452
000060 MlWP_OOCSN73Iirmraquo01|rngtlaquo|gtl
Mr Michael Smith Septembers 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
MITEC 104e 02453
000061 Mwr_cocS4miinmogtmoltsri
HSI GEOTRANS
T T Q T 6 Lancaster County Road ^ Harvard Massachusetts
GEOTRANS laquolaquo A TETRA TECH-COMPANY 978-772-7557 FAX 978-772-6183
PNN753-014
October 151999
Mr Michael Smith vZ Agency of Natural Resource J Department of Environmental Conservation Waste Management Division I 103 South Main StreetWest Building j Waterbury VT 05671-0404
Re Ailing Industrial Park Source Area Investigation
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants Evaluation of field data has determined the extent ofthe dissolved phase contamination migrating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) HSI GeoTrans will begin a Source Area Investigation on October 181999 to determine the nature and areal extent ofthe suspected contaminant source The investigation will be undertaken to gather the data necessary to complete the Site Investigation Report and the Feasibility Study which was set forth by the Agreement Between Mitec Telecom INC and Vermont Concerning the Ailing Industrial Park (1999) The Source Investigation will focus on the property owned by Beatrice Ailing and former MITEC lease hold (Lot 19-11 Williston plat map) and the area ofthe Ailing Industrial Park which has exhibited elevated contaminant concentrations during Site Investigation activities We are submitting this letter to The Vermont Department of Conservation(VTDEC) as an addendum to the approved Site Investigation Work Plan The addendum Source Investigation Work Plan will outline the tasks and methodologies to be utilized during the investigative work
Jack Guswa and I met with you on September 101999 to present the plans to investigate the suspected source area in the Ailing Industrial Park You agreed with the additional work as presented with the addition of two upgradient wells to be located to the west ofthe suspected source area (Figurel-1 ASI-30 and ASI-31) The VTDEC also agreed during the meeting to arrange access to the property for the Source Area Investigation The VTDEC and HSI GeoTrans were subsequently granted access to the property on September 111999 In addition to the work presented at the meeting it is necessary to preform a 72 hour pump test to characterize the
000054 MwrDOCSW79JimMOUIIOOpd
MITEC 104e 02454
Mr Michael Smith 2 October 151999
hydrologic conditions at the site The additional Source Area Investigation activities to be undertaken are presented below
Site Reconnaissance Ground Penetrating Radar (GPR) Survey Monitoring Well and Soil Boring Installation Low Flow Groundwater Sampling Hydraulic Characterization
The additional field work attributed to the Source Area Investigation will follow the standard operating procedures presented in the approved Site Investigation Work Plan (HSI GeoTrans 1999) The locations ofthe proposed well cluster installations and GPR survey are presented on Figure 1-1 The well cluster locations presented in Figure 1-1 were finalized during the September meeting between HSI GeoTrans and the VTDEC The GPR survey and hydraulic characterization tasks are presented below The Source Area Investigation field work will be completed within two week after its initiation The task specific outlines are presented below
Site Reconnaissance
The monitoring wells to be included in the site reconnaissance are monitoring wells MI-1 MI-2 MI-6 and RB-2 The monitoring wells on Lot 19-11 will be surveyed to a common datum with the existing site wide survey data Well integrity testing consisting of depth to bottom water level and visual inspection ofthe wells will be preformed Groundwater samples will be collected from selected monitoring wells based on the integrity testing Samples will be collected by the Low Flow Protocol set forth in the Site Investigation Work Plan (HSI GeoTrans 1999)
GPR Survey
A GPR survey will be preformed to identify on-site leach field septic tank or cesspool location remnants of waste water lagoon and any other subsurface anomalies We propose to use a 5 foot by 5 foot orthogonal grid survey to detect any near surface anomalies which exist on Lot 19-11 Geophysics GPR International will be performing the survey and will be utilizing a GSSI SR10 ground penetrating radar system with a high resolution 500 MHz antenna and a deep-penetration 100 MHZ antenna Any GPR response which indicate buried metal objects will be investigated with a Fisher TW6 pipe locator to augment the radar data All data will be analyzed in the field by GPR personnel and presented to HSI GeoTrans field personnel to determine the optimal location for well cluster ASI-28 If several anomalies are detected the VTDEC and HSI GeoTrans will evaluate the anomalies and modify the work plan accordingly
Well Installation and Soil Boring Advancement MITEC 104e 02455
The well clustes will consist of a small diameter shallow monitoring well and a deeper conventional well screened across the zone of highest concentration Well cluster installation will be performed in accordance with the Site Investigation Work Plan (HSI GeoTrans 1999) yjth 0 0 5 5
MWP_DOCSK731IW9M OOSIIOOprl
HSI GEOTRANS
Mr Michael Smith 3 October 151999
the exception ofthe deep wells The site conditions observed during previous field work prohibit the use of standard commercially available screen slot sizes The deep wells will be advanced by a large diameter Geoprobereg rod and installed using an outer filter sock to prohibit the infiltration offine sediments in to the well The well cluster installations will be performed jointly by Checkpoint Environmental and Twin State Environmental HSI GeoTrans will be provide oversite ofthe contractors and analysis of groundwater samples using afield Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999) The rationale for the selected well cluster locations is presented below
Monitoring well clusters ASI-25 through ASI-27 are located down gradient ofthe suspected source area The well clusters will be installed to more adequately define the areal extent ofthe concentrated portion ofthe contaminant plume A single soil boring will be advanced at location ASI-26 The soil boring will be screened as it is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-28 will be located after the GPR survey has been completed shyThe cluster will help define the suspected source area and the vertical migration of contaminants in the area The location will be determined in thefield after review ofthe GPR survey is completed The location will be based on any anomalies observed in the GPR data A single soil boring will be advanced at location ASI-28 The soil will be screened with a Flame Ionization Detector as the soil boring is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-29 will be located upgradient ofthe suspected source area The cluster will define the upgradient boundary andor any additional upgradient source areas The ASI-29 well will be paired with the existing shallow monitoring well AL-14
Monitoring well clusters ASI-30 and ASI-31 will be installed to the west cross gradient from the suspected source area to document the areal distribution of dissolved phase contamination emanatingfrom the Ailing Industrial Park The locations selected for these wells should define the northwestern and western extent of contamination
Low Flow Sampling
The additional monitoring well clusters will be sampled in accordance with the approved Site Investigation Work Plan (HSI GeoTrans 1999) Lowflow sampling procedures will be used to sample the newly installed deep wells in their respective clusters ASI-25 through ASI-31
MITEC 104e 02456
000056 MWP_DOCSgtK15JlWMOWllltraquoraquoprl
HSI GEOTRANS
Mr Michael Smith 4 October 151999
Hydraulic Characterization
HSI GeoTrans will conduct a 72 hour pumping test on the deep well at cluster ASM 2 The test is being undertaken to more adequately characterize hydraulic conditions at the site The data from this test will be used in the evaluation of remedial alternatives in the Feasibility Study The pump test will be performed as a step-drawdown test The pumping rates will ultimately be determined in the field from observed conditions Preliminary calculations indicate that pumping rates of 2 5 and 10 gallons per minute will be necessary to achieve the desired drawdown at observation wells The water level data will be recorded at observation wells ASI-06 ASI-13 ASI-25 ASI-26 NO-1 NO-2 and NO-3 The water level data will be recorded using pressure transducers and dataloggers
The effluent water from the pumping test will be treated by liquid phase granular activated carbon filters provided by Carbtrol Inc Two 175 pound carbon filters will be connected in series to treat the pump test effluent The effluent will be discharged to the unnamed brook upon approval from Randy Bean ofthe VTDEC The effluent will be periodically sampled between the carbon units and at the discharge point to detect break through ofthe carbon units The effluent samples will be analyzed utilizing a field Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999)) If the effluent sample between the carbon canisters exceeds 1000 ugL Trichloroethene (TCE) the discharge point sample will be analyzed If concentration of TCE in the discharge point sample exceed 300 ugl the test will be discontinued
We hope that this letter addendum to the Site Investigation Work Plan for the Source Investigation is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJmm MITEC I04e
02457
000057 MWFDOCSN731imu00SI 100 bullpd
HSI GEOTRANS
JHSTUART March 1 1985
Agency of Environmental Conservation D e partment of Water Resources und
E nvironmental Engineering H a z a r d o u s Materials Management Program A t t n John A m i d o n H y d r o g e o l o g i s t M o n t p e l i e r Vermont 05602
R e M I T E C Systems Corp W i l liston
Dear J o h n
During our meeting at MITEC on February 20th you noted that some additional information was needed to c omplete the initial phase of testing as well as the d o c umentation of the activities under takentodate Outline d~ beTow-Ts ~t h e~1 n f o r m a ti o n t h a t y o u r e q u e s t shyed
1 Attac hed here to is the plan used to install the grou ndwat er moni t o r s collection and analysis of the grou ndwa t er samp les for metals and organics and the extr actio n of and testing of soils from the area of the dispo sal site 2 A rev ised sit e pla n has been incl uded refl ecting the new well posi tions and the e leva t ions of t he top of t he mo ni to r s and th e groundwa ter 1e vels as of F e shybr ua ry 0th As note d in our m ost r ecent tel ephone conv i on th e lat ter have r isen 14-15 inc hes as er sa t the It o f th e rec ent thaw Two copie s of the resu plan be f orw ar ded to Winslo w Lad ue as req uested will and pla ns t 0 sur vey all ho uses on Br owne 11 Rd MITEC _tp tain if there are ajiy shallo w wel I sources ltis ce r with e dr aina ge ar ea a f fecte d by the 1agoo n in th 3 ngla nd Ma r ine C o m r a c t o r has been con tacted New E for remo va 1 of th e lagoon soil a nd co ntra c tural the ar ra nts wil 1 be concluded du r ing t he comi ng ngeme week if ic at io n of work comme nceme nt wi II be proshy Not vide your off ice i n advance d to t m Resul t s of th e met als and or genies are expected shor tiy
f rom IEA and will be fo rwarded to your ofshyf ice oon as a va i la ble as s 5 R esul t
s fr om t he pr e vious soi 1 and water sampling have inc 1 ude d bee n
CIVIL 4 EfViROUMEI-L pound l j i t fcHpound P ) OGA lt i f r l h r l h w i l l n-- i i U - iO l i l ) bU i l I
MITEC 104e 02458
s
MITEC Page 2 March 1 1985
If you have any questions please do not hesitate to contact me
Stuart PE
JHSocc
MITEC 104e 02459
MITEC Systems Corporation Williston Vermont
Soil and Water Sampling Program
1 Install groundwater monitors at nine (9) locashytions consisting of two (2) inch inside diameter PJpound with ten (10) feet of factory slotted pipe extending into the groundwater and terminating with a minimum of two (2) feet above ground level and capped
2 Establish elevations of the groundwater monitors for the top of each pipe and the groundwater elevashytion for each for a specific date Due to the shalshylow depth to groundwater from 51-112 inches the level is established by graduated tape and a light Each measurement will be performed a minimum of three times to assure accuracy to within one-eighth inch The location of each well and the established elevations will be represented on a general site plan showing the MITEC property
3 Groundwater samples are to be collected from each well on the same date by pump or baling Prior to - k ~ -~-|1bdquo--bdquobdquo f bdquo k bdquobdquobdquobdquobullbdquo ltv~ 11 1 1 v bdquo bdquo bdquo
acidification for metals preservation to assure ac curacy of the test results All samples are to be analyzed for copper cadmium nickel cyanide pH conductivity total chromium and hexavalent chrome
U Soil samples are to be collected as follows
GWM09 Saturated zone (aaprox 5) Overburden East side lagoon Composite from
two holes 5 apart-at-1 bullbull2 bullbull A below the-sur=mdash face and one in the saturated zone
North wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface 1 into the saturated zone
South wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface I1 into the saturated zone
Bottom of lagoon Composite offour test holes 8 apart one in the unsaturated zone
MITEC 104e 02460
MITEC Sampling Program
All samples are to be analyzed for the same constituents as required of the water testing
5 Collect separate samples of the groundwater after the above referenced purging process for storage in air-tight vials The samples which are to be colshylected from wells A-9 with only 5 and 7 analyzed initially by the GCMS- EPA method 62A If organics are detected in the first samples testing must be performed on 4 and 8 as well
6 All sampling will be performed with a State repshyresentative on-site and results of the testing to be forwarded to the State as soon as available
7 The contaminated soil within the lagoon will be removed by a Vermont certified contractor for disposhysal in an approved wastedepository The top one (1) foot of soil from the flood level and below will be extracted during the process
MITEC 104e 02461
i
o H
ON f J
o
bull I I bull
HA
OOO
x x z
bull
MITEC 104e 02463
WK miui w ci ivnui II i ici ILUI ujiyitb inc iii PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5108
ANALYSIS REPORT
Customer j H S c u a r t Associates Date 26 February 1985
Address P gt 0 gt B o x 3 6 7 Date Samples Received
Ci ty S t a t e Zip Essex Center VT 05A15 20 February^1985
Customer Order Nomber
Attent ion J o h n S t u a r t
Station 9
J
2
3
A
5
6
7
8
9
poundH
5A
58
52
5A
A5
53
53
55
59
j MITEC
Conductivity U mbos ( 25degC)
206
A18
21A
176__
208
230
205
16A
265
GROUNDWATER ANALYSIS
O01 0 OS bull
Cadmium Total Chromium (mRl) (mRl)
0A1 lt0025
006- 270
00A 012
bull005 189
005 023
001 lt0025
lt0C Hexavalent Chromium (mKI)
bull
lt0025
239
005
183
lt0025
lt0025
ampo
Zinc (mKl)
005
0A0
032
015
OU
003
Note Organic analyses to follow in two weeks
cc John Amadon
Signature jJfcrryyS 7lrifrylC
Offices ond loborotones located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02464
if jsznoi U hnvironmentol jiolysts Inc PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5138
ANALYSIS REPORT
Customer J H Stuart Associates Date 21 December 1984
Address PO Box 367 Date Samples Received 14 December 1984
City State Zip Essex Center VT 05451 Customer Order Number
Attention John Stuart
WATER ANALYSIS
PH 52 57 50 53 45 34
Conductivity (pmhos 25degC) 213 420 152 167 202 bull 225
O l Cadmium (mgl) lt001 lt001 001 v 028 bull 005 003
o pound Chromium Total (ng1) lt0025 lt0025 lt0025 lt0025 2-35 v 014 - -bullbull - bull - -bull V 013 bull^Chromium Hexavalent (mgl)1 0 11
gt1p Copper (mgl) lt002 lt002 lt002 lt002 bull 084 004
Q Cyanide (mgl) lt0005 lt0005 lt0005 lt0005 bull -lt0005 lt000E
Z Nickel (mgl) lt0025 lt0025 lt0025 lt0025 bull 010 003
fO 2inc (mgl) 0J1 UU1 0U3 001 038 030
Hexavalent chromium was only analyzed when total chromium was present
Signature fmnigt Mji fnt f VncL 7
Offices and laboratories located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02465
bull i
ANALYSIS REPORT
Customer J H Stuart Associates Date 22 January 1985
Address PO Box 367 Date Samples Received 14 December 1984
Ci ty State Zip Essex Center VT 05415 Customer Order Number
Attent ion John Stuart
bull shy
bull bull mdash bull bull bull bull bull - bull bull bull bull shy SOIL ANALYSIS1
Hexavalent Cyanide Chromium Chromium Cadmium Copper Nickel Zinc
poundH bull (mgl) (mgl) (mq1) bull (mq1) (mq1) (mgl) (bullmgl) -
2 442 lt0005 lt0025 lt0025 lt 001 lt 002 015 006
4 402 lt0005 lt0025 lt0025 lt 001 lt 002 lt002 001
7 504 lt0005 lt0025 lt0025 lt001 lt002 lt002 001
8 486 lt0005 lt0025 lt0025 lt001 lt002 lt002 bull 008
9 441 lt0005 lt0025 lt0025 lt001 lt602 lt002 004
10 444 0005 lt0025 lt0025 lt001 lt002 lt002 006
11 498 lt0005 lt0025 lt0025 lt001 003 lt002 009
30 532 lt0005 lt0025 008 lt001 005 lt002 010
31 544 lt0005 lt0025 lt0025 lt001 002 056 003
32 472 lt0005 lt0025 lt0025 lt001 lt002 024 003
36 536 0008 lt0025 011 lt001 005 lt002 011
37 490 lt0005 lt0025 lt0025 lt001 021 lt002 009
38 391 lt0005 0276 032 lt001 050 lt002 011
41 416 lt0005 0108 018 001 229 lt002 o5i
42 395 lt0005 0399 041 lt001 039 lt002 014
i
Signature Ltrf(7( ni W0 6M Analysis of EP toxicity extract
Offices ond loborotoriei locoted in Essex Junction Vermont Reseorch Triongle Pork North Corolino
MITEC 104e 02466
JHSTUART
A p r i l 2 9 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Hazardous Waste Materials Program Attn Cedric Sanborn Environmental Engineer Montpelier Vermont 05602
Re Mitec Systems Williston
Dear Cedric
I was phoned by David Gee today and informed that a truckload of the contaminated material was removed from the lagoon area as the result of a previous commitment entered into by Mitec Due to conflicting information about Mitecs responsibilities at this juncture I am recommending that any further work cease until a realistic program be agreed to by both parties I base that on the following
1 Following the trial pre-hearing the State was inshystructed to contact Mitec to develop a schedule for further dialogue and actions connected with the reshyhabilitation of the lagoon site To my knowledge there has not been any such attempt made on the part of the State to resolve issues that need clarificashytion
2 On April 18th I forwarded a letter to you outlinshying some new information with recommendations That correspondence has not been addressed yet Mitec has been ordered to continue with the soil removal
3 A letter from John Amadon on April 23rd notes the organic sampling to be invalid due to the time lapse and the method of storing the samples We do not take issue with this position however there is apshyparently some question about the validity of the GCMS method of analysis We have been instructed to re-sample but now there is a question about whether we should employ GC or GCMS
A On numerous occasions we have expressed the deshysire to tailor the soil removal process to a minimum
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 3C7 ESSEX CTR VERMONT 05451 TELEPHONE 802 876 bull 5171
MITEC 104e 02467
L
Mitec Page 2 April 29 1985
2- bull number of truckloads as they are projected to cost about $4000 for each load Mitec being in a startshyup phase of their operation cannot approach this operation with a blank check Chris Stone who was on hand today to represent the State indicated that many more loads may be necessary to effectively rid the site of contamination
Too many questions surround this project for my clishyent to understand his responsibilities and ultimate costs The requirements issued by your office either in writing or verbally on-site have changed repeatshyedly and unless we can mutually agree to a reasonshyable program that is connrifpH rnmdashyr r i ng Mitec has no other option but to let the court decide the isshysue
Again keep in mind there are questions that we feel must be resolved in order to reach a satisfactory conclusion
1 Provided that all Browneil Road houses are connected to the CWD system and thereby reshymoved from any threat of groundwater conshy
- p tamination what level of soil contamination is permissible From this limitation provishyded we concur as to its reasonableness an approximation can be developed as to how many loads of soil must be removed
2 If the soil is to be removed why is it neshyy cessary to conduct organics sampling unless
i t~ i s tne ulterior motive ot the State to direct renovation of the groundwater as well If that is the case the process will now be more expensive than at the outset due to the mobilization of the contaminants
3 If the contaminated soil is to be removed whv is additional groundwater monitoring
pound bull necessary Documentation of the degree of dilution is not considered acceptable
A If organic testing is to be performed y_hich -- method of analysis is to be used
As soon as we can receive a response to the quest-
MITEC 104e 02468
I um laquoi i laquo m mdash n r r j mdash i mdash
Mitec Page 3 April 29 1985
ions at hand then further discussion with the State will dnsue Also please be advised that at the dishyrection of Mitec all future correspondence communishycations requests for information or notification of site vists are to be forwarded to my office We also request that one person in your office be designated to process such information
tuart PE
JHSocc cc Mitec
Robert Cronin Esq
MITEC 104e 02469
jmfMraquoi w i f u m i
A u u raquo laquo F pound raquo laquobull= -
B C f U S t B C INC ENVIRONv i bullbullbull bullbull
5 GREEN MOUNTAIN DRIVE SOUTH BURLINGTON VERMONT 05401 TELEPHONE (802) 658-1074
February 17 1984
I I Mr Cedric Sanborn i
of Environmental Conservationi AgencAgencyy ox ampnvifoiuneniai Lonservdciun I i Dept of Water Resources and
Environmental Engineering Montpelier VT 05602
Dear Mr Sanborn j i
RE Mitec Clean-Up 84011 j
I am writing this letter to inform you of the work that has been completed thus far at Mitec Systems Corp The discharge of i rinsewater into the lagoon has stopped and the rinsewater is being batched and treated at Aquatec as I described in my letter to Stan Corneille dated February 3 1984
Although the chemical reduction and precipatation process works bull bull
very well we have found that the cost for design installation j septic design and installation and permit reviews is far above | Mitecs budget Aquatec has looked at a second alternative for bull the treatment and reduction of rinsewater that being ion exchange J The ion exchange system will be purchased from a vendor and will bull be installed by Aquatec to accomodate Mitecs rinsewater volumes i The rinsewater will be recirculated and will not require any discharge hence there will be no need for subsurface disposal [ permits I will send you specifications on the system and resins j that will be used I
The proposal for the out-door clean up work is enclosed Mr Kucer is currently discussing the cost estimate with his Montreal office I see no reason to intiate this work as soon as I get formal approval from your office and from Mitec
Please feel free to call me if you should have any questions
Sincerely
liytrl Zi [U$) John R Deigo Project Engineer
Enclosure cc Mr Steven Kucer
Hydrographic Studies and Analyses bull Water Quality Studies raquo Analytical Laboratories Ecological Studies bull Aquatic Nuisance Control - Industrial Waste Surveys
MITEC 104e 02472
Recommended Treatment of Rinsewater
Mitec System Corporation
Prepared By
Aquatec Inc
South Burlington Vermont
January 23 1984
MITEC 104e 02473
RE Mitec Groundwater Cleanup - 84011
The treatment of rinsewater will consist of a three stage rinse system with a batch chemical reduction treatment process Parts submersed in chromic acid solutions will be rinsed in a primary rinse bath The primary rinse bath will be a closed system and considered a rough rinse
The secondary rinse bath will also be a closed rinse system The third and final rinse will be a continuous overflow system Effluent from the tertiary system will flow directly into the septic system Tertiary effluent limits must be less than 005 mgl (ppm) before entering an underground septic system
The primary rinse bath will eventually become saturated with chromic acid solutions and require periodic batch treatment When the primary rinse water becomes spent it will be transferred into a 250 gal polyethylene plating tank The rinse water from the secondary rinse bath will be transferred into the primary rinse bath and the secondary bath will be refilled with fresh rinse water
When the tank reaches 80 of its capacity treatment will be initiated The treatment will consist of reducing hexavalent chromium to trivalent chromium by the addition of anhydrous sodium sulfite to a pH of lt2 The amount of sodium sulfite added will depend on the concentration and volume of rinsewater to be treated A portable electric mixer will be attached to the tank to ensure proper mixing The rinsewater in the reduced form will be gravity fed into a second 250 gallon polypropylene plating tank where lime will be added precipatlng out trivalent chromium as well as other heavy metals The mixer should be used to agitate the solution when the lime is added The mixer should be removed and the solids allowed to settle Once the solids have completely settled the treated water will be pumped into the tertiary effluent to allow for further dilution before it is discharged into a septic system
Periodic sampling of effluent waters should be incorporated to ensure that rinsewater discharged does not exceed 005 mgl (ppm)
Sludge will be properly stored and eventually disposed of by a certified hazardous waste carrier
MITEC 104e 02474
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Wildlife and Department of Forests Parks and Recreation Environmental Engineering Department of Water Resources amp Environmental Engineering Natural Resources Conservation Council State Geologist
January 4 1984
3 2ampov~ loo Mr J H Stuart
f i 2 Sm ^
P O Box 3 67 - - l ^ J ^ S M J Essec Center Vt 05451
SUBJECT Mitec Z 0~npJ^
1 o
Dear J o h n
I appreciate your sending me a copy of the recent Mitec water quality results It appears that there remains a detrimenshytal affect of the lagoon on the downgradient groundwater quality This is best demonstrated with the pH and chrome data While it appears that the downgradient well 5 has higher metalic concenshytration then well 6 in the middle of the lagoon I believe the Well 5 results are anamously high due to the turbidity or solids that we saw in the sample In talking with Cathy Cutting of IEA sample 5 was not filtered prior to acid digestion for the AAS analysis ^^
I would suggest that well s 4 5 and 6be resampled and analyzed along with the wells installed on CecT 17 amp 18 We would like to have a representative of our office on site when the sampling is performed so please contact me when a purging and sampling date is set in the near future The groundwater sample from test well 6 that you helped me obtain on December 17 with the teflon bailer was confirmed by our laboratory to contain volatile organics Therefore you must include the volatile orshyganics assay done by JGCMSjas a part of your analysis plan Adshyditionally I would suggest that you review the appropriate protocol for groundwater sampling and obtain the necessary equipshyment A sampling and analysis plan must be submitted for our apshyproval prior to commencing this second round of sampling The plan should be submitted by January 18 1985 with the sampling done within one month of our approval Please feel free to conshytact me with any comments or questions you may have
R f n r mdash i 1 Off ices - BarreEssex J c t P i t t s f o r d N Spr ing f ie ld S t Johnsbury
MITEC 104e 02844
J H Stuart Page 2
I do look forward to reviewing the results of the soils asshysays along with your report outlining the sampling protocol sampling locations data interpretations and projected course of action based on the results
Very truly yours
John F Amadon Hydrogeologist Hazardous Materials Management Program
JFAkp
cc Meredith Wright AG
MITEC 104e 02845
b v
HSTUART ASSOCIATES September 10 1984
Agency of Environmental Conservation Department of Water Resources and Environmental Engineering Air and Solid Waste Programs Attn Cedric Sanborn Air Pollution Control Engineer Montpelier Vermont 05602
Re M I T E C Corporation Williston Vermont
Dear Cedric
As Che result of our conversation on September 7th I am forwarding the information Chat we discussed
The CesCing program format was prepared prior Co our disshycussion and will be altered slightly based on some inforshymation that was collected
A boring was established in the cencer of Che disposal pic and Che wacer Cable as well as che Impeding layer were found to be located at 29 Inches below the surface The shallow depth will allow us co place addicional wells in che area co accuracely depicc Che groundwacer copography
The plan submiCCed herewith provides general information abouc che locaclon of che plane propercy lines and sugshygested positions for Che monitors The final location of che laccer will be decermined in che field once we collect more data on water table elevations
As we are most anxious to proceed with the program your expeditious review and responsewill be most appreciated
SCuart PE
JHSadt
cc David Gee MITEC
CIVIL ENVIRONMENTAL ENGINEERS 120 LAKE STREET BURLINGTON VERMONT 0S401 TELEPHONE 802-8640094
MITEC 104e 02846
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Game and Department of Forests Parks and Recreation
Department of Water Resources amp Environmental Engineering Environmental Engineering Natural Resources Conservation Council
September 19 1984
Mr John H Stuart PE JH Stuart Associates 120 Lake Street Burlington Vermont 05401
RE MITEC Project
Dear Mr Stuart
Chris Stone and I have reviewed the proposed soil sampling and groundwater monitoring plan for Mitec A summary of comments follows
1) The site plan did not show the location of the soil sampling sites Also we felt that additional boringmonitoring sites should be made closer to the facility The map has been re-marked to reflect these additional sites
2) It was not clear as to why the monitoring wells are to be installed 5 feet into the impeding layer However at least one boring should be made into the impeding layer to detershymine its thickness
3) Permeability tests should be performed on at least four of the test holes to determine aquifer characteristics
4) Since the water table is apparently close to the surface we feel that factory slotted pipe would be appropriate for the final monitoring wells
5) All soil1 ft 5 ft
samples 10 ft or
shouldto imp
be eding
takenlayer
at whic
depthshever
of comes
first
MITEC 104e 02847
Mr JH Stuart -2- September 19 1984
6) In addition to the soil sample in the center of the former lagoon four other locations within 2 feet of the edge of the lagoon must be sampled These locations are marked on the enclosed map
7) The State regulations do not address a level below which the metals are no longer hazardous as is done by EPA Toxicity Levels The level of contamination that is acceptable to the State is determined on a case by case basis
8) The analysis for chromium should include both hexavalent and total chromium
If you have any questions regarding our comments do not hesitate to contact us at 828-3395shy
Sincere
Sanborn C h r i s t o p h e r T Stone Environmental Engineer Hydrogeo log i s t Hazardous M a t e r i a l s Hazardous M a t e r i a l s Management Program Management Program
c r s - c t s a d e n c l o s u r e
MITEC 104e 02848
JHSTUART November 9 1984
Agency of Environmencal Conservation Deparcmenc of Wacer Resources and
Environmencal Engineering Hazardous MaCerials Management Program Attn Cedric Sanborn Environmental Engineer Mnotpelier Vermont 05602
Re M I T E C Corporation Williston Vermonc
Dear Cedric
There has been an apparent misunderstanding regarding your letter of September 19 1984 as soil and wacer sampling has been commenced ac che above location A call was placed Co your office on October 30th or 31sc and a message lefc for you indicating that we would begin on November 6ch at 8 AM
In the afternoon of November 6th I telephoned Chris Scone co inform him of our progress On che following morning you notishyfied MITEC that approval to begin had not been granced and chac work musC cease AC chac point we had completed che installashytion of five monitors and had extracted Cwo soil samples from the botcom of che wasce pic
On November 8ch I met with you and Chris to oucline che reshysulCs from our effores I was informed Chat we may have to inshystall one or Cwo additional monitors and Chac all future work muse be performed wich an Agency represenCacive in accendance
LaCe that afternoon Gerry Adams phoned Co notify me chat on short notice he was leaving to begin a large contract in rUasashychusetts and that it was unlikely that he would be back in the area for an extended period Had we been permitted to continue ttith our work on the 7th his portion of the project vould have been concluded
Enclosed you will find an updated version of the site plan orishyginally submitced wich my leCCer of Sepcember lOch A new plan will be developed buc Chis drawing will serve the purpose of locating existing and proposed wells
Whereas I am now withouc a drilling concracCor I would like chu
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05461 TELEPHONE 802 878 5171
MITEC 104e 02849
M I T E C Page 2 November 9 1984
authorization to determine groundwater elevations by auger and then establish one more monitor in a location agreed to by all che parcles I feel chac we have developed sufficient information co date to proceed in this manner
Furcher since Adams will noc be available I would also like Co extract che remaining soil samples wich a bucket auger IC can demonstrated chac che sample collected in chls manner will provide a good represencacion of che soil ac che level desired in Che profile
We are prepared co conclude chls phase of che sice evaluacion Samples from Che groundwacer monitors can be secured in a few days and I would like co follow wich che soil samples using che method described above
Please contact me at 878-5171 if you need additional informashytion
H Stuart PE
JHSadt
cc David Gee MITEC
MITEC 104e 02850
JHSTUART December 19 1984
M I T E C Corporation AtCn David Gee Manager IS Commerce Way Wllliscon Vermonc 05495
Dear David
Under Che Cerms of our agreemenc daced 10584 I wish Co proshyvide you wish an up-daCe of the project status
At the completion of 1219 we will have completed Items 1-4 as specified in the agreement specifically the soils sampling and initial set of water samples will have been collected and submitted for analysis As of chls momenC we still do not know the extent of the problem but will have a better indication once the test results are available in about a week My feelshying Is chac the problem is noc severe
We have compleCed all wells as prescribed however Che State is opting for an additional well Although the contract provides for only six the costs to date are below my target and it does not appear Chac any exCra will be necessary provided ChaC che driller concludes his work coday
The only work remaining afCer chls dace will be che collecCion of che second baCch of waCer samples and discussions wich Che State about any remedial action if necessary
Feel free to contacC me if you have any quescions
Regards
John H Stuart PE
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 878 bull 5171
MITEC 104e 02851
JHSTUART
M I T E C Corporation December 20 1984 ACCn David Gee Manager 15 Commerce Way Willaton VT 05495
Dear David
During our investigations yesterday Che work was completed on the additional monitor well as invoiced as well as drilling to the impeding layer The State decided however that two addishytional wells are required both of which will be Installed toshyday west of the Industrial park boundary line
A major change developed In Che method of testing the soils in the vicinity of the disposal pit that is not covered by our contract Instead of the four peripheral borings and one in Che center of che pic which would have produced flfceen soil samshyples che StaCe representatives decided Co require a different CesC paCCern Chac produced thirty seven samples I have collectshyed all of the samples but have Instructed the Cest lab to hold until authorization Is received Co proceed on Chls change as it Is a subsCanClal cost and will cause Che contract limit to be exceeded
Included is an invoice reflecting the additional wells the cost Co sample the groundwater for those monitors and the additional funds needed to run the soil tests I do not believe that any further surprises are in order
Regards
John H Stuart PE
JHSadt
CIVIL ft ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 06451 TELEPHONE 802 878 5171
MITEC 104e 02852
JHSTUART
December 28 1984
M I T E C Corporation Attn David Gee Manager 15 Commerce Way Williston VT 05495
Dear David
Enclosed are the results from the water quality analyses of the samples submitted to our lab I have noted in the left hand column the allowable limits for each element A copy of this information has been forwarded to John Ami-don per his request
There are several readings that are suspicious according to John The cadmium level in 4 may be an error and Che chromium found in 5 mosc likely Includes che CurbldlCy measured only in ChaC well Both should be resampled to confirm The cadmium and chromium levels in 06 exceed che allowable llmlCs but not excessively so The soil tesCs which have begun will reveal more about the ultimate disshyposition of these elemenCs
On the sewer Issue I spoke wich Frank Ailing again and his plans are Co now develop Che design and receive approval chis wincer for consCrucCion of the required Improvements this spring
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 5171
MITEC 104e 02853
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LA6^M PLAU
MITEC 104e 02855
JHSTUART January 28 1985
M I T E C Corporation Attn David Gee Manager 15 Commerce Drive WillistonVermont 05495
Dear David
On January 25th I met with John Amadon and Cedric Sanborn to discuss the contents of my 12385 letshyter The following resulted subject to confirmation by more senior members of the AEC staff
1 The water samples to be collected from wells 45 and 6 are to be checked for cadmium both chromiums and conductivity Wells 1 2 and 3 will be tested for conductivity and pH only
2 Samples will be collected from wells 4-9 for orshyganics but only wells 56 and 9 are to be checked at this time to determine the scope of contaminatshyion
3 The material to be removed from the pit is conshysidered as a hazardous waste and there are not any disposal sites located within Vermont certified to receive it I did obtain a listing of contractors that are approved for handling the material and I will provide this during our next meeting
4 Attached is a copy of the State lab results that address the organics problem
5 Based on the above we will have to amend our ashygreement to include the $1150 additional costs for the testing connected with Items 1 and 2
Call me if you have any questions
John H Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 raquo 878 bull 5171
MITEC 104e 02856
JHSTUART January 30 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Attn John Amadon Hydrogeologist Montpelier Vermont 05602
Re M I T E C
Dear John
I have had several discussions with MITEC relative to our meeting of last Friday In essence they have agreed to the program that you defined but with several provisos
They would like a letter from your office detailing the additional measures to be implemented together wich specific instructions as to what steps must be taken in the process of removing the contaminated soil
Further their acceptance to collect and sample for volatile organics is limited Perchloroethylene as I had indicated is not and has not been used by MITEC The materials stored on the premises as well as the list of suppliers for paints and solvents are available for inspection co corroborate that position MITEC will provide a complete analysis of all organics for the specified wells however fushyture testing for TCE will not be at the expense of MITEC unless its presence can be attributed to their operation
We are prepared to proceed as soon as we receive the requested notification
Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 bull 5171
MITEC 104e 02857
CORRECTIVE ACTION FEASIBILITY INVESTIGATION
EPA SITE NUMBER VTD-098353545 (LOT 19-11)
PREPARED FOR
ALLING INDUSTRIAL PARK
PREPARED BY
HSI GEOTRANS INC
6 LANCASTER COUNTY ROAD
HARVARD MASSACHUSETTS 01451
HSI GEOTRANS PROJECT NO N753-016 OCTOBER 52000
HSI GeoTrans inc
MITEC 104e 02353
TABLE OF CONTENTS
PAGE
1 INTRODUCTION 1-1
2 STUDY AREA CONCEPTUAL MODEL 2-1 21 STUDY AREA LOCATION AND DESCRIPTION 2-1
22 STUDY AREA LAND USE 2-1
23 HYDROGEOLOGIC SETTING 2-1
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION 2-3
3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES 3-1 31 IDENTIFICATION OF ARAR S 3-1
32 REMEDIAL ACTION OBJECTIVES 3-1
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES 3-1
322 GROUNDWATER 3-1
323 SURFACE WATER 3-2
324 INDOOR AIR 3-3
33 INITIAL SCREENING 3-3
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES 3-4
4 DETAILED ANALYSIS OF ALTERNATIVES 4-1 41 ALTERNATIVE 1 NO ACTION 4-1
411 SHORT-TERM EFFECTIVENESS 4-1
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-2
413 LONG-TERM EFFECTIVENESS 4-2
414 COMPLIANCE WITH ARARS 4-3
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 4-4
416 IMPLEMENTABILITY 4-4
417 COSTS 4-5
42 ALTERNATIVE 2 MONITORING INSTITUTIONAL CONTROLS AND
HYDRAULIC CONTAINMENT 4-5 421 SHORT-TERM EFFECTIVENESS 4-8
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-9
423 LONG-TERM EFFECTIVENESS 4-9
424 COMPLIANCE WITH ARAR S 4-10
425 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-11
426 IMPLEMENTABILITY 4-11
427 COSTS 4-12
FOR ALLING INDUSTRIAL PARK MWP_DOCSW5J20OTALlIWFS9-00U0030929wro 11 HSI GSOTrflnS IflC
MITEC 104e 02354
TABLE OF CONTENTS (CONTINUED)
PAGE
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS
AND PERMEABLE REACTIVE BARRIER 4-13
431 SHORT-TERM EFFECTIVENESS 4-15
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-16
433 LONG-TERM EFFECTIVENESS 4-17
434 COMPLIANCE WITH ARARs 4-18 435 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-18
436 IMPLEMENTABILITY 4-19
437 COSTS 4-20
44 ALTERNATIVE 4 MONITORING INSTITUTIONAL CONTROLS
AND NATURAL ATTENUATION 4-20
441 SHORT-TERM EFFECTIVENESS 4-21
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-21
443 LONG-TERM EFFECTIVENESS 4-22
444 COMPLIANCE WITH ARARS 4-23
445 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-23
446 IMPLEMENTABILITY 4-23
447 COSTS 4-24
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION 4-25
451 SHORT-TERM EFFECTIVENESS 4-26
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-27
453 LONG-TERM EFFECTIVENESS 4-27
454 COMPLIANCE WITH ARARS 4-28
455 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-29
456 IMPLEMENTABILITY 4-29
457 COSTS 4-30
FOR ALLING INDUSTRIAL PARK MWPJXgtCSN7532000AUJNOFSlaquo)0I0030929WPD 111 HSI GeOTrSDS ItlC
MITEC 104e 02355
TABLE OF CONTENTS (CONTINUED)
PAGE
5 COMPARATIVE EVALUATION OF ALTERNATIVES 5-1 51 SHORT-TERM EFFECTIVENESS 5-1
52 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT 5 - 3 53 LONG-TERM EFFECTIVENESS 5-4
54 COMPLIANCE WITH ARARS 5-4
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 5-4
56 IMPLEMENTABILITY 5-5
57 COSTS 5-5
6 PREFERRED REMEDY 6-1 61 PREFERRED REMEDY 6-1
62 MONITORING PROGRAM 6-2
REFERENCES 7-1
APPENDIX A TWODAN INPUT FILES
FOR ALLING INDUSTRIAL PARK MWgt_DOCSW7532000WJJNGfS9^)0M00J(raquo9wpo I V H S I G S O T r a H S I n C
MITEC 104e 02356
LIST OF TABLES
PAGE
TABLE 3-1 REMEDIAL ACTION OBJECTIVES 3-7
TABLE 3-2 DESCRIPTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES 3-8
TABLE 3-3 SELECTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES
FOR DETAILED ANALYSIS 3-11
TABLE 41 COST ESTIMATES FOR REMEDIAL ALTERNATIVES 4-31
TABLE 6-1 SAMPLING LOCATIONS 6-5
TABLE 6-2 VOC ANALYTES 6-6
TABLE 6-3 PARAMETERS TO EVALUATE BIODEGRADATION 6-7
FOR ALLING INDUSTRIAL PARK MWP DOCSN7S32000AUJNOFS9-00I0030929 wro HSI GeoTrans inc
MITEC 104e 02357
LIST OF FIGURES
PAGE
FIGURE 1-1 STUDY AREA LOCATION MAP 1-2
FIGURE 1 -2 LATERAL BOUNDARIES OF REGION OF TCE-CONTAMINATED GROUNDWATER 1 -3
FIGURE 4-1 MODELED SITE-EXISTING CONDITIONS 4-33
FIGURE 4-2 MODELED SITE WITH THREE RECOVERY WELLS PUMPING AT 5 GPM 4-34
FIGURE 4-3 MODELED SITE WITH TEN RECOVERY WELLS PUMPING AT 5 GPM 4-35
FIGURE 4-4 ALTERNATIVE 3 PERMEABLE REACTIVE BARRIER 4-36
FIGURE 6-1 PROPOSED MONITORING LOCATIONS 6-8
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUUNOFS9-OOV 10030929 w r o VI HSI GeoTrans inc
MITEC 104e 02358
1 INTRODUCTION
This Corrective Action Feasibility Investigation is submitted on behalf of Mitec Telecom
Inc (Mitec) by HSI GeoTrans The investigation was done to evaluate potential remedial
alternatives for groundwater contaminated by trichloroethylene (TCE) and to a lesser extent
tetrachloroethylene (PCE) and petroleum related compounds (BTEX) at the Ailing Industrial
Park (the Study Area) A recently prepared Site Investigation Report (SIR) (HSI GeoTrans
2000) identified the nature and extent of contaminated groundwater within the Study Area
Figure 1-1 is a map ofthe Study Area and Figure 1-2 is a map that outlines the region of
contaminated groundwater for which potential remedial alternatives were evaluated
The SIR concluded that the TCE contamination was widespread across the Study Area
that residual TCE dense non-aqueous phase liquid (DNAPL) resulting from one or more releases
was a continuing source of contamination to groundwater and that under current conditions the
groundwater contamination does not pose an unacceptable risk to human health and the
environment Current conditions include the continued effective mitigation of indoor air vapors
at the residence at Lot 3-30 no other residences with basements below the water table and no
use of groundwater within the Study Area as a potable supply The SIR also concluded that if
groundwater were to be used as a potable supply a significant health risk would exist as a result
of exposure to groundwater through ingestion dermal contact and inhalation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^X)M0030929WPD 1 - 1 HSI GCOTrdnS ITC
MITEC 104e 02359
I - N -
Former Mitec Hold y
Meters
Explanation
Study Area TITLE
MITEC 104e 02360
Study Area Location Map
LOCATION
Williston Vermont CHECKED MS FIGURE HSI OfVFTED RMK
GEOTRANS RLE f s ~ Expa nd~S(tsdirq 1-1 A T I T M TICK C011irraquoraquoT DATE- 10600 ~
2 STUDY AREA CONCEPTUAL MODEL
The following discussion ofthe Study Area conceptual model is summarized from
information contained in the previously submitted SIR (HSI GeoTrans 2000)
21 STUDY AREA LOCATION AND DESCRIPTION
The Study Area is located at the Ailing Industrial Park and adjacent areas in Chittienden
County Williston VT The VT state plane coordinates for the Study Area are Northing
71210837 (44 27 T north latitude) and Easting 147576375 (73 7 50 west longitude) The
Study area is within the Winooski River watershed and has an elevation ranging from 330 to 350
feet above mean sea level (MSL) The ground surface has little relief and slopes gently to the
southwest A small unnamed brook flows in a southerly direction along the eastern edge of an
industrial park located within the Study Area There is unlimited public pedestrian access to the
Study Area
22 S T U D Y A R E A L A N D U S E
The land in the Study Area is currently zoned for mixed residential commercial and
industrial use The eastern portion ofthe Study area is primarily zoned for commercial use and
the western portion ofthe Study Area is predominantly residential The Study Area includes an
industrial park where there has been light industrial and commercial use since 1946 Three lots
in the industrial park have been previously identified as locations of former manufacturing andor
fabrication operations that resulted in release of contaminants to groundwater (Brinkerd 1996
TRC 1993 Griffin 1995)
23 HYDROGEOLOGIC SETTING
The unconsolidated geologic deposits beneath the Study Area consist of sand silt and
clay which were deposited in the former Champlain Sea overlying till The unconsolidated
deposits occur in four distinct layers The surficial deposits are medium to fine sand which
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generally becomes finer-grained with depth and extend to approximately 20 feet below ground
surface (bgs) Interbedded silts and fine sands are present from approximately 20 to 40 feet bgs
An areally-extensive clay layer underlies the interbedded silt and fine sands at a depth of
approximately 32 to 60 feet bgs Beneath the clay layer is a dense till which extends from about
60 to 100 feet bgs The underlying bedrock is comprised of massive gray limestone gray
dolomite and white marble ofthe Beckman formation This bedrock is of lower Ordovician age
and is part ofthe Hinesburg Synclinorium structure
The aquifer in the Study Area and surrounding regions is primarily the surficial medium
and fine sands although some water is capable of being extracted from the lower silt and fine
sand The residences and businesses within the Study Area are currently serviced by a public
water supply and the aquifer is not used for potable water supply within the Study Area The
hydraulic conductivity ofthe medium to fine sands was determined from a slug test to be about
20 feetday (Johnson 1999) The hydraulic conductivity ofthe interbedded silt and fine sand as
determined from rising and falling head slug tests (HSI GeoTrans 2000) ranged from 1 to 20
ftday with a geometric mean of 38 ftday A pumping test of well NO-1 yielded a hydraulic
conductivity estimate of about 2 to 30 ftday for the combined medium to fine sands and
underlying silt and fine sand There are no hydraulic conductivity data for the underlying clay
and till layers It is believed that the clay and till act as a lower confining layers restricting the
vertical flow of water between the overlying sand and the underlying bedrock
Beneath the Study Area the depth to water generally ranges from 3 to 11 feet below
ground surface In general groundwater flow beneath the Study Area is from the north to the
southeast and southwest There is a groundwater divide in the water table that runs generally
parallel to Commerce Street East ofthe divide groundwater flows toward and discharges to the
unnamed brook West ofthe divide groundwater flows toward Muddy Brook which is located
about 300 meters or 1000 feet west ofthe Study Area Groundwater recharge within the Study
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Area is primarily from infiltration of precipitation Prior to 1986 when a sewer line was
installed groundwater recharge also resulted from discharge to numerous on-site disposal
systems
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION
Figure 1-2 illustrates the 1999 distribution of TCE-contaminated groundwater within the
Study Area The lateral boundaries ofthe region of TCE-contaminated groundwater
approximately represent the lateral boundaries ofthe region of volatile organic compound
(VOC)-contaminated groundwater As discussed in the SIR (HSI GeoTrans 2000) VOCs
present in groundwater include TCE PCE and BTEX The compound detected at the highest
concentrations and over the largest portion ofthe Study Area is TCE PCE is generally detected
in the same area as TCE but at significantly lower concentrations BTEX compounds have been
detected in groundwater primarily in the eastern portion ofthe Study Area and are commingled
with but not coincident with TCE-contaminated groundwater The lateral boundaries shown in
Figure 1-2 approximately represent the lateral extent of groundwater contamination and are not
intended to indicate that all groundwater within those boundaries is contaminated This figure
includes data collected on behalf of Mitec as part ofthe SIR (HSI GeoTrans 2000) and data
collected in 1999 by the Johnson Company (Johnson 1999) Figure 4-2 A ofthe SIR (HSI
GeoTrans 2000) shows all TCE concentration data collected in 1999 as well as some data
collected in 1997 The SIR (HSI GeoTrans 2000) summarized previous investigations that
indicated that at least three properties have contributed to the region of VOC-contaminated
groundwater On Lot 19-11 there were a disposal lagoon and a leach field that resulted in the
release ofthe VOCs TCE and PCE (perhaps as an impurity in the TCE) Lot 19-12 once had
underground storage tanks from which a previous release of BTEX was discovered when the
tanks were removed Lot 19-2 contained a disposal pit and outfall pipe from which TCE was
reportedly released
Figure 1-2 of this report shows in plan view the areal distribution of TCE-contaminated
groundwater Where there were multiple 1999 data values for the same location preference was
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AL1JNOFS9-OOM0030929WPD 2-3 HSI GSOTraHS JHC
MITEC 104e 02364
given to samples collected by low-flow sampling done subsequent to well installation In
addition for those locations which had samples from different depths the sample with the
highest concentration was used Figure 1-2 illustrates that TCE-contaminated groundwater is
widespread beneath the Study Area and that the highest TCE concentrations are detected in
groundwater beneath the eastern portion ofthe Study Area The figure illustrates that TCE-
contaminated groundwater in the eastern portion ofthe Study Area discharges to the unnamed
brook No VOCs including TCE have been detected in groundwater samples collected from
wells on the eastern side of the unnamed brook Based on surface water and groundwater data
that have been collected the unnamed brook appears to limit the southeasterly extent ofthe
region of VOC-contaminated groundwater In the western portion ofthe Study Area the lateral
boundaries of contaminated groundwater were identified through vertical profile sampling at
several locations Figure 1-2 shows the location ofthe vertical profiling borings that define the
lateral extent of TCE-contaminated groundwater The SIR (HSI GeoTrans 2000) recommended
periodic sampling and analysis of wells in the western portion ofthe Study Area for the purpose
of determining whether this region of VOC-contaminated groundwater was stable or expanding
in size
While not evident from Figure 1-2 it was determined that throughout the Study Area the
highest TCE concentrations were detected in samples collected from the interbedded siltclay
layer As shown on Figure 4-2A ofthe SIR the higher TCE concentrations were generally
detected at a depth of about 35 feet below ground surface in the eastern portion ofthe Study
Area and at a depth of about 30 feet below ground surface in the western portion ofthe Study
Area It is believed that the current distribution of TCE contamination resulted from DNAPL
releases at one or more locations within the Study Area One such release area was at Lot 19-11
DNAPL migrated downward through the upper medium to coarse sands under the primary
influence of gravitational forces There would have been some lateral displacement along
preferential pathways provided by sloping unconsolidated deposits but the primary flow would
have been downward Upon encountering the more resistive capillary pressure forces associated
with the water-saturated finer-grained geologic units such as the interbedded silts and sands
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which exist beneath the upper medium to coarse sands the DNAPL downward migration would
have stopped The DNAPL would have accumulated on top ofthe capillary pressure barrier layer
and then would have spread laterally following preferential flow paths within the coarser-grained
geologic units above the interbedded silts and sands The amount of lateral spreading of
DNAPL from any release area would have been dependent upon the volume and frequency ofthe
releases As the DNAPL migrated it would have created a region of residual DNAPL This
region of residual DNAPL consists of isolated DNAPL droplets trapped within pore spaces ofthe
unconsolidated deposits The lateral migration ofthe DNAPL would have been affected by the
slope ofthe surface ofthe finer-grained units that halted downward migration ofthe DNAPL
and it would not necessarily have been coincident with the direction of hydraulic gradient or
groundwater flow The region of residual DNAPL is now a continuing source of contamination
to the groundwater which flows past and gradually dissolves the DNAPL The locations ofthe
residual DNAPL zones are not known
There were no direct observations of DNAPL during drilling and well installation but it
is expected that residual DNAPL generally exists within regions of higher concentration detected
in the eastern portion of the Study Area The residual DNAPL is not necessarily continuously
connected within that region Based on the vertical distribution of TCE concentrations it is also
expected that the residual DNAPL exists in a relatively thin zone within the interbedded silt and
clay Limited hydrodynamic dispersion within the interbedded silt and clay has resulted in a
relatively thin zone of relatively high TCE concentrations in groundwater The southeastward
and southwestward divergence of groundwater flow has resulted in a laterally extensive region of
TCE-contaminated groundwater
There has been no indication in any ofthe investigations done within the Study Area
including the SIR (HSI GeoTrans 2000) that there are locations within the Study Area where
DNAPL is present in sufficient volume to be recoverable in the DNAPL phase
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3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES
31 IDENTIFICATION OF ARARS
Two Applicable or Relevant and Appropriate Requirements (ARARs) were identified in
consultation with Mr Mike Smith ofthe Vermont Department of Environmental Conservation
(VTDEC) The first are the Groundwater Enforcement Standards as outlined in Appendix one of
the Chapter 12 Groundwater Protection Rule (VTDEC 1997) These standards apply to
concentrations of contaminants in groundwater in the Study Area (TCE PCE and BTEX) The
second are the Vermont Water Quality Criteria dated March 142000 (VTDEC 2000) which
specify surface water quality criteria and policy
32 REMEDIAL ACTION OBJECTIVES
The remedial action objectives (RAOs) for the Study Area are summarized in Table 3-1
and further described below
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES
One ofthe RAOs for the Study Area is the remediation of source areas Soil excavation
and removal has already occurred at the known release areas Not withstanding the fact that
previous DNAPL releases are suspected no areas of recoverable DNAPL have been detected in
the Study Area Concentrations of TCE in groundwater indicate it is present in some areas as
residual phase below the water table One purpose of this Corrective Action Feasibility
Investigation is to evaluate options for remediating residual DNAPL in the Study Area
322 GROUNDWATER
Attain VT Groundwater Enforcement Standards The ultimate goal of remediation is to
attain Groundwater Enforcement Standards for VOCs in groundwater This is in accordance
with the VT Groundwater Protection Rule and Strategy (VTDEC 1997) which states that If an
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enforcement standard has been reached or exceeded at a compliance point the goal is to take
appropriate action to retum the groundwater quality to below the enforcement standard if
possible
Prevent Expansion ofthe Dissolved Plume A risk assessment (Menzie Cura 2000a and
2000b) was included as part ofthe SIR (HSI GeoTrans 2000) The risk assessment concluded
that under current conditions concentrations of VOCs dissolved in groundwater in the Study Area
do not pose a risk to human health andor the environment The SIR (HSI GeoTrans 2000) also
indicated that the available monitoring data were not sufficient to determine whether the region
of VOC-contaminated groundwater in the southwestern portion ofthe Study Area was stable in
size or expanding This Corrective Action Feasibility Investigation explores options for
monitoring groundwater quality and preventing the region of VOC-contaminated groundwater
from expanding in size
Prevent Potable Use of Groundwater Within the Dissolved Plume Menzie Cura prepared
a June 1 2000 addendum (Menzie Cura 2000b) to the April 2000 risk assessment (Menzie Cura
2000a) The addendum evaluated risk posed by potable use of groundwater at the site The
addendum found there to be a human health risk associated with the use of groundwater at the
site for potable purposes One RAO of this Corrective Action Feasibility Investigation is to
propose institutional controls so that groundwater within the region of contaminated
groundwater would not be used as a potable supply until concentrations are suitable for such use
323 SURFACE WATER
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
under current conditions VOCs dissolved in surface water in the Study Area do not pose arisk to
human health or the environment Currently however surface water concentrations in the
unnamed brook exceed VT Water Quality Criteria (VTDEC 2000) One ofthe RAOs for the
site will be to meet these surface water quality standards in the unnamed brook
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324 INDOOR AIR
The VTDEC has conducted air sampling at several residences along Kirby Lane and
South Browneil Road The results have indicated the presence of TCE and PCE in indoor air at
some ofthe South Browneil Road residences (Brinkerd 1996) and unacceptable VOC
concentrations in the basement ofthe residence at Lot 3-30 on South Browneil Road The
presence of VOC vapors in the residence on Lot 3-30 is believed to have resulted from
volatilization of groundwater which infiltrated the basement through a continuously operating
sump pump The sump was vented to the exterior ofthe house as part of a state-sponsored
action and the indoor air concentration ofthe contaminants reduced to an acceptable
concentration Therefore one institutional control for the site will be to maintain the sump
venting as long as necessary to prevent health risks due to inhalation of VOC concentrations in
indoor air Also an institutional control in the form of a zoning restriction should be
implemented to prohibit the construction of new buildings with basements below the water table
in the region of contaminated groundwater The restriction should specify that in cases where it
is unavoidable to place the basement below the water table proper containment and venting of
the sump drainage system is required
33 INITIAL SCREENING
Four general categories of remedial technologies were evaluated The first monitoring
may be used alone or in conjunction with other remedies The second category includes
institutional controls to prevent exposure to contamination in groundwater and indoor air
Institutional controls could also be used alone or in conjunction with other remedies The third
category includes source removal technologies
The fourth category includes contaminated groundwater containment technologies such
as a hydraulic barrier or permeable reactive barrier Containment technologies can be applied in
two different ways Thefirst source control application would entail installing the containment
technology directly downgradient ofthe highest dissolved concentrations in an attempt to contain
the contaminated groundwater nearest the source Over time if new contamination is not
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allowed to migrate beyond the source VOC concentrations in the downgradient region of
contaminated groundwater should attenuate
The second application would entail installing the containment technology at the
downgradient edge ofthe region of Contaminated groundwater The containment would protect
downgradient receptors from impacts by the region of contaminated groundwater
Both containment technology approaches were considered for use in the event additional
monitoring data shows that the region of VOC-contaminated groundwater is expanding in size
or if VOC concentrations in groundwater discharging to the unnamed brook are increasing
Table 3-2 identifies the remedial technologies considered and summarizes the results ofthe
initial screening for applicability to addressing the ARARs
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES
The list of potentially viable technologies shown in Table 3-2 was subjected to an initial
screening process The purpose ofthe initial screening was to identify those technologies that are
potentially feasible in the Study Area prior to performing a more detailed technology screening
Many ofthe source removal technologies were removed from further consideration because of
the impracticability of remediating residual DNAPL at the site
As described in the SIR (HSI GeoTrans 2000) DNAPL is likely present in the Study
Area Although present DNAPL has not been directly observed in any location and there has
been no indication that there is recoverable DNAPL present The failure to detect DNAPL
directly is not an uncommon situation at DNAPL sites and commonly results from its
heterogeneous distribution or its presence only at residual saturation (US EPA 1992)
Groundwater extraction and treatment is not an effective technology for remediation of residual
DNAPL due to limitations resulting from the limited solubility of most DNAPL compounds and
the heterogeneous distribution ofthe DNAPL (US EPA 1993) Designing remedial strategies
for DNAPL is made difficult by the inability to accurately locate the DNAPL sources This
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320(XAALlJNoFS9^)010030929wro 3 - 4 H S I G C O T r a n S I n C
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inability to locate the DNAPL renders the use of targeted source remedies that might be cost
effective for a small readily definable source area ineffective These targeted source remedies
include excavation air sparging chemical oxidation in-situ thermal desorption and chemical
flushing technologies
Subsurface deposits in the Study Area are heterogeneous due to the interbedded nature of
the sands and silts overlying an areally extensive clay The presence of such heterogeneity
creates extremely variable and unpredictable groundwater flow velocities as well as flow paths
for DNAPL migration The contrast in permeability and porosity between different lithologies
results in the development of preferential flow pathways While preferential flow through coarse
sand and gravel zones provides higher than average groundwater flow rates and contaminant
flushing less preferential flow pathways such as silty sands silts and clays remain poorly
flushed even under forced hydraulic gradients created by extraction wells Contaminants
however may have migrated to these areas of less preferential flow as DNAPLs under
gravitational influence or by diffusion over long periods of time The low permeability zones
even if addressed by localized extraction of groundwater will transmit only small quantities of
water and hence contaminant flushing is slow This is compounded by the low solubility of
DNAPL constituents and the tendency for them to become trapped in soils by capillary pressure
forces
Specific source removal technologies which have been screened out as ineffective at this
stage include air sparging groundwater amendments excavation and in-situ thermal desorption
Low permeability zones prevent the migration of soil vapors or sparged air to the near-surface for
recovery due to the preferential flow caused by heterogenieties it is not possible to determine if
amendments which can be added to the groundwater or chemical flushing compounds which
displace the groundwater and help liberate residual DNAPL such as oxidants alcohol polymers
andor surfactant would reach the DNAPL Excavation which has already been used to remove
impacted surface soils in known release areas is not practical for removing residual DNAPL
deep below the water table The in-situ thermal desorption can be useful in some environments
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but can also induce downward DNAPL migration if hydraulic control ofthe system is not
complete Because the location of residual DNAPL is not known and because hydraulic control
ofthe underlying silt clay and till into which the DNAPL may migrate cannot be assured in-situ
thermal desorption is not feasible for this site
Monitoring and institutional controls are included in each option evaluated except for the
no-action alternative These are required to rule out possible future health risks due to expansion
ofthe region of VOC-contaminated groundwater or the creation of new contaminant exposure
pathways
The technologies remaining after the initial screening are presented in Table 3-3
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Table 3-1 Remedial action objectives
MEDIA REMEDIAL ACTION OBJECTIVE
Groundwater -Remove or control contaminant sources
bullAttain VT Groundwater Enforcement Standards
-Prevent expansion ofthe region of contaminated groundwater
-Prevent use of groundwater within the region of contaminated groundwater as a
potable water supply where contaminant concentrations exceed federal drinking
water standards
Surface Water -Attain VT Water Quality Criteria
Air -Prevent inhalation of concentrations in indoor air derived from groundwater
FOR ALLING INDUSTRIAL PARK MWP DOCSW7520(XMUJNOFS9^XM0030929WPO 3-7 HSI GeoTrans inc
MITEC 104e 02373
-n Table 3-2 Description of potentially viable remediation technologies o w o
i mi m rshym
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R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Basement Sump Venting
Restriction on new buildings with basements set below the water table
Restrict Potable Use of Groundwater
Excavation
Natural Gradient Flushing
Air Sparging
RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
PROCESS DESCRIPTION OPTIONS
No Action No Action
Monitor groundwater concentrations to confirm that region of VOC-contaminated groundwater is not expanding in size
Monitor surface water concentrations in unnamed brook to ensure concentrations remain below risk levels
Continue to vent the sumps at Lot 3-30 on South Browneil Road
Restrict construction of any new buildings with basements set below the water table within the area of dissolved VOC contamination and require basement sump venting in those where a below water table basement is unavoidable
Place restrictions on potable use of groundwater at properties overlying the region of VOCshy contaminated groundwater
Excavation and removal of soils containing residual DNAPL
Continued dissolution and natural attenuation of residual DNAPL
Injection of air beneath the water table to volatilize residual DNAPL and dissolved concentrations in groundwater
INITIAL SCREENING C O M M E N T
Used as a baseline for comparison No cost Long remediation time
Can be used in conjunction with other response actions Will be required in the southwest portion ofthe region of contaminated groundwater since existing data are inconclusive regarding this issue
Can be used in conjunction with other response actions
Will be required until data show there is no longer a risk to indoor air from groundwater in the basement
Will be required until data show there is no risk of migration of VOCs to indoor air from groundwater
Will be required at all properties in the area of VOC-contaminated groundwater to prevent a risk to human health
Has been used at the site to remove residual DNAPL in soils in the release areas Impractical to recover residual DNAPL at depth The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Intermediate cost Short time frame to cleanup if all residual source can be removed
Higher permeability zones are preferentially remediated On-going monitoring required No installation or on-going maintenance costs Long time frame to cleanup
Small-scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Intermediate installation and high on-going maintenance costs
MITEC 104e 02374
5 T l O Description of potentially viable remediation technologies (continued) PO
Table 3-2 O
RESPONSE REMEDIAL PROCESS g 5 ACTION TECHNOLOGY OPTIONS 5 m
r-m Source Chemical Ozone m Removal Oxidation Sparging q JO o n o
o
Potassium Permanganate Injection
Fentonss Reagent Injection
i co
Source In-Situ Steam Removal Thermal Stripping
Desorption
Electrical Resistance Heating
I Radio (pound Frequency
O m Heating OH 3) gt Z 0)
DESCRIPTION
Injection of air and encapsulated ozone beneath the water table to oxidize dissolved DNAPL constituents such as TCE
KMn04 is injected below the water table to oxidize dissolved DNAPL constituents
Fentons Reagent is injected below the water table to oxidize dissolved DNAPL constituents
Stream injected below the water table As the groundwater and soil are heated residual DNAPL is mobilized and collected by groundwater and soil vapor extraciion techniques
Low frequency alternating current is applied below the water table to cause resistive heating ofthe soil and groundwater As the groundwater and soil heat residual DNAPL is mobilized Groundwater and soil vapor extraction techniques are used to collect dissolved and vaporized DNAPL constituents
Electromagnetic radiation is applied below the water table As the groundwater and soil heat residual DNAPL is mobilized
INITIAL SCREENING COMMENT
Presence of DNAPL will potentially require large quantities of ozone The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Small scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Ozone is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of KMn04 The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of Fentons Reagent The exact location of the residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Fentons Reagent is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Small scale heterogenieties can result in channeling during steam injection and reduce the recovery efficiency Shallow depth of application may preclude effective steam control The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeneity has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeniety has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult so target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
_ mdash_ mdash _ _
MITEC I04e 02375
bulln Table 3-2 Description of potentially viable remediation technologies (continued) o
R E S P O N S E
A C T I O N
tn Source Removal
Source Containment Plume Management
co bull
o
lt)
o mOH 30 gt Z OJ
REMEDIAL
TECHNOLOGY
Chemical Flushing
Hydraulic Containment
Impermeable Barrier
Permeable Reactive Barrier
Phytoshyremediation
PROCESS
OPTIONS
bull
DESCRIPTION
Injection and recovery of alcohol polymers andor surfactant below the water table to enhance dissolution of residual DNAPL
Pump groundwater in downgradient portion of VOC-contaminated region groundwater to intercept contamination before it reaches a receptor or downgradient ofthe highest concentrations as source containment
Impermeable barrier is installed in the subsurface to contain groundwater and reduce the pumping rate needed for containment Can be installed upgradient of a receptor to prevent exposure or downgradient of the highest concentrations as source containment
Reactive material such as zero valent iron placed in flow path of contaminated groundwater Contaminants are treated as the natural gradient causes groundwater to flow through the barrier
Extracting of contaminated groundwater by evaporation from high water use trees Organic contaminants may also be biodegraded by the root system or may adsorb to living or dead root tissue and become immobilized
INITIAL SCREENING C O M M E N T
Higher permeability zones are preferentially remediated The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Groundwater extraction is required to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent fulfresidual DNAPL removal Very high installation and operation cost
Effective in containing dissolved concentrations Relatively low installation cost moderate on-going maintenance costs
Effective in containing dissolved concentrations Requires groundwater extraction and treatment Moderate installation cost moderate on-going maintenance costs
Moderate installation costs Lifetime of reactive material difficult to predict and reinstallation may become necessary No on-going maintenance costs prior to replacement
Still experimental Hard to confirm water usage rates and prove containment Trees may require ongoing monitoring and replacement Low installation and maintenance costs Only operates during the growing season
MITEC 104e 02376
1 T l Table 3-3 Selection of potentially viable remediation technologies for detailed analysis 1
rt g g g
5
i 8 5
3
CO
o m O H JO gtZW
o3 O tn
spound r m rshymO
M nn o
gt zbulllt
RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Indoor Air Monitoring
Basement Sump Venting
Potable Use of Groundwater
Restrict Basements Below Water Table
Excavation
Natural Gradient Flushing
Air Sparging
Chemical Oxidation
In-Situ Thermal Desorption
Chemical Flushing
PROCESS
OPTIONS
No Action
Ozone Sparging
Potassium Permanganate Injection
Fentonss Reagent Injection
Steam Stripping
Electrical Resistance Heating
Radio Frequency Heating
RETAINED
DISCARDED
Retained
Retained
Retained
Retained
Retained
Retained
Retained
Discarded
Retained
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
RATIONALE
Used as a baseline for comparison
Necessary to evaluate if the region of VOC-contaminated groundwater is expanding in size and if the VOC concentrations in groundwater discharging to the unnamed brook are increasing
Necessary to monitor that concentrations remain below health risk levels
May be required al new residences with basements below the water table built in Browneil Road area
The existing sump vents at Lot 3-30 on South Browneil Road will be required to mitigate indoor air risks
Restriction of potable use of groundwater at properties overlying the region of VOC-contaminated groundwater will be required to prevent dermal ingestion and inhalation exposure
Restriction of construction of new basements below the water table in the area of VOC-contamination will be required to prevent future inhalation risks
Residual DNAPL located too far below ground surface to make excavation feasible The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Excavation of known release areas has occurred
Longer time frame to clean up not a drawback at this site Lower cost is a benefit
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location of the residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL Steam control difficult
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
MITEC 104e 02377
2 Table 3-3 Selection of potentially viable of remediation technologies for detailed analysis (continued) a m RESPONS E R E M E D I A L PROCES S RETAINED RATIONALE
ACTION T E C H N O L O G Y OPTION S DISCARDED
Source Containment Hydraulic Containment Retained Proven effective at containing expansion ofthe region of contaminated groundwater Region of Contaminated
iisect
n n o
Groundwater Management
Impermeable Barrier Retained Proven effective at region of contaminated groundwater containment
Permeable Reactive Retained Proven effective at region of contaminated groundwater containment Barrier
Phyto-remediation Retained Experimental however there are no potential negative consequences in using the technology Low cost is a benefit
co i
IO
I (A O m OH 73 gtZ
MITEC 104e 02378
4 DETAILED ANALYSIS OF ALTERNATIVES
41 ALTERNATIVE 1 NO ACTION
The no-action alternative is included in accordance with EPAs Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA (EPA 1988) The no-action
alternative provides a baseline for comparison and involves taking no additional actions at the
Study Area This remedy assumes no continuing monitoring of dissolved concentrations in
groundwater surface water or concentrations in indoor air This remedy assumes no institutional
controls on basement sump venting at Lot 3-30 on South Browneil Road property no restrictions
on new buildings with basements set below the water table constructed within the area of VOC
concentrations in groundwater and no restrictions groundwater use for potable purposes within
the region of VOC-contaminated groundwater
411 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community The risk assessment completed for the SIR
(HSI GeoTrans 2000) concluded that current conditions at the Study Area do not pose a risk to
human health Current conditions include venting ofthe sump at Lot 3-30 on South Browneil
Road no buildings other than at Lot 3-30 with basements below the water table in VOC-
contaminated areas and no potable-use wells within the region of VOC-contaminated
groundwater Without institutional controls to ensure this there may be future risk The risk
evaluation indicated that concentrations in the unnamed brook resulting from contaminated
groundwater discharge while not above risk-based thresholds were close to levels that could
pose a risk to human health Therefore monitoring is advised to confirm that VOC
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7533000AUJNOFS9^010030929WPD 4 - 1 HSI GGOTrSOS jflC
MITEC 104e 02379
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of VOC-contaminated groundwater could result in health risks not
evaluated in the risk assessment
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative
Time to Achieve Remedial Action Objectives It is estimated that the time frame required
for natural attenuation of contaminants to meet the groundwater cleanup concentrations will
significantly exceed the two-year time frame used to evaluate short-term effectiveness
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment There is no treatment of contaminants under this option
Reduction in Toxicity Mobility or Volume Some reduction of residual DNAPL and
accompanying dissolved concentrations is expected through natural attenuation over time if no
action were pursued at the Study Area However no monitoring data would be available to
confirm the progress
Amount of Material Contained or Treated Natural attenuation may serve to contain the
entirety of the region of groundwater contaminated with dissolved VOCs
413 LONG-TERM EFFECTIVENESS
Residual Risk Therisk assessment completed for the SIR (HSI GeoTrans 2000)
concluded that current conditions at the Study Area do not pose a risk to human health
However the risk evaluation indicated that concentrations in the unnamed brook resulting from
contaminated groundwater discharge while not above risk-based thresholds were close to levels
that could pose a risk to human health Therefore monitoring is advised to confirm that VOC
FOR ALLING INDUSTRIAL PARK
M W P _ D O C S N 7 5 3 2 0 0 0 A L U N O F S W raquo I 0 0 3 0 9 2 9 W P D 4-2 HSI GeOTrdDS IflC
deg2380
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of contaminated groundwater could result in health risks not evaluated in
the risk assessment Without institutional controls to ensure basement sump venting at Lot 3-30
on South Browneil Road restrictions on new buildings with basements set below the water table
within the region of VOC-contaminated groundwater and prevention ofthe installation of wells
for potable supplies within the region of VOC concentrations in groundwater a residualrisk to
human health remains
Adequacy and Reliability of Controls This remedy does not assume the sump in the
basement ofthe residence at Lot 3-30 on South Browneil Road remains sealed and vented to the
outside and that the pump is maintained in operable condition to continue to keep groundwater
out ofthe basement Previous air sampling conducted by the VTDEC has confirmed that this is
necessary to control indoor air impacts to this residence This remedy relies on natural
attenuation to control the region of VOC-contaminated groundwater however there is no
continuing monitoring of dissolved VOC concentrations in groundwater Since monitoring to
date has not confirmed that the region of VOC-contaminated groundwater is not expanding in
size a remedy which has a natural attenuation component but does not include monitoring does
not provide adequate control
Permanence of Remedy In the very long-term natural gradient flushing should reduce
VOC concentrations in groundwater to acceptable levels
414 COMPLIANCE WITH ARARs
Groundwater Protection Rule and Strategy It is expected that natural attenuation would
over time reduce groundwater concentrations to below VT Groundwater Enforcement Standards
However a no-action response would not comply with VT Groundwater Protection Rule and
Strategy (VTDEC 1997) which allows for remediation of sites by natural attenuation if sufficient
monitoring is perfonned to document that expansion ofthe region of contaminated groundwater
is not occurring and that natural attenuation is occurring The no-action alternative would not
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AU1NGFS90010030929wro 4-3 HSI GSOTraFIS IflC
MITEC 104e 02381
allow for continued monitoring and would not meet this requirement
Surface Water Quality Standards It is expected that natural attenuation would over
time reduce surface water concentrations to below VT Water Quality Criteria for the protection
of human health and aquatic organisms (VTDEC 2000)
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
concentrations of VOCs adsorbed to soil and dissolved in groundwater in the Study Area do not
pose a risk to human health andor the environment under current uses There would be arisk if
groundwater within the region of VOC-contamination were used as a potable supply Therefore
if dissolved concentrations were not migrating beyond the limits ofthe region identified in the
SIR (HSI GeoTrans 2000) and groundwater were not used for potable purposes the no action
alternative would be protective of human health and the environment However there are not
sufficient data to determine whether the region of VOC-contaminated groundwater is stable or
decreasing in size If the region of contaminated groundwater were expanding beyond the limits
upon which the risk assessment was based there may be a future risk to human health and the
environment Also restrictions should be placed on properties overlying the region of VOC-
contaminated groundwater to prohibit construction of basements below the water table and the
use of groundwater as a potable supply and the venting ofthe sump at Lot 3-30 should continue
416 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000AlXINGFS900U0030929wro 4-4 HSI GGOTrdRS IflC
MITEC 104e 02382
Technical Feasibility The no-action alternative is technically feasible
bull Ability to Construct the Alternative The no-action alternative requires no
construction
bull Reliability ofthe Technology No technology would be applied under the no-
action alternative
bull Ease of Undertaking Additional Remedial Actions The no-action alternative
would not prevent future remedial actions
Administrative Feasibility The no-action alternative is administratively feasible
Availability of Services and Materials No services or materials are required to carry out
the no-action alternative
417 COSTS
There are no costs associated with the no-action alternative The no-action alternative is
shown on Table 41 for purposes of comparison
4 2 A L T E R N A T I V E 2 M O N I T O R I N G INSTITUTIONAL C O N T R O L S AND
H Y D R A U L I C C O N T A I N M E N T
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull institutional controls would be implemented to restrict construction of any
buildings with basements within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull groundwater extraction and treatment would be done to contain the region of
VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753laquo000WJJNoFS9JXI10030929wro 4 - 5 HSI GSOTraDS JllC
MITEC 104e 02383
Groundwater pumping is an effective technology for hydraulic containment of
contaminated groundwater Hydraulic containment can be used if the region of VOC-
contaminated groundwater is impacting a sensitive receptor or is expanding is size The risk
assessment (Menzie Cura 2000a and 2000b) showed that groundwater was not impacting any
receptors to a degree that would represent a human health risk or risk to the environment There
is not sufficient temporal data however to confirm that the region of VOC-contaminated
groundwater is not expanding is size Therefore an analysis of hydraulic containment has been
included in this Corrective Action Feasibility Investigation in the event that future monitoring
shows the region of VOC-contaminated groundwater is expanding and that containment is
necessary
If monitoring indicates that natural attenuation is not causing the region of VOC-
contaminated groundwater to be stable in size or to shrink then an active containment remedy
may be required Under this scenario a groundwater pump-and-treat system would be installed
and operated in the Study Area to hydraulically contain contaminated groundwater and prevent
expansion ofthe region of VOC-contaminated groundwater Pumping wells would be installed
in the overburden silts and sands to the clay layer Wells would be installed in the downgradient
portions of contaminated groundwater to the southeast and southwest Extracted groundwater
would be treated before discharge to surface water The primary treatment operation will be air
stripping with a low-profile stripper for the removal of VOCs primarily TCE Depending on
treatment efficiencies secondary treatment with granular activated carbon may be required In
addition a particulate filter may be added to remove iron prior to treatment and reduce iron
fouling ofthe air stripper and carbon Extracted and treated groundwater would be discharged to
surface water via an outfall Compliance sampling can be conducted at the outfall or at a
sampling point within the treatment building The outfall should be constructed to minimize
hydraulic impacts on the receiving water body
The number and location of pumping wells that may be required to capture and contain
the region of TCE-contaminated groundwater has been investigated using the two-dimensional
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9JXA10030929WO 4-6 HSI GSOTfanS IdC
MITEC 104e 02384
analytical element simulation code TWODAN (Fitts 1997) TWODAN is a commercially
available copyrighted program The input parameters to the model are based on the values
reported in the SIR (HSI GeoTrans 2000) Input data sets for the analyses contained in this
report are included in Appendix A The bottom elevation ofthe model is 306 ft which is
representative ofthe top ofthe continuous clay layer beneath the site The model represents the
interbedded silts and fine sand layer and the overlying medium to fine sand surficial unit as one
layer The hydraulic conductivity ofthe modeled layer is 184 ftday The estimated areal
recharge for the model is 10 inyr The basement sump at Lot 3-30 on South Browneil Road
pumps groundwater year round The resulting depression ofthe water table is represented by a
constant head of 33128 ft which is approximately 8ft below ground surface at that location
Groundwater elevations used in the model were based on an average ofthe July 1999 and
December 1999 potentiometric surface in wells with screened intervals intersecting the water
table The model representation of current hydrologic conditions at the Study Area is shown in
Figure 4-1 Groundwater elevations are shown in meters on this figure
Two containment scenarios were evaluated The first was a source control application in
which the TWODAN model was used to determine the number of wells and pumping rates
required to contain the 10000 to 20000+ ugL TCE concentration zone as shown in Figure 1-2
In this scenario pumping would contain the contaminated groundwater nearest the source(s)
Over time if new contamination is not allowed to migrate from the source(s) the VOC
concentrations in the rest ofthe region of contaminated groundwater would attenuate The
second scenario was a containment application in which the TWODAN model was used to
determine the number of wells and pumping rate required to contain the 1000 to 10000 (igL
TCE concentration zone as displayed in Figure 1-2 In this scenario pumping occurs in the
downgradient portions ofthe contaminated groundwater
Each recovery well was assumed to be 4 inches in diameter fully screened and have a
pumping rate of 5 gpm The pumping rate was based on the aquifer testing results reported in the
SIR (HSI GeoTrans 2000) applied to a fully screened extraction well The results ofthe model
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000A1XINOFS9JX)10030929WPD 4-7 HSI GSOTraDS IflC
MITEC 104e 02385
analyses indicate that a minimum of three 4-inch diameter recovery wells pumping at 5 gpm are
required to contain the 10000 to 20000+ ugL TCE concentration zone The results of this
model simulation are shown on Figure 4-2 The model analyses also indicated that a minimum
often 4-inch diameter recovery wells pumping at 5 gpm are required to contain the 1000 to
10000 ugL TCE concentration zone Figure 4-3 shows the results of this model simulation
Figures 4-2 and 4-3 also show that groundwater extraction for hydraulic containment may induce
infiltration of surface water in response to pumping thereby reducing the amount of water
flowing in the brook
421 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 2 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with extraction well construction and treatment plant construction Access by
unauthorized personnel would be restricted by fencing temporary barriers andor warning signs
The groundwater treatment building would be locked and secured A health and safety plan
(HASP) would be prepared for the remedial activities In conformance with Occupational Safety
and Health Administration (OSHA) regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative Suitable dust control measures would be implemented during
construction ofthe groundwater treatment system Additionally the treatment process is
expected to be relatively simple with a low potential for exceedance of discharge limitations
Monitoring ofthe treatment process would be performed
Time to Achieve Remedial Action Objectives The time estimated for well installation
system debugging and establishing hydraulic gradient control is three to six months The RAOs
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^XM0030929wro 4-8 HSI GSOTraOS IIIC
MITEC 104e 02386
for groundwater would be achieved when monitoring results indicated that VOC concentrations
had attenuated and groundwater standards had been met It is estimated that attenuation of VOC
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of recovered groundwater would remove some ofthe VOCs from
the aquifer This treatment would generate residuals such as used filters and spent carbon This
process is irreversible
Reduction in Toxicity Mobility or Volume Treatment ofthe extracted groundwater
would reduce its toxicity prior to surface water discharge Contaminants adsorbed to any
secondary carbon would ultimately be destroyed during the process of regenerating the carbon
Contaminants adsorbed to any particulate filters would be landfilled or incinerated along with the
filters The toxicity and volume of contamination in groundwater are nominally reduced by
extraction and treatment but effectiveness is limited as discussed in Section 421 above
Modeling shows that groundwater extraction would be effective in reducing the mobility ofthe
dissolved phase contamination
Amount of Material Contained or Treated The volume of contaminated groundwater
that would be treated on a long-term basis is estimated at about 8 million gallons per year for the
source containment option and about 26 million gallons per year for containment of all dissolved
TCE concentrations greater than 1000 ugl
423 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
FOR ALLING INDUSTRIAL PARK MWPJXXTSN75320(XAAUJNOFS9-OCM0030929WKgt 4-9 HSI GSOTrSDS IDC
MITEC 104e 02387
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Groundwater pumping would control any risks caused by expansion ofthe
region of contaminated groundwater Residual risk to human health would be controlled through
institutional controls
Adequacy and Reliability of Controls Extracted groundwater would be treated on-site to
standards required for discharge to surface water The extraction well pumps and groundwater
treatment equipment would require maintenance on a long-term basis Groundwater monitoring
to ensure that the contamination was being adequately contained by the groundwater extraction
would be necessary on a long-term basis
Permanence of Remedy The groundwater treatment plant would be enclosed and
designed as a modular system and its equipment would be readily replaceable if required The
extraction wells may need to be rehabilitated andor replaced during the life ofthe remedy
424 COMPLIANCE WITH A R A R S
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to return the
remaining groundwater to below Groundwater Enforcement Standards Groundwater extraction
would also eventually return the areas of highest groundwater contamination to below
Groundwater Enforcement Standards
Surface Water Quality Standards Hydraulic control of the groundwater migration would
interrupt and remove contaminates from groundwater thereby preventing discharge to the
unnamed brook resulting in achievement of Water Quality Criteria for the protection of human
health and aquatic organisms (VTDEC 2000)
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200OALUNoFS9^Kgtl0030929wro 4-10 HSI GOOTrSDS IDC
laquoTEC I04e 02388
425 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The hydraulic containment alternative would offer protection to both human health and
the environment if expansion ofthe region of contaminated groundwater were identified Since
the risk assessment (Menzie Cura 2000a) found that under current conditions groundwater and
surface water concentrations are below levels which constitute a risk to human health and since
hydraulic containment would ensure the region of VOC-contaminated groundwater remained in
the current configuration hydraulic containment would be protective of human health and the
environment This alternative assumes institutional controls will be in place to continue sump
venting in the basement at Lot 3-30 on South Browneil Road restrict the installation of
basements below the water table within the region of VOC-contaminated groundwater and
prevent potable use of groundwater within the region of VOC-contaminated groundwater
Protection would be achieved at the end ofthe construction period of three to six months The
residual risks posed by contaminated material remaining within the groundwater would not be
significant because all potential exposure routes would be addressed
426 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction which would present no special problems
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AUB4CFS9^10l0030929wro 4 - 1 1 HSI GGOTrdDS IDC
MITEC 104e 02389
bull Reliability ofthe Technology Hydraulic gradient control is a frequently used
alternative that has proven effective in preventing further expansion of areas with
- contamination in groundwater Filtration air stripping and carbon absorption
have frequently been used and proven effective in treating groundwater in other
applications
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the
gradient control system was inadequate to restrict the expansion ofthe region of
contaminated groundwater implementation of additional resources would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
operate maintain and monitor the well head portions ofthe treatment system Institutional
controls would also be needed to implement institutional controls to continue sump venting in
the basement at Lot 3-30 on South Browneil Road The town must pass zoning restriction which
would prevent construction of basements below the water table and potable use of groundwater
within the region of contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor the groundwater treatment system associated with the hydraulic containment option
are available
427 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 2 The
capital costs would be $207000 for the source control application and $732000 for the
containment option OampM costs include groundwater monitoring and maintenance ofthe
groundwater extraction and treatment system These are $77000 per year for the source control
application and $139000 per year for the containment option The present worth analysis
(calculated at a 7 discount rate interest for 30 years) yields a total of $1085403 for the source
control application and $2287474 for the plume containment option
FOR ALLING INDUSTRIAL PARK MWPJXXSN753U0OOALUNGFS9-tfW0030929wro 4-12 HSI GSOTrailS IRC
MITEC 104e 02390
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS AND
PERMEABLE REACTIVE BARRIER
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull and a permeable reactive barrier would be installed and maintained at a
downgradient location to reduce concentrations of TCE dissolved in groundwater
as it flows under natural gradient flow conditions if groundwater monitoring
shows the region of VOC-contaminated groundwater is expanding in size
PRBs consist of a permeable region of chemically reactive materials constructed to
intercept the path of a dissolved groundwater contaminants Reactive materials may include
bull zero-valent iron for reductive dehalogenation
precipitation agents such as gypsum to create insoluble metal salts
bull sorptive agents such as granular activated carbon to capture and immobilize organics
bull reducing agents such as dithionite and hydrogen sulfide to reduce and insolubilize metals
and
bull biologic electron acceptors such as lactic acid or nitrate to enhance aerobic
biodegradation
FOR ALLING INDUSTRIAL PARK MAWPJX)CSVN7532000AmNOFS9-OOU0030929wpo 4-13 HSI GSOTrSDS IDC
MITEC 104e 02391
Zero-valent iron and granular activated carbon are both applicable for use in the treatment
of TCE in a PRB Granular zero-valent iron has been widely applied in PRB installations and
promotes reductive dehalogenation of TCE to chloride ion ethane and ethene Activated carbon
has been used in a limited number of field and lab studies to simply adsorb dissolved organic
constituents as they pass through thePRB
Because ofthe costs ofthe reactive or adsorptive material PRBs are generally
constructed as a funnel and gate system The funnel portion ofthe PRB is a typical vertical
barrier wall constructed of sheet piles bentonite or other impermeable material which is
designed to direct groundwater flow to the gate portion ofthe PRB containing the reactive or
adsorptive material Funnel and gate sections ofthe PRB are keyed together and generally to a
low permeablility zone located at depth
The use of permeable reactive barriers is not directly applicable to treatment of DNAPL
The mechanism for groundwater remediation using a PRB would include
bull dissolution ofthe DNAPL into groundwater by natural processes
bull downgradient transport ofthe dissolved contaminants to the PRB location
artificial channeling ofthe contaminated groundwater to the reactive material located in
the gate by the barrier funnel and
bull reductive dehalogenation or adsorption of a portion ofthe VOC as is passes through the
gate
A variety of methods are available for emplacement ofthe PRB The most conventional
method includes excavation of a trench and backfill will a soilbentonite slurry for the funnel
portion and granular iron or carbon in the gate section Other methods such as sheet-piling jet
grouting continuous trenching fracturing and others are available For the subject site because
ofthe presence of sand in the formation it is likely that a continuous trenching method would be
the most applicable and cost effective
FOR ALLING INDUSTRIAL PARK MWPJX)CSN7S320O0ALUNGFSraquo-O0U0030929wro 4-14 HSI GGOTfaDS IOC
MITEC 104e 02392
Operation maintenance and monitoring ofthe PRB is relatively simple Groundwater
samples would be periodically collected from locations upgradient and downgradient ofthe gate
section(s) ofthe PRB to monitor its effectiveness Media installed in the gate (iron or carbon)
would require periodic replacement probably on a annual basis for carbon and every 5 to 10
years for iron
The placement depth width and length ofthe PRB would depend on the region of
VOC-contaminated groundwater that was desired to be intercepted the depth to the underlying
low permeability layer and the desired TCE concentration reduction (which determines resident
time required in the gate) As wilh hydraulic containment two scenarios were investigated The
first a source control option would intercept VOC-contaminated groundwater with TCE
concentrations greater than 10000 ugL A PRB of approximately 1200 feet in length would be
required The second a region of contaminated groundwater containment option would
intercept VOC-contaminated groundwater with TCE concentrations in excess of 1000 ugL A
PRB of approximately 2200 feet in length would be required The depth ofthe PRB in both
cases would likely extend from ground surface to about 40 feet below ground surface The PRB
would be installed into the underlying areally-extensive clay layer Figure 4-4 shows the
placement ofthe PRB under each opinion
431 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 3 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with PRB construction since either conventional or continuous trenching methods
would be employed during its construction However exposure hazards during construction
would be considerable since the emplacement requires excavation and handling of a large
volume of potentially contaminated soils During construction access by unauthorized personnel
would be restricted by fencing temporary barriers andor warning signs Following
FOR ALLING INDUSTRIAL PARK
MWP_DOCSN753 2000 AUJNCFS9^10 10030929 WPD 4-15 HSI GSOTrSPS IDC
MITEC 104e 02393
construction little to no hazards should be expected from the long-term operation ofthe PRB A
HASP would be prepared for the construction activities In conformance with OSHA
regulations site workers would be trained required to wear appropriate protective equipment
and as applicable would be enrolled in a medical monitoring program Groundwater monitoring
wells would be sampled to determine changes in VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative with proper controls Suitable dust control vapor monitoring and
stormwater runoff measures would be implemented during construction ofthe PRB
Time to Achieve Remedial Action Objectives The time estimated for PRB emplacement
is four to six months The RAOs for groundwater would be achieved when monitoring results
indicated that the VOC concentrations have attenuated and groundwater standards have been
met It is estimated that attenuation of contaminant concentrations to ARARS will significantly
exceed the two-year time frame for short-term effectiveness This is because the application of a
PRB at the site would not significantly alter groundwater flow or TCE dissolution from within
the source area Therefore it would not increase the rate at which concentrations of residual
DNAPL or dissolved constituents of DNAPL (TCE) were removed from the source area It
would however limit the size ofthe region of VOC-contaminated groundwater
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of groundwater flowing through the permeable sections ofthe PRB
would remove the dissolved TCE as is flows under natural gradient conditions from the source
area
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNGFS9^X)10030929WPO 4-16 HSI G G O T T S O S jflC
MITEC 104e 02394
Reduction in Toxicity Mobility or Volume Treatment ofthe groundwater would reduce
its toxicity Contaminants adsorbed to carbon (if used as the treatment media in the gate sections
ofthe PRB) would be excavated on a periodic basis and ultimately be destroyed during the
process of regenerating the carbon
Amount of Material Contained or Treated The volumetric flux of contaminated
groundwater through the PRB is estimated to be approximately two million gallons per year for
the 10000 (igL source containment option and approximately four million gallons per year for
containment of all dissolved TCE concentrations greater than 1000 ugL
433 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Treatment of groundwater intersecting the PRB would control any risks
caused by expansion ofthe region of contaminated groundwater to the southeast Residual risk
to human health would be controlled through institutional controls
Adequacy and Reliability of Controls Performance of PRBs in reducing concentrations
of chlorinated organics such as TCE using zero-valent iron has been mixed Most ofthe PRB
performance demonstrations indicate that a concentration reduction of 60 to 90 percent can be
expected Some applications however have been much less successful at reducing VOC
concentrations Although little experience is available for PRBs using activated carbon the
removal efficiency should be expected to be greater and more reliable than zero-valent iron but
far more costly Groundwater monitoring would ensure that the contamination was being
adequately contained by the PRB and would be necessary on a long-term basis
Permanence of Remedy Installation of a PRB would be considered a permanent remedy
although periodic maintenance and replacement of reactive material in the gate would be
required for both carbon and iron-based systems
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9^X)l0030929wro 4-17 HSI GGOTfSnS IDC
MITEC 104e 02395
434 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to reduce VOC
concentrations in the remaining groundwater to below Groundwater Enforcement Standards
Natural gradient flushing would also eventually reduce the areas of highest groundwater
contamination to below Groundwater Enforcement Standards
Surface Water Quality Standards VOC concentrations in groundwater discharging to the
unnamed brook would be reduced significantly Thus operation ofthe PRB would result in
achievement of Water Quality Criteria for the protection of human health and aquatic organisms
(VTDEC 2000)
435 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This downgradient containment alternative would offer protection to both human health
and the environment if VOC concentrations in groundwater discharging to the unnamed brook
were to increase or if the region of contaminated groundwater were to expand in size This
alternative assumes institutional controls will be in place to continue sump venting in the
basement at Lot 3-30 on South Browneil Road restrict installation of new basements below the
water table within the region of VOC-contaminated groundwater and prevent potable use of
groundwater within the contaminated region Protection relative to the risks posed by expansion
ofthe region of contaminated groundwater to the unnamed brook would be achieved at the end
ofthe construction period of four to six months The residual risks posed by contaminated
material remaining within the groundwater would not be significant because all potential
exposure routes would be addressed
FOR ALLING INDUSTRIAL PARK MWP JX3CSN753V2000AIXINOFS90Crl0O30929wPD 4-18 HSI GCOTtSHS IRC
MITEC 104e 02396
436 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
bull Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction Removal and handling of contaminated soils
presents potential risks to construction workers during construction which could
be minimized through health and safety controls
bull Reliability of the Technology Although many full-scale applications of this
approach have been conducted they have been relatively recent Long-term
reliability and effectiveness of PRBs has not been established
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the PRB
was inadequate to prevent expansion ofthe region of VOC-contaminated
groundwater implementation of additional resources would not be hampered by
this alternative
Administrative Feasibility Installing and maintaining the PRB will require access to
properties overlying the region of VOC-contaminated groundwater Additionally property
owner cooperation would be needed to operate maintain and monitor wells located upstream
and downstream ofthe gate sections ofthe PRB system Restrictions would also be needed to
implement institutional controls to continue sump venting in the basement at Lot 3-30 on South
Browneil Road restrict the construction of basements below the water table within the region of
VOC-contaminated groundwater and prevent potable use of groundwater within the region of
VOC contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UO(XAAUJNOFS9-O0 10030929 WPO 4-19 HSI GGOTrSMS IDC
MITEC 104e 02397
Availability of Services and Materials The materials equipment and personnel required
to design install and maintain the PRB are readily available
437 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 3 The
capital costs would be $572000 for the source control application and $1022000 for the
containment option OampM costs include groundwater monitoring and periodic replacement of
the permeable barrier These average $64000 per year for the source control application and
$112000 per year for the containment option The present worth analysis calculated at a 7
discount rate over a 30-year duration yields a total of $1277356 for the source control option
and $2248691 for the containment option
4 4 A L T E R N A T I V E 4 M O N I T O R I N G I N S T I T U T I O N A L C O N T R O L S AND
N A T U R A L A T T E N U A T I O N
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water
The chief mechanisms contributing to reduction of contaminant concentrations in
groundwater by natural attenuation include biotransformation dilution dispersion and discharge
through advective flow and volatilization (EPA 1998) Volatilization is not likely a major
mechanism at the Study Area since contaminated groundwater is located at depth below the
FOR ALLING INDUSTRIAL PARK
MWP_DOCSW7S3U000WXINoFS9-001003O929wro 4-20 HSI GGOTfaDS IDC
MITEC 104e 02398
water table A natural attenuation evaluation will be conducted to better identify the mechanisms
contributing to concentration reduction through natural attenuation Monitoring to be completed
for this evaluation is included in Section 62 EPAs Technical Protocol for Evaluating Natural
Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) was used as the basis for the
design ofthe natural attenuation evaluation
441 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community A HASP would be prepared for the remedial
activities In conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Groundwater monitoring wells would be sampled to determine changes in
VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative
Time to Achieve Remedial Action Objectives The RAOs for groundwater would be
achieved when monitoring results indicated that the region of contaminated groundwater had
naturally attenuated and groundwater standards had been met It is estimated that natural
attenuation of contaminants to ARARS will exceed the two-year time frame for short-term
effectiveness
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0ALUNOFS9^X)M0030929wro 4-21 HSI GGOTfaflS jflC
MITEC 104e 02399
Treatment This alternative involves only natural in-situ processes No remediation
wastes would be generated
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area
Amount of Material Contained or Treated Natural attenuation may serve to contain the
region of VOC-contaminated groundwater at the Study Area Treatment may be accomplished
through biotransformation ofthe contaminants to environmentally acceptable compounds
443 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation of VOC-contaminated groundwater at the Study Area
would eventually achieve the ARARs Residual risk to human health would be controlled
through institutional controls Implementing institutional controls to maintain the sump venting
at Lot 3-30 on South Browneil Road restrict the construction of basements below the water table
within the region of VOC-contaminated groundwater and to control the use of groundwater
within the region of VOC-contaminated groundwater for potable purposes would provide
protection against the potential for exposure
Adequacy and Reliability of Controls Monitoring for VOC concentration reductions in
groundwater and institutional controls would be the main controls of this alternative Sump
venting at Lot 3-30 on South Browneil Road would prevent indoor air impacts at this location
and restrictions on construction of basements below the water table would prevent future indoor
air impacts Control ofthe use of groundwater within the region of VOC-contaminated
groundwater for potable purposes would minimize potential use of groundwater with VOCs
above federal and state drinking water standards Groundwater monitoring would ensure that
attenuation of VOC concentrations was proceeding and provide for periodic assessment ofthe
region of VOC-contaminated groundwater in the Study Area
FOR ALLING INDUSTRIAL PARK bull MWPJXXSN7532000AUINOFS9-00I0O30929WPD 4 - 2 2 HSI GGOTPaMS IRC
MITEC 104e 02400
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time
444 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
445 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
446 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK _
M W P _ D O C S N 7 5 3 U O O O A L U N O F S 9 - O O U 0 0 3 0 9 2 9 W P O 4-23 HSI GGOT 13118 IflC
MITEC 104e 02401
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
bull Ability to Construct the Alternative No major construction is included in this
alternative
bull Reliability ofthe Technology Ongoing monitoring and evaluation on would
ensure that natural attenuation was controlling and remediating the contaminated
groundwater
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation was not restricting the size ofthe region of VOC-contaminated
groundwater implementation of additional remedial actions would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
sample and maintain monitoring wells Restrictions would also be needed to implement
institutional controls to continue sump venting in the basement at Lot 3-30 on South Browneil
Road restrict construction of basements below the water table in VOC-contaminated
groundwater and prevent potable use of groundwater within the region of VOC-contaminated
groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor natural attenuation are also available
447 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 4 The
capital costs would be $55000 and include the initial natural attenuation evaluation and the
implementation of institutional controls OampM costs include groundwater monitoring These are
$9000 per year The present worth analysis yields a total of $163083 for this 30-year
alternative
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0AUJNOFS9^X)10030929wro 4-24 HSI GGOTraDS 1110
MTECl04e 02402
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water and
phytoremediation would be used to intercept TCE-contaminated groundwater
where it discharges to the unnamed brook
In this alternative all components of Alternative 4 would be implemented and
phytoremediation would be implemented in the area where TCE- contaminated groundwater
intersects the unnamed brook to intercept the contaminated groundwater and reduce the amount
of VOCs reaching the brook Phytoremediation of VOCs is still an experimental technology
Several field studies have used hybrid poplars (EPA 2000) to extract TCE- contaminated
groundwater It has been shown that TCE is removed along with groundwater by the trees and
metabolized as well as transpired from the leaves The rate of TCE contaminant removal from
the groundwater and its discharge to air by transpiration varies based on site specific conditions
and season Therefore contaminant or groundwater removal rates are impossible to predict at
this time without field studies Trees may be subject to destruction by natural disasters and pests
Their condition must be monitored and they may require replacement
F O R ALLING INDUSTRIAL PARK MWPJXXSN7532OOOWXINGFS9JraquoIOO30929WPO 4 - 2 5 H S I G G O T r S D S IOC
MITEC 104e 02403
In order for interception ofthe region of contaminated groundwater to be effective the
trees must be planted so that the root zone intercepts the contaminated groundwater Due to the
depth ofthe higher VOC concentrations in most areas ofthe site phytoremediation would be
ineffective in containing expansion ofthe region of contaminated groundwater An exception to
this is the area near the unnamed brook According to the SIR (HSI GeoTrans 2000) VOC-
contaminated groundwater appears to be discharging upward in groundwater into the unnamed
brook Trees planted along the border ofthe brook may help to intercept this contaminated
groundwater before it discharges into the brook
451 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 5 are as follows
Protection of Workers and the Community Normal landscaping hazards would be
associated with installation ofthe trees A HASP would be prepared for the remedial activities
In conformance with OSHA regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative Suitable dust control measures would be implemented during
planting of trees
Time to Achieve Remedial Action Objectives The time required for maximum
interception ofthe contaminated groundwater by the trees would depend on site specific
conditions such as root growth rate and tree survival rate The RAOs for groundwater would be
achieved when monitoring results indicated that VOC concentrations had attenuated and
groundwater standards had been met It is estimated that natural attenuation of contaminant
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
FOR ALLING INDUSTRIAL PARK MWP J X 3 C S N 7 5 3 2 0 0 0 A U J N O F S 9 ^ ) 0 1 0 0 3 0 9 2 9 W P D 4-26 HSI G G O T H S I I S IDC
MITEC 104e 02404
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment This alternative involves only in-situ treatment ofthe groundwater Plant
tissue would be analyzed for the presence of VOCs Plant materials can bio-accumulate metals
present in soil and groundwater If concentrations are high enough dead plant matter may have
to be disposed in an appropriate manner
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area Phytoremediation may
metabolize some ofthe VOCs
Amount of Material Contained or Treated Natural attenuation and phytoremediation
may serve to prevent expansion ofthe region of VOC-contaminated groundwater at the Study
Area Treatment is accomplished with biotransformation ofthe contaminants to environmentally
acceptable compounds
453 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation ofthe region of VOC-contaminated groundwater and
phytoremediation at the Study Area would eventually achieve the ARARs Implementing
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil Road
restrictions on construction of basements below the water table in regions of VOC-contaminated
groundwater and to control the use of groundwater for potable purposes within the region of
VOC-contaminated groundwater would provide protection against the potential for exposure
FOR ALLING INDUSTRIAL PARK MWP_IXXSW532000ALL1NOFS9^)0I0030929WTO 4-27 HSI GCOTraDS IflC
M l T E C l 0 4 e 0240S
Therefore despite the fact that an extended time period may be required to reduce VOC
concentrations to an acceptable level the residual risk associated with this alternative would be
minimal Trees planted near the unnamed brook may serve to intercept contaminated
groundwater before it discharges to this receptor
Adequacy and Reliability of Controls Groundwater monitoring for natural attenuation
institutional controls and interception of contaminated groundwater before it reaches the
unnamed brook would be the main controls of this alternative Sump venting at Lot 3-30 on
South Browneil Road would prevent indoor air impacts at this location and restriction on the
construction of new basements below the water table within the region of VOC-contaminated
groundwater would prevent future indoor air impacts at other locations Control ofthe use of
groundwater for potable purposes within the region of VOC-contaminated groundwater would
minimize potential use of groundwater with VOCs above federal and state drinking water
standards Groundwater monitoring would ensure that natural attenuation of contaminants was
proceeding and provide for periodic assessment ofthe region of VOC-contaminated groundwater
in the Study Area Groundwater and surface water monitoring would also be conducted to
monitor success ofthe phytoremediation in intercepting contaminated groundwater before it
reaches the unnamed brook
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time Trees must be monitored and will be replaced in
the event of destruction by severe weather pests or other reasons
454 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUINOFS9-00I0030929WPD 4-28 HSI GGOTraflS IllC
MITEC 104e 02406
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
Phytoremediation at the edge ofthe unnamed brook would further reduce the VOC
concentrations in groundwater discharging to the brook
455 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
456 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
Ability to Construct the Alternative Installation of this alternative requires
landscaping skills which are readily available
bull Reliability ofthe Technology Ongoing monitoring and evaluation would ensure
that natural attenuation was controlling and remediating the contaminated
groundwater Ongoing monitoring ofthe condition ofthe trees would also be
required to ensure they are continuing to grow and do not need replacement
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^)OM0030929WPD 4-29 HSI GGOTfaDS jflC
MITEC 104e 02407
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation and phytoremediation were not restricting the size ofthe region of
VOC-contaminated groundwater implementation of additional resources would
not be hampered by this alternative
Administrative Feasibility Planting trees and if necessary installing and monitoring
additional wells might require access to private property Additionally property owner
cooperation would be needed to sample and maintain monitoring wells Restrictions would also
be needed to implement institutional controls to continue sump venting in the basement at Lot 3shy
30 on South Browneil Road restrict construction of new basements below the water table in
regions of VOC-contaminated groundwater and prevent potable use of groundwater within the
region of VOC-contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to plant the trees and monitor natural attenuation are also available
457 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 5 The
capital costs would be $80000 and include the initial natural attenuation evaluation the
implementation of institutional controls and installation of a phytoremedial barrier of poplars
OampM costs include groundwater monitoring and maintenance ofthe phytoremedial barrier
These are $11000 per year The present worth analysis yields a total of $209397 for this 30shy
year alternative
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000ALLINOFS9^)0I0030929WPD 4-30 HSI GGOTfaDS IPC
MITEC 104e 02408
r TI Table 41 Cost estimates for remedial alternatives i deg 5 70
8 P
QUANTITY UNITS UNIT C O S T CAPITA L C O S T ANNUAL
OampM C O S T
5 n Alternative I No Action 8 O a Q
na na $0 $0 $0 a sect
Total $0 $0
Alternative 2 Monitoring Institutional Controls and Hydraulic Containment
1) Implement Institutional Controls 32 properties $10000 $32000
2) Groundwater Monitoring $9000
3) Pumping System
Option 1 Source Containment
Extraction wellspiping $50000 $15000
Electrical distributioncontrol $25000 $8000
Construction oversight $25000
Groundwater treatment system $75000 $45000
Total Option 1 $207000 $77000
Option 2 region of contaminated
groundwater Containment
Extraction wellspiping $175000 $35000
w Electrical distributioncontrol $50000 $20000
O
o H mO Construction oversight $125000
o n gt Groundwater treatment system $350000 $75000
o z 0) Tolal Option 2 $732000 $139000
i deg QUANTITY UNITS UNI T C O S T
5 so
Alternative 3 Monitoring Institutional Controls and Permeable Barrier
m t - 1) Implement Institutional Controls 32 properties $10000
9 O 2) Groundwater Monitoring
| o 3) Permeable Harrier
Option I Source Containment
Barrier installation 1200 feel $450
Total Option 1
Option 2 region of contaminated
groundwater Containment
Barrier Installation 2200 feet $450
w Total Option 2 NJ
Alternative 4 Monitoring Institutional Controls and Natural Gradient Flushing
1) Implement Institutional Controls 32 properties $10000
2) Groundwater Monitoring
3) Natural Attenuation Evaluation
Total
Alternative 5 Monitoring Institutional Controls Natural Gradient Flushing and Phytoremediation
1) Implement Institutional Controls 32 properties $10000 X (A 2) Groundwater Monitoring
reg 3
o m O H
3) Natural Attenuation Evaluation
4) Phytoremediation
gt z Total (A
Notes na = not applicable
CAPITAL C O S T
$32000
$540000
$572000
$990000
$1022000
$32000
$23000
$55000
$32000
$23000
$25000
$80000
ANNUAL
OampM C O S T
$9000
$55000
$64000 1
$103000
$112000
$9000
$9000
$9000
$2000
$11000
MODEL CALCULATED GROUNDWATER CONTOUR IN FEET ABOVE MEAN SEA LEVEL
APPROXIMATE PROPERTY BOUNDARY
M6-2 raquo EXISTING MONITORING WELL
CP-6 bull EXISTING SOIL BORING
M 8 - 2 raquo MONITORING WELL (RESAMPLED)
bull SMALL DIAMETER BORING - BELOW CLAY
bull BEDROCK MONITORING WELL
A S I - 2 I H S I GEOTRANS WELL CLUSTER LOCATION
U-TRIB-8a SURFACE WATER SAMPLING LOCATION R S - U
a PASSIVE SAMPLER LOCATION
T2-2 PROFILE SAMPLE LOCA1ION (JOHNSON COMPANY 1999)
WELL DESTROYED
TEF Concentrat ions ( u g A l
1000 - 10000
iry IOOOO - 20000
bull 20000 + NOTES AREA WHERE TCE CONCENTRATION IS
M l LOCATIONS APPROXIMATE INTERPOLATED THERE IS NO TCE
BASE PUN DEVELOPED FROM DATA FROM THESE AREAS
1 TOWN OF WUUSION PARCEL BOUNOART MAP (SHIPPED 121597) PROVIDED ST (VS (BURUNCTON VT) IN DXF FORMAT
2 PLAN DEVELOPED BT HEINDEL AND NOTES (BURUNCTON VT) FOR THE BATES PROPER1Y 1NVESIBAT10N AND PROVIDED TO THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION HASTE MANAGEMENT DIVISION 1997
3 ORTHOPHOTO SHEET 100216 VERMONT STATE MAPPING PROJECT 1988
4 TORN OF WIUJSTON ASSESSORS MAP 1997
5 VARIOUS SITE PUVQ CN RLE WITH THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION WASTE HMUGElENr OOVBON
6 DM FROM JOHNSON DD REPORT UNTIED GROUNDWXIER IHVESI1CAH0M ALLWC INDUSTRIAL PARK DATED 7 W FDR THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Modeled Site - Existing Conditions copy H
pound n Williston Vermont o CHECKED MS HSI
DRAFTED RMK GEOTRANS FU fa-Site-mod-ECdwg 4 - 1 A TITIA T t n HBVAIT
DATE 10600
5 COMPARATIVE EVALUATION OF ALTERNATIVES
The purpose of this section is to compare the remedial alternatives on the basis ofthe
evaluation criteria developed and discussed in Section 4 and provide a recommended alternative
These criteria include overall protection of human health and the environment short-term
effectiveness reduction of toxicity mobility or volume long-term effectiveness and
permanence compliance with ARARs implementability and cost
The comparative analysis is conducted to highlight significant differences between
identified alternatives All alternatives for the Study Area groundwater except the no-action
alternative include the following
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater and
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
The no-action alternative is not included in the comparison provided in the following
sections since it would not meet the RAOs All four ofthe remaining alternatives would meet
the RAOs stated in Section 32
51 SHORT-TERM EFFECTIVENESS
Protection of Workers and the Community Groundwater would be monitored under all
scenarios to look for any changes in VOC concentration which might result in increased risk
The containment options in Alternatives 2 3 and 5 would be more protective ofthe community
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320MAUINOFSWWI0030929WPD 5 - 1 HSI GSOTrSflS IflC
MITEC 104e 02415
if the region of VOC-contaminated groundwater were shown to be expanding and presenting
increased risk However in the event that the region of VOC-contaminated groundwater is not
expanding Alternative 4 would be equally protective Under all options a HASP would be
prepared and in conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Alternatives 2 3 and 5 would involve normal construction hazards during
installation of pumping wells piping trenches treatment enclosures permeable reactive barrier
trenches or planting of trees In addition under Alternative 5 release of VOCs to air through
transpiration may need to be measured to prevent creation of a new exposure pathway and health
risk through air
Environmental Impacts Minor additional impacts may occur during installation of
Alternatives 2 3 and 5 due to dust and sediment production Groundwater would need to be
treated to regulatory discharge limits before discharge under Alternative 2 and treatment may be
temporarily hampered in the event of treatment system mechanical failure Because ofthe
experimental nature of phytoremediation greater uncertainty exists that the trees will be effective
in acting as a barrier to expansion ofthe region of contaminated groundwater to the unnamed
brook under Alternative 5 If it is shown that expansion ofthe region of contaminated
groundwater toward the unnamed brook poses a future health risk additional measures may
become necessary to contain the contaminated groundwater
Time to Achieve Remedial Action Objectives None ofthe alternatives has an appreciably
shorter time frame than the others in reducing groundwater concentrations to VT Groundwater
Enforcement Standards and VT Water Quality Criteria This is because while Alternatives 2 3
and 5 rely on engineered remedies to contain the region of contaminated groundwater residual
TCE DNAPL and geologic heterogenieties will cause the contaminant source to persist for an
extended time As discussed in Section 34 active DNAPL removal alternatives were removed
during the preliminary screening DNAPL has never been directly observed at the Study Area
and is assumed to be present based on dissolved concentrations of TCE DNAPL distribution is
FOR ALLING INDUSTRIAL PARK MWP_DOCSW753200OALLINOFS9-00M0O30929wPD 5-2 HSI GGOTr3nS IflC
MITEC 104e 02416
expected to occur heterogeneously at residual saturation and it is infeasible to locate the DNAPL
to treat it directly Because of this each ofthe remedies is expected to exceed the two-year time
frame for short term effectiveness
52 R E D U C T I O N O F T O X I C I T Y M O B I L I T Y O R V O L U M E T H R O U G H
T R E A T M E N T
Treatment All ofthe proposed alternatives would treat the residual DNAPL source of
contamination through dissolution and natural gradient flushing While Alternatives 2 3 and 5
are intended primarily for containment and not groundwater restoration these alternatives would
actively treat some concentrations in groundwater
Reduction in Toxicity Mobility or Volume The containment Alternatives 2 3 and 5
may result in decreased mobility ofthe region of contaminated groundwater However
groundwater monitoring may show that the region of contaminated groundwater is not
expanding under existing conditions If this were the case containment would not result in any
additional decrease in size ofthe region of VOC-contaminated groundwater
Since Alternatives 2 3 and 5 treat concentrations in groundwater without treating the
residual DNAPL source and the amount of contaminants that can be removed from groundwater
by these methods would likely equal the amount added by continued dissolution ofthe DNAPL
sources alternatives 2 3 and 5 would not result in a greater reduction in the total volume of
contaminant than Alternative 4
Amount of Material Contained or Treated As described above the amount of material
contained under Alternatives 2 3 and 5 would not be any greater than under Alternative 4 unless
the size ofthe region of VOC-contaminated groundwater is not presently contained by natural
attenuation If natural attenuation is currently controlling the size ofthe region of VOC-
contaminated groundwater then the amount of contaminants being removed by natural processes
equals the amount added by dissolution of residual DNAPL In this case intercepting and
removing contaminants from the groundwater using one ofthe containment alternatives will not
result in a significant increase in the amount of contaminant treated
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000ALUNOFS9-OOUM30929WPD 5-3 HSI GGOTrdHS jflC
MITEC 104e 02417
53 LONG-TERM EFFECTIVENESS
Residual Risk Implementing institutional controls to maintain the sump venting at Lot 3shy
30 on South Browneil Road to restrict construction of buildings with basements below the water
table within the region of VOC-contaminated groundwater and to control the use of groundwater
for potable purposes within the region of VOC-contaminated groundwater would provide
protection against the potential for exposure to existing concentrations in groundwater
Therefore despite the fact that some ofthe remedial alternatives may be required to operate for
an extended time the residual risk associated with any ofthe alternatives would be minimal
Adequacy and Reliability of Controls Alternative 5 has the least reliable controls
because ofthe difficulty in predicting the effectiveness of phytoremediation The second least
reliable alternative would be Alternative 2 because of its reliance on mechanical equipment to
maintain containment and to meet discharge standards
Permanence of Remedy All ofthe proposed alternatives would rely on permanent
destruction of contaminants through natural attenuation over time If one ofthe containment
technologies are required maintenance and periodic replacement would be necessary to ensure
containment was maintained until expansion ofthe region of VOC-contaminated groundwater
was no longer a threat This maintenance would be straight-forward and easy to continue for any
of the containment alternatives
54 COMPLIANCE WITH ARARs
All ofthe alternatives would eventually reduce contaminant concentrations within the
current region of contaminated groundwater to below VT Groundwater Enforcement Standards
and VT Water Quality Criteria
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Each ofthe alternatives would rely on groundwater monitoring and institutional controls
on venting basement sumps at Lot 3-30 on South Browneil Road restrictions on the construction
of new basements below the water table within the region of VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWPJX3CSN7S3UOOOAUJNGFS9-OOUM30929wro 5-4 HSI GOTr3nS IflC
MITEC 104e 02418
and potable use of groundwater from within the region of VOC-contaminated groundwater to
maintain conditions protective of human health and the environment If monitoring shows that
natural attenuation is not restricting the size ofthe region of VOC-contaminated groundwater
then one ofthe containment alternatives would be more protective than Alternative 4
56 IMPLEMENTABILITY
The most easily implemented alternativewould be Alternative 4 as it would not require
any installation but only groundwater monitoring to gauge the progress of natural attenuation
Alternative 5 requires all the components of Alternative 4 and adds trees along the unnamed
brook Alternatives 2 and 3 are the most difficult to implement as they require disruptive and
invasive installation techniques However the necessary equipment materials workers and
specialists required to implement all the alternatives are available
57 COSTS
The present worth costs range form a low of $163083 for Alternative 4 to a high of
$2287474 for the containment option of Alternative 3 These present worth costs were based on
a 30-year service period and an annual discount rate of seven percent
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALLINOFS9-OOM0030929WPD 5-5 HSI GGOTfaDS IflC
MITEC 104e 02419
6 PREFERRED REMEDY
61 PREFERRED REMEDY
Alternatives 2 34 and 5 are all protective of human health and the environment and rely
on the following technologies
bull groundwater monitoring to evaluate spatial and temporal trends in VOC
concentration
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil
Road
restrictions on the construction of new buildings within the region of VOC-
contaminated groundwater to prevent unacceptable concentrations of volatile
compounds in indoor air and
institutional controls to restrict the use of groundwater for potable purposes within
the region of VOC-contaminated groundwater
All ofthe alternatives rely on dissolution and natural gradient flushing to treat the
residual DNAPL source of groundwater contamination Therefore none ofthe alternatives has
an appreciably shorter time frame than the others in reducing groundwater concentrations to VT
Groundwater Enforcement Standards and VT Water Quality Criteria
Alternative 4 includes remediation by natural attenuation There is no active containment
technology associated with Alternative 4 As such it is simpler less costly and easier to
implement than Alternatives 2 3 and 5 which include some form of active containment ofthe
region of VOC-contaminated groundwater Containment could become necessary under
Alternative 4 if future groundwater quality monitoring indicates the region of VOC-contaminated
groundwater is impacting a sensitive receptor or is expanding in size and not contained by natural
attenuation The SIR (HSI GeoTrans 2000) risk assessment (Menzie Cura 2000a and 2000b)
showed that under current conditions groundwater was not impacting any receptors to a degree
FOR ALLING INDUSTRIAL PARK MWPJXXrSN7532000ALUNcFS9-OOU0030929WO 6 - 1 HSI GSOTraflS jflC
MITEC 104e 02420
that would represent a human health risk or risk to the environment Therefore containment is
not necessary to protect any sensitive receptors currently being impacted by the region of
contaminated groundwater Continued groundwater monitoring is required to demonstrate
whether the region of VOC-contaminated groundwater is stable in size or expanding
Alternative 4 has been selected as the preferred remedy On-going monitoring ofthe
effectiveness of natural attenuation in containing and remediating the region of VOC-
contaminated groundwater is part ofthe remedy Further details on this proposed monitoring are
provided in Section 62 If monitoring shows that size ofthe VOC-contaminated region is not
contained by natural attenuation then one ofthe other technologies could be used to supplement
Alternative 4 based on the nature ofthe expansion ofthe region of contaminated groundwater
If monitoring data indicates that VOC concentrations in the groundwater discharging to the
unnamed brook have increased and pose an unacceptable risk to human health and the
environment then phytoremediation could be considered in this location Phytoremediation
would be less costly than installation of a permeable reactive barrier or active groundwater
extraction system Phytoremediation would be ineffective in containing expansion ofthe region
of contaminated groundwater in the rest ofthe Study Area however because contaminated
groundwater is further below ground surface in these regions and phytoremediation is limited by
the depth ofthe roots ofthe selected plant If monitoring data indicates that the southwestern
portion ofthe region of VOC-contaminated groundwater is expanding then Alternative 4 could
be supplemented with extraction wells or a PRB for hydraulic containment
62 MONITORING PROGRAM
In its guidance document Use of Monitored Natural Attenuation at Superfund RCRA
Corrective Action and Underground Storage Tank Sites (EPA 1999) EPA states that long-term
performance monitoring will be a fundamental component of any remedy which relies on
monitored natural attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000 A1XINOFS9-00 I0030929 WPO 6-2 HSI GSOTrSDS IMC
MITEC 104e 02421
The SIR (HSI GeoTrans 2000) concluded that there were not sufficient temporal data to
determine whether the region of VOC-contaminated groundwater was stable in size or
expanding Continued monitoring for the compounds of concern will be necessary to confirm
that the region of VOC-contaminated groundwater is not expanding Table 6-1 identifies
locations which are proposed to be monitored annually to evaluate spatial and temporal trends in
VOC concentration These locations are shown in Figure 6-1
There are several mechanisms by which natural attenuation occurs These include
dilution of contaminant concentrations sorption ofthe contaminant onto the soil matrix and
biodegradation ofthe contaminant to a less toxic form Further study is necessary to determine
the contribution of each of these mechanisms to overall attenuation ofthe area of VOC
contamination
Evidence of biodegradation can be obtained by collecting three types of data of increasing
complexity (National Research Council 1993)
bull documentation of contaminant loss or transformation in the field
bull the presence of electron donors and acceptors andor alteration of groundwater
chemistry consistent with intrinsic biodegradation processes and
microcosm studies which provide direct microbiological evidence that indigenous
bacteria are capable of mediating the contaminant transformations observed
Microcosm studies are typically not employed unless the contaminant is unique or the
transformation which is being observed is not well documented in the literature For the
transformations anticipated in the Study Area numerous laboratory and field studies have
established that naturally-occurring bacteria are capable of mediating the contaminant
transformations of contaminants of concern For that reason microcosm studies will not be
performed as part of this study
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^)OM0030929 WPO 6-3 HSI GSOTrSHS jflC
MITEC 104e 02422
Of particular concern to the determination of biodegradation is the delineation of aerobic
and anaerobic zones within the contaminant area because these zones dictate the types of
biological degradation that would be expected to occur Oxygen is the primary electron acceptor
during aerobic oxidation Anaerobic processes including denitrification iron-reduction sulfate-
reduction and methanogenesis occur in the absence of oxygen and use nitrate iron (III) sulfate
and carbon dioxide respectively as primary electron acceptors Reductive dehalogenation of
TCE has been observed under iron-reducing sulfate-reducing and methanogenic conditions
although very low redox (ie methanogenic) conditions may be necessary for production of
ethene and ethane
Further sampling and analysis of selected parameters in groundwater will be conducted to
assess the potential for biodegradation in accordance with EPAs Technical Protocol for
Evaluating Natural Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) The
twelve sampling locations shown in Table 6-1 used to monitor ofthe area of VOC contamination
will also be sampled for parameters used to evaluate biodegradation The parameters include
compounds of concern and compounds which are degradation products ofthe compounds of
concern shown in Table 6-2 Table 6-3 lists parameters chosen to evaluate the presence of
electron donors and a groundwater chemical environment conducive to biologic reductive
dechlorination These parameters will be sampled once unless evaluation ofthe data indicates
that further sampling would be beneficial to calculate a rate of attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000ALUNCFS9JraquoM0030929 WPD 6-4 HSI GSOTfaHS IDC
MITEC 104e 02423
Table 6-1 Sampling locations
LOCATION
ID
ASI-32D2
RB-1
ASI-26D2
ASI-I6D2
ASI-13D2
ASI-23D2
ASI-18D2
ASI-12D2
ASI-01D2
ASI-09D2
U-TRIB-5
SW-I
Notes BGS =
SCREENED
INTERVAL
DEPTH BGS
35-40
35-40
35-40
30-35
31-36
25-30
32-37
35-40
31-36
31-36
surface
surface
Below Ground Surface
RATIONALE
Upgradient of region of highest VOC concentrations
Closest to lot 19-11 former lagoon and septic leach field source areas
Within area of highest concentrations
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient ofthe region of VOC concentrations in the southwest direction
Downgradient of source area within region of VOC concentrations in southeast direction
Downgradient of source area within region of VOC concentrations in southeast direction
At downgradient edge of region of VOC concentrations in southeast direction
Stream upgradient of VOC discharge from groundwater
Stream at location of VOC discharge from groundwater
(
FOR ALLING INDUSTRIAL PARK MWP DOCSN7532000ALUNCFS9^X)VI0030929WPO 6-5 HSI GeoTrans inc
MITEC 104e 02424
Table 6-2 VOC analytes
PARAMETER
TCE
PCE
11-DCE
cis 12-DCE
trans 12-DCE
Vinyl Chloride
Benzene
Toluene
Ethylbenzene
Xylenes
ANALYTICAL METHOD
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
8260A
8260A
8260A
8260A
RATIONALE |
Contaminant of Concern
Contaminant of Concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
Notes SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical
Methods SW-846 US EPA 3ri edition 1986
TCE = Trichloroethene
PCE = Tetrachloroethene
11-DCE = 11-Dichloroethene
cis 12-DCE = cis 12-Dichloroethene
trans 12-DCE = trans 1 2-Dichloroethene
FOR ALLING INDUSTRIAL PARK MAWP DOCSN75320laquoMLUNOFS9^XM0030929WPO 6-6 HSI GeoTrans inc
MITEC 104e 02425
Table 6-3 Parameters to evaluate biodegradation
PARAMETER ANALYTICAL METHOD RATIONALE
Field Parameters
Alkalinity as CaCO Hach Alkalinity Test Kit Model ALP Positive correlation between microbial activity and
MG-L alkalinity Measures the buffering capability of
groundwater
Total Ferrous Iron Hach Method 8146 May indicate anerobic degradation
Dissolved Hydrogen Reducing Gas Detector Predicts possibility for reductive dechlorination
Dissolved Oxygen Direct Meter Reading Indicates probability of aerobic vs aerobic
degradation
PH Direct Meter Reading Aerobic and anaerobic biological processes are pH
sensitive
Redox potential (Eh) A2580B An indicator ofthe relative tendency of a solution
to accept or transfer electrons
Specific Conductivity Direct Meter Reading Used to determine when purging of a well for
sampling is complete
Temperature Direct Meter Reading Affects the metabolic activity of bacteria and the
solubility of dissolved gasses
Laboratory Analyses
Dissolved Organic Carbon SW 9060 Carbon and energy source which can drive
dechlorination
Nitrate-N IC Method E300 At higher concentrations may compete with
reductive pathway
Total Manganese EPA 2007 or 2009 To determine if anaerobic biological activity is
solubilizing Mn for the aquifer matrix
Chloride SW 9250 Can be used as a conservative tracer to estimate
biodegredation rates
Sulfate IC Method E300 May be used as an electron acceptor for
biodegradation after dissolved oxygen and nitrate
are depleted
Sulfide IC Method E300 Indicates if reductive pathway is possible
Ethane SW 3810 Modified Daughter product of Ethene
Ethene SW 3810 Modified Daughter product of Vinyl Chloride
Methane SW 3810 Modified Ultimate reductive daughter product
Notes Rationales taken from USEPA 1998
Hach refers to Hach Company Catalogue
A refers to Standard Methods for the Examination of Water and (fostewater 18 edition 1992
E refers to Methods for Chemical Analysis of Water and Wastes US EPA 1983
SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical Methods SW-846 US EPA 31 edition
1986
FOR ALLING INDUSTRIAL PARK | C I nr A^Twmrmr bullbullltlaquo MWP DOCSN7532000ALLINCFS9-0Ol0030929wro 6-7
MITEC 104e 02426
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REFERENCES
Brinkerd 1996 Site Investigation Ailing Industrial Park Williston Vermont April to
September 1996 October 1996
Fitts C R 1997 TWODAN documentation prepared by Dr Charles Fitts Scarborough Maine
Griffin 1995 Monitor Well Log (MW-4) and Analytical Data Bove-Fagan Ice Cream
Distribution Investigation Williston VT Griffin International Inc
HSI GeoTrans Inc 2000 Site Investigation Report June 15 2000
Johnson 1999 Limited Groundwater Investigation N753 July 6 1999
Menzie Cura 2000a Screening Level Risk Characterization April 2000
Menzie Cura 2000b Addendum to Screening Level Risk Characterization June 1 2000
NRC 1993 National Research Council Committee on Bioremediation In Situ Bioremediation
When Does it Work Washington DC National Academy Press 1993
TRC 1993 Site Inspection-Ailing Industrial Park Williston Vermont VTD982748477 Final
Report
US EPA 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies
Under CERCLA OSWER Directive 93553-01
U S EPA 1992 Estimating Potential for Occurrence of DNAPL at Superfund Sites OSWER
Number 93554-07FS 9p
FOR ALLING INDUSTRIAL PARK MWP_DOCSW75JV20(XKALUNOFS9-0(AI0030929WPD 7 - 1 HSI GeOTTSHS irtC
MITEC 104e 02428
US EPA 1993 Guidance for Evaluating the Technical Impractibility of Groundwater
Restoration EPA540-R-93-080
US EPA 1998 Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents
in Ground Water EPA600R-9812~8
US EPA 1999 Use of Monitored Natural Attenuation at Superfund RCRA Corrective Action
and Underground Storage Tank Sites EPA Directive 92004-17P
US EPA 2000 Introduction to Phytoremediation EPA600R-99107
VTDEC 1996 Site Investigation Guidance August 1996
VTDEC 1997 Chapter 12 Groundwater Protection Rule and Strategy October 1997
VTDEC 2000 Vermont Water Quality Standards March 2000
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(AAUJNGFS9^)OM0030929WPD 7-2 HSI GSOTfanS tC
MITEC I04e 02429
APPENDIX A
TWODAN INPUT FILES
FOR ALUNG INDUSTRIAL PARK MWP_DOCSVN7S3200(AALUNOFS9-0(AI0030929WPO HSi GfiOTfanS WC
MITEC 104e 02430
i - i i a a o U 0 t A X H i d t l Z 018J UaiUEAJJLKATia Htj v j pound
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MITEC 104e 02431
15
6 Lancaster County Road HSI Harvard Massachusetts
GEOTRANS 01451 A TETRA TECH COMPANY 97^772-7557 FAX 978-772-6183
R E C E i ^ D PNN753-001
CUTLER A8TANPIELD Campltf December 11997
Mr Michael Smith Vermont Department of Environmental Conservation Waste Management Division 103 South Main Street Waterbury VT 05671-0404
Subject Proposed Surface Water Sampling MITEC Site Williston VT
Dear Michael
This letter describes the proposed surface water sampling at the MITEC site that we discussed during our meeting of November 201997 Our intention is to complete this work as soon as possible to avoid the complications of colder weather and possible freezing ofthe stream My understanding is that you are prepared to review and approve this plan fairly quickly and also to assist us with obtaining property access and appropriate maps to locate these sampling sites We appreciate this help In future we anticipate that the constraints of weather will not require such an expedited field mobilization process and that we will all have more time to prepare
Purpose and Extent of Sampling
The purpose ofthe surface water sampling is to further assess impacts to the unnamed tributary and to make preliminary inferences regarding the extent ofthe TCE plume currently migrating to the southeast across the Ailing Industrial Park by measuring the effects of its discharge to the stream To this end sampling locations have been chosen to 1) provide better spatial resolution in the area east of Commerce Street toward its southern end (SW-1 SW-2 SW-3 and S W-5) 2) assess the quality of surface water contributed by other tributaries (SW-4 SW-6) and 3) make preliminary estimates ofthe downgradient extent of impacts (SW-7 and SW-8) Samples from previously established sampling locations UTrib-6 7 8 1014 and 18 will also be obtained A total of 14 samples will be collected The proposed sampling locations
L-W7jni20iiooonl
MITEC 104e 02432
Michael Smith 2 December 11997
are indicated on the attached maps which depict the site at two different scales The first is a site map taken from the Binkerd report and shows the previous sampling locations east of Commerce Street as well as proposed new locations SW-1 SW-2 and SW-3 The second map shows the site and the surrounding area including the more downstream locations
Methods
At each proposed location a number of water quality indicators will be measured including temperature pH redox potential dissolved oxygen and conductivity Samples for volatile organic compound (VOC) analysis will be obtained in triplicate using a stainless steel sampling container samples will be transferred immediately to 40 mL glass vials with teflon septa and preserved with hydrochloric acid Each sample will be submitted to a local analytical laboratory for a screening level analysis of VOCs Three selected samples will also be analyzed using EPA Method 8260 The appropriate level of documentation will be generated for these samples such that laboratory analytical results can be validated to EPA Region 1 level Tier II This will require the collection and analysis of a duplicate sample a trip blank a field blank and matrix spikematrix spike duplicate samples
Sincerely
f i t mdash Peter ZeebPhD Senior Hydrogeologist
cc Sandy Feldman Sheila Jones
PZmm
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HSI GEOTRANS
LEGEND O Honrtorog Veil
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Figure 11 Station location map O Surface Water
Qfor monitoring wells borings and surface water MITEC 104e
02434
HD BINKERD ENVIRONMENTAL
HSI bull bull
GEOTRANS if prsTAOC
6 Cancaster County Road
A TETRA TECH COMPANY
Harvard Massachusetts 01451 faL32 HMETER 3 4 r t
Sheila Jones Esq Cutler and Stanfield 700 Fourteenth Street NW Washington DC 200052010
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Harvard Massachusetts 01451 GEOTRANS
A T E T R A T E C H C O M P A N Y 978-772-7557 FAX 978-772-6183
PN N753-002
May 111999 RECEIVED
MAY t 3 1999 Mr Michael Smith
CUTLER ampSTANrlc-uAgency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Dear Mike
Based on the site walkover and well inventory ofthe existing monitoring well network completed on April 201999 HSI GeoTrans determined that several monitoring wells proposed for sampling and monitoring in the Work Plan are not accessible or are damaged or missing Outlined below are the actions we will undertake to resolve the outstanding issues with the monitoring well network
As ofthe date of this letter access to the Bates well network has not been obtained The Work Plan identified eleven off property well clusters installed by the Bates and two wells installed by the State on the Bates property to be included in the sampling and monitoring activities for the Site Investigation (BW-2 BW-5 BW-7 BW-8 BW-9 BW-11 BW-12 BWshy13 BW-17 BW-18 BW-19) Ten ofthe off property clusters were included in the sampling plan and all eleven were included in the site water level round The wells installed by the State on the Bates property were included in the both sampling and water level rounds Replacement of eight ofthe well clusters slated for groundwater sampling is recommended (BW-5 BW-8 BW-9 BWshy12 BW-13 BW-17 BW-18 BW-19) The remaining Bates wells do not require replacement in order to achieve the goals ofthe Site Investigation Note that two ofthe original well clusters in the Work Plan BW-17 and BW-18 have been destroyed and would require replacement even if access is granted by Bates In addition HSI GeoTrans well clusters had already been proposed adjacent to BW-2 BW-7 and BW-11 and will provide the required data at these locations
It is our understanding that the two monitoring wells installed by the State on the Bates property JB-1 and JB-2 are accessible to the State for sampling and water level monitoring and that the State will sample and monitor these wells to fulfill the goals ofthe Site Investigation IF this is not the case please let me know at your earliest convenience
M WP DOCS NT^VWMiSimbW wpd
MITEC 104e 02438
Mr Michael Smith 2 May 11 1999
Several ofthe remaining wells (BF-1 BF-3 NO-2 and OE-1) were observed to be damaged during the inspection We propose to repair the wells which have been damaged The repairs will involve installation of protective casing or road boxes re-development and reshysurveying of the new measuring points The other wells are missing and presumed destroyed (ARC-2 ARC-3 BF-2 BM-2 MB-1 PO-SOUTH and RB-1) We believe that only monitoring wells MB-1 and MB-1 A require replacement The remaining wells that could not be located during the site inspection do not require replacement in order to achieve the goals ofthe Site Investigation
Based on our telephone conference on May 10 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MWgt_DOCSN753l9Wlaquo310l600raquopd M l 1 XA ~r
02439
HSI GEOTRANS
Mr Michael Smith 3 May 11 1999
bcc Sheila Jones
snwp_DocjN7sni9wcmoi6i)iraquoplti TVflTEC 1046
02440
HSI GEOTRANS
X_l ^ T 6 Lancaster Countv Road
Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-11 i 5
PN N753-002
June 25 1999
Mr Michael Smith Agency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Work Plan Modifications Ailing Industrial Park Site Williston VT
Dear Mike
This letter documents changes to the work plan for the Ailing Industrial Park Site in accordance with a telephone conference between you myself and Peter Zeeb On the results of the Site Investigation to date as well as additional data collection by the DEC we agreed that several revisions to the work plan are warranted The revisions for the work plan include the location and method of installation for the bedrock monitoring wells and the sampling of shallow monitoring wells recently installed Outlined below are the revisions to the specific tasks that we will undertake
Re-location of Bedrock Monitoring Weil BR-1
The DECs Source Area investigative work in the original location of BR-1 identified high levels (100 mgL) of VOCs present at or near the silt clay interface DEC believes that drilling through the clay layer in this location creates an unacceptable risk ofthe migration of contaminants into the underlying units HSI GeoTrans will relocate the bedrock well BR-1 adjacent to ASI-16 as located on the attached site plan
Bedrock Well Installation Method
Geophysical work at the site has refined our estimation of the depth to bedrock Depth to bedrock was initially anticipated to be greater than 150 feet below ground surface We currently anticipate bedrock at 100 to 140 feet below ground surface The shallower depth to Bedrock will
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MITEC 104e 02441
Mr Michael Smith 2 June 25 1999
enable us to reduce the size ofthe pilot hole needed for the well installation At locations BR-1 and BR-2 drillers will advance and set 4 in casing several feet into the clay unit and chop and wash the annulus ofthe casing All cuttings and wash water will be contained for proper disposal The casing will be refilled with potable water and the hole will be advanced with a 3 in roller bit When telescoping becomes necessary to prevent caving 3 in casing will be installed The 3 in casing will be advanced to the bedrock surface and seated The coring of bedrock will follow the original work plan specifications
Shallow Monitoring Well Sampling
The field GC water quality data obtained during small diameter installation at the site has demonstrated that contaminant concentrations in the upper portion ofthe aquifer to be low (lt 10 MgL) or non-detect in most locations This has led to the revision of our sampling plan Select shallow wells will be sampled to confirm the field GC data If these data are confirmed the low level and none detect shallow wells will not be sampled The shallow wells to be used for confirmation sampling are listed below
ASI-01 ASI-02 ASI-03 ASI-05 ASI-08 ASI-10 ASM 2 ASI-08
Based on our telephone conference on June 24 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MXTECl04e 02442
HSI GEOTRANS
Mr Michael Smith 3 June 25 1999
bcc Sheila Jones
MITEC I04e
02443
HSI GEOTRANS
1 0 T 2 shyCylty
T-TCT 6 Lancaster County Road _ _ _ Harvard Massachusetts
GEOTRANS OH 5 1
A TETRA TECH COMPANY 978-772-7557 FAX 978-772-6183
PN 753-010
July 9 1999
Mr Michael Smith Agency of Natural Resources Vermont Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Bedrock Monitoring Well Installation Ailing Industrial Park Site Williston VT
Dear Michael
On July 8 we became aware that a drill casing was advanced through the sand clay and till strata at the Ailing Industrial Park (site) without being sealed at the sandclay interface Although for the reasons described below we do not believe any vertical migration of contaminates occurred this method of drilling is contrary to the work plan for the site Therefore we are notifying you of this incident
On June 4 shallow direct push monitoring wells were installed at location ASI-06 where a deeper bedrock monitoring well is planned Groundwater quality profiling data from this location is provided on the attached boring log TCE is present in groundwater here at concentrations as high as 2270 ugl at 31 - 36 ft below ground surface (bgs) decreasing to 262 ugL at 41 - 44 ft bgs A soil boring (D-2) was advanced at this location on June 22 Field screening data from soil samples obtained in this boring are also provided on the attached log As apparent from the log fine to medium sand occurs to a depth of approximately 15 ft at this location grading to silt at depth A clay layer is encountered at 40 ft bgs Glacial till is present from 57 to 100 ft bgs where the bedrock surface is located Prior to drilling through the clay and glacial till a direct push well screen was advanced through the clay and into the till to a depth of 58 bgs and no groundwater recharge to the well screen occurred at any of five sampling depths
MWP_DOCSN753 199M7M1600 wpd
MITEC 104e 02444
Mr Michael Smith 2 July 9 1999
Drilling of bedrock monitoring well BR-2 began on June 29 Four inch casing was advanced to a depth of 44 ft and sealed within the clay layer Three inch casing was then advanced through the till layer to the bedrock surface During seating ofthe casing in the bedrock the casing was damaged and was subsequently withdrawn from the borehole
On July 7 a different drill rig was used to continue drilling the same location In accordance with both the drillers proposal to HSI GeoTrans and the work plan for the site investigation the driller was to seat a casing in the clay establish a seal and drill through the clay and till with smaller casing prior to coring bedrock Instead the drilling contractor withdrew the previously installed four inch casing without grouting it changed the drive shoe on the casing to a spin shoe and advanced the four inch casing directly to the bedrock surface Upon arrival at the site to log the coring of bedrock on July 8 HSI GeoTrans ascertained that the borehole had not been sealed at the clay surface prior to drilling deeper as was specified HSI GeoTrans then instructed the drilling contractor to immediately remove the casing and to seal the borehole with grout in the process
It is our intention to have a new drilling contractor complete the installation of BR-2 at an adjacent location in a manner that limits the potential for introducing contaminated unconsolidated deposits groundwater to the bedrock as specified in the work plan for this site investigation Within one week of completing the installation of BR-2 groundwater quality data collected from BR-2 will be evaluated with respect to the potential for contaminant migration along the unsealed borehole that existed at this location for approximately 24 hours As the casing was advanced by spinning providing a relatively good seal between the casing wall and the formation we do not anticipate that vertical migration along the casing was significant
If you have any questions regarding this letter please contact me at (978) 772-7557
Sincerely yours
Peter Zeeb PhD Senior Hydrogeologist
PZcas
MWP OOCSVN7S3M999070ll600wpri
MITEC 104e 02445
HSI GEOTRANS
1 HSI | 9pound9TPpoundSpound SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
LOCATION Williston VT CASING TYPEDIAMETER None
DRILUNG METHOD Drive and Wash Direct Push SCREEN TYPESLOT None
SAMPLING METHOD ss shelbv GRAVEL PACK TYPE None
GROUND ELEVATION GROUT TYPEQUANTITY Bentonite Portland Slurry
TOP OF CASING DEPTH TO WATER
LOGGED BY NSB GROUND WATER ELEVATION
REMARKS This log compiles the results o the all methods used to comolete the borehole over its entire depth
gtshyci IT UJ t o UJ E t shygt z L oi lti LITHOLOGIC DESCRIPTION 3Q O bdquo a UJ lt a ca sect 1a UJ
o amp UJ _ a 1 Oi i ai o UJ a E 03 5 1 - X X X
cc -S
Moderate olive Brown - Olive Grey m-f SAND w trace fines wet poorty graded
bull bull bull
- 5 shy
J
bull bull
- 1 0 shyD2-SS01 21 13 NO 7 NO 13
A12 7
bull bull
Light olive Brown SILT w trace fine sand wet poorly - 1 5 shy graded
O2-SS02 4 7 11 8
A7
6 7
- 2 0 shy Dark greenish Grey SILT wet poorly graded
O2-SS03 2 0 41 1
WOR WOR l
D2-SS04 2 4 2 X - 2 5 shy4
D2 13 1159
3
1 D2-SS05 2 5 39 v
WOR AWOR WOR - 3 0 shyD2-SS06 4 921 WOR
XWOR WOR
02-SS07 8 2270 1
X1 2 3
Continued Next Page 1 OF 3 02446
HSI GEOTRANS SOIL BORING LOG BR-02 A T E T R A T E C H C O M P A N Y
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
9 gtshyOC
UJ - j a
UJ gt o ^ r-6 LITHOLOGIC DESCRIPTION
ui
CD U UJ S oc =
o o
uj _ Q pound iT O
o
Medium Grey dayey SILT wet poorly graded
D2-SS09 4 S
28 1572
3 6
D2-SS10 WOR 1 18 13
4 6
D2-SS11 3 3 20 NO Medium Grey CLAY wet poorly graded 262
4 5
BR2-SS01 1 2 20 ND Soft Olive Grey CLAY moist laminated coheisive 2 4
BR2-SS02 20 NO
- 5 0 -
BR2-SS03 20 NO - 5 5 -
Dense Light olive Grey sandy GRAVEL w few fines
BR2-SS04 16 19 24
ND
bull60
moist poorly graded
21
Very dense Light olive Grey gravelly SAND w little fines moist well graded angular
BR2-SS05 40 51
13 ND 6 5 shy
60 66
I-7 0 shySO BR2-SS06 11 ND 50 100
5000
MITEC 104e 02447
Continued Next Page PAGE 2 OF 3
HSI GEOTRANS A T E T R A T E C H C O M P A N Y SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
a UJ
Q
05
i i m u
gt ac ui gtO bdquo UJ 3 oc S
o o
0 CO UJ _ Q pound LL C5
LITH0L0GIC DESCRIPTION 9 LU O
BR2-SS07 81 1004
10 NO E 8 0 shy
BR2-SS08 30 59 68
16 ND w8 5 shy
BR2-SS09 1005 NO 9 0 shy
BR2-SS10 89 1944
ND E bull95shy
- 1 0 0 shyND
Limestone
MITEC 104e 02448
PAGE 3 OF 3
Mr Michael Smith 3 July 9 1999
bcc Sheila Jones bcc Jerry Amman
MWPJXXSN753M9MW70J160Owpd
MITEC 104e 02449
6 Lancaster Countv Road HSI Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6 I i 5
PN N753-014
Septembers 1999
Mr Michael Smith Agency of Natural Resource Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in die Site Investigation Ailing Industrial Park Williston IT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and die Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation ore outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste waler lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot IV-11 using small-diameter wells and afield GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
bull perform one day ofwellpoint permeability testing at selected monitoring wells
mwFDocwsiMwwwnoootd MITEC 104e 02450
Mr Michael Smith September 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
M l T ECl04e 02451
U laquo OOCTN791Mtm01IOOOraquofrl
HSI GEOTRANS
HSI GEOTRANS
6 Lancaster County Road Harvard Massachusetts
01451
A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6183
PNN753-014
Septembers 1999 amp y gt
Mr Michael Smith D oJ Agency of Natural Resource Km Jt Department of Environmental Conservation i j f i l Waste Management Division ft y^y( 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park ft Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and the Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation are outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
bull perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste water lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot 19-11 using small-diameter wells and a field GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
MITEC 104e perform one day ofwellpoint permeability testing at selected monitoring wells 02452
000060 MlWP_OOCSN73Iirmraquo01|rngtlaquo|gtl
Mr Michael Smith Septembers 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
MITEC 104e 02453
000061 Mwr_cocS4miinmogtmoltsri
HSI GEOTRANS
T T Q T 6 Lancaster County Road ^ Harvard Massachusetts
GEOTRANS laquolaquo A TETRA TECH-COMPANY 978-772-7557 FAX 978-772-6183
PNN753-014
October 151999
Mr Michael Smith vZ Agency of Natural Resource J Department of Environmental Conservation Waste Management Division I 103 South Main StreetWest Building j Waterbury VT 05671-0404
Re Ailing Industrial Park Source Area Investigation
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants Evaluation of field data has determined the extent ofthe dissolved phase contamination migrating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) HSI GeoTrans will begin a Source Area Investigation on October 181999 to determine the nature and areal extent ofthe suspected contaminant source The investigation will be undertaken to gather the data necessary to complete the Site Investigation Report and the Feasibility Study which was set forth by the Agreement Between Mitec Telecom INC and Vermont Concerning the Ailing Industrial Park (1999) The Source Investigation will focus on the property owned by Beatrice Ailing and former MITEC lease hold (Lot 19-11 Williston plat map) and the area ofthe Ailing Industrial Park which has exhibited elevated contaminant concentrations during Site Investigation activities We are submitting this letter to The Vermont Department of Conservation(VTDEC) as an addendum to the approved Site Investigation Work Plan The addendum Source Investigation Work Plan will outline the tasks and methodologies to be utilized during the investigative work
Jack Guswa and I met with you on September 101999 to present the plans to investigate the suspected source area in the Ailing Industrial Park You agreed with the additional work as presented with the addition of two upgradient wells to be located to the west ofthe suspected source area (Figurel-1 ASI-30 and ASI-31) The VTDEC also agreed during the meeting to arrange access to the property for the Source Area Investigation The VTDEC and HSI GeoTrans were subsequently granted access to the property on September 111999 In addition to the work presented at the meeting it is necessary to preform a 72 hour pump test to characterize the
000054 MwrDOCSW79JimMOUIIOOpd
MITEC 104e 02454
Mr Michael Smith 2 October 151999
hydrologic conditions at the site The additional Source Area Investigation activities to be undertaken are presented below
Site Reconnaissance Ground Penetrating Radar (GPR) Survey Monitoring Well and Soil Boring Installation Low Flow Groundwater Sampling Hydraulic Characterization
The additional field work attributed to the Source Area Investigation will follow the standard operating procedures presented in the approved Site Investigation Work Plan (HSI GeoTrans 1999) The locations ofthe proposed well cluster installations and GPR survey are presented on Figure 1-1 The well cluster locations presented in Figure 1-1 were finalized during the September meeting between HSI GeoTrans and the VTDEC The GPR survey and hydraulic characterization tasks are presented below The Source Area Investigation field work will be completed within two week after its initiation The task specific outlines are presented below
Site Reconnaissance
The monitoring wells to be included in the site reconnaissance are monitoring wells MI-1 MI-2 MI-6 and RB-2 The monitoring wells on Lot 19-11 will be surveyed to a common datum with the existing site wide survey data Well integrity testing consisting of depth to bottom water level and visual inspection ofthe wells will be preformed Groundwater samples will be collected from selected monitoring wells based on the integrity testing Samples will be collected by the Low Flow Protocol set forth in the Site Investigation Work Plan (HSI GeoTrans 1999)
GPR Survey
A GPR survey will be preformed to identify on-site leach field septic tank or cesspool location remnants of waste water lagoon and any other subsurface anomalies We propose to use a 5 foot by 5 foot orthogonal grid survey to detect any near surface anomalies which exist on Lot 19-11 Geophysics GPR International will be performing the survey and will be utilizing a GSSI SR10 ground penetrating radar system with a high resolution 500 MHz antenna and a deep-penetration 100 MHZ antenna Any GPR response which indicate buried metal objects will be investigated with a Fisher TW6 pipe locator to augment the radar data All data will be analyzed in the field by GPR personnel and presented to HSI GeoTrans field personnel to determine the optimal location for well cluster ASI-28 If several anomalies are detected the VTDEC and HSI GeoTrans will evaluate the anomalies and modify the work plan accordingly
Well Installation and Soil Boring Advancement MITEC 104e 02455
The well clustes will consist of a small diameter shallow monitoring well and a deeper conventional well screened across the zone of highest concentration Well cluster installation will be performed in accordance with the Site Investigation Work Plan (HSI GeoTrans 1999) yjth 0 0 5 5
MWP_DOCSK731IW9M OOSIIOOprl
HSI GEOTRANS
Mr Michael Smith 3 October 151999
the exception ofthe deep wells The site conditions observed during previous field work prohibit the use of standard commercially available screen slot sizes The deep wells will be advanced by a large diameter Geoprobereg rod and installed using an outer filter sock to prohibit the infiltration offine sediments in to the well The well cluster installations will be performed jointly by Checkpoint Environmental and Twin State Environmental HSI GeoTrans will be provide oversite ofthe contractors and analysis of groundwater samples using afield Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999) The rationale for the selected well cluster locations is presented below
Monitoring well clusters ASI-25 through ASI-27 are located down gradient ofthe suspected source area The well clusters will be installed to more adequately define the areal extent ofthe concentrated portion ofthe contaminant plume A single soil boring will be advanced at location ASI-26 The soil boring will be screened as it is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-28 will be located after the GPR survey has been completed shyThe cluster will help define the suspected source area and the vertical migration of contaminants in the area The location will be determined in thefield after review ofthe GPR survey is completed The location will be based on any anomalies observed in the GPR data A single soil boring will be advanced at location ASI-28 The soil will be screened with a Flame Ionization Detector as the soil boring is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-29 will be located upgradient ofthe suspected source area The cluster will define the upgradient boundary andor any additional upgradient source areas The ASI-29 well will be paired with the existing shallow monitoring well AL-14
Monitoring well clusters ASI-30 and ASI-31 will be installed to the west cross gradient from the suspected source area to document the areal distribution of dissolved phase contamination emanatingfrom the Ailing Industrial Park The locations selected for these wells should define the northwestern and western extent of contamination
Low Flow Sampling
The additional monitoring well clusters will be sampled in accordance with the approved Site Investigation Work Plan (HSI GeoTrans 1999) Lowflow sampling procedures will be used to sample the newly installed deep wells in their respective clusters ASI-25 through ASI-31
MITEC 104e 02456
000056 MWP_DOCSgtK15JlWMOWllltraquoraquoprl
HSI GEOTRANS
Mr Michael Smith 4 October 151999
Hydraulic Characterization
HSI GeoTrans will conduct a 72 hour pumping test on the deep well at cluster ASM 2 The test is being undertaken to more adequately characterize hydraulic conditions at the site The data from this test will be used in the evaluation of remedial alternatives in the Feasibility Study The pump test will be performed as a step-drawdown test The pumping rates will ultimately be determined in the field from observed conditions Preliminary calculations indicate that pumping rates of 2 5 and 10 gallons per minute will be necessary to achieve the desired drawdown at observation wells The water level data will be recorded at observation wells ASI-06 ASI-13 ASI-25 ASI-26 NO-1 NO-2 and NO-3 The water level data will be recorded using pressure transducers and dataloggers
The effluent water from the pumping test will be treated by liquid phase granular activated carbon filters provided by Carbtrol Inc Two 175 pound carbon filters will be connected in series to treat the pump test effluent The effluent will be discharged to the unnamed brook upon approval from Randy Bean ofthe VTDEC The effluent will be periodically sampled between the carbon units and at the discharge point to detect break through ofthe carbon units The effluent samples will be analyzed utilizing a field Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999)) If the effluent sample between the carbon canisters exceeds 1000 ugL Trichloroethene (TCE) the discharge point sample will be analyzed If concentration of TCE in the discharge point sample exceed 300 ugl the test will be discontinued
We hope that this letter addendum to the Site Investigation Work Plan for the Source Investigation is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJmm MITEC I04e
02457
000057 MWFDOCSN731imu00SI 100 bullpd
HSI GEOTRANS
JHSTUART March 1 1985
Agency of Environmental Conservation D e partment of Water Resources und
E nvironmental Engineering H a z a r d o u s Materials Management Program A t t n John A m i d o n H y d r o g e o l o g i s t M o n t p e l i e r Vermont 05602
R e M I T E C Systems Corp W i l liston
Dear J o h n
During our meeting at MITEC on February 20th you noted that some additional information was needed to c omplete the initial phase of testing as well as the d o c umentation of the activities under takentodate Outline d~ beTow-Ts ~t h e~1 n f o r m a ti o n t h a t y o u r e q u e s t shyed
1 Attac hed here to is the plan used to install the grou ndwat er moni t o r s collection and analysis of the grou ndwa t er samp les for metals and organics and the extr actio n of and testing of soils from the area of the dispo sal site 2 A rev ised sit e pla n has been incl uded refl ecting the new well posi tions and the e leva t ions of t he top of t he mo ni to r s and th e groundwa ter 1e vels as of F e shybr ua ry 0th As note d in our m ost r ecent tel ephone conv i on th e lat ter have r isen 14-15 inc hes as er sa t the It o f th e rec ent thaw Two copie s of the resu plan be f orw ar ded to Winslo w Lad ue as req uested will and pla ns t 0 sur vey all ho uses on Br owne 11 Rd MITEC _tp tain if there are ajiy shallo w wel I sources ltis ce r with e dr aina ge ar ea a f fecte d by the 1agoo n in th 3 ngla nd Ma r ine C o m r a c t o r has been con tacted New E for remo va 1 of th e lagoon soil a nd co ntra c tural the ar ra nts wil 1 be concluded du r ing t he comi ng ngeme week if ic at io n of work comme nceme nt wi II be proshy Not vide your off ice i n advance d to t m Resul t s of th e met als and or genies are expected shor tiy
f rom IEA and will be fo rwarded to your ofshyf ice oon as a va i la ble as s 5 R esul t
s fr om t he pr e vious soi 1 and water sampling have inc 1 ude d bee n
CIVIL 4 EfViROUMEI-L pound l j i t fcHpound P ) OGA lt i f r l h r l h w i l l n-- i i U - iO l i l ) bU i l I
MITEC 104e 02458
s
MITEC Page 2 March 1 1985
If you have any questions please do not hesitate to contact me
Stuart PE
JHSocc
MITEC 104e 02459
MITEC Systems Corporation Williston Vermont
Soil and Water Sampling Program
1 Install groundwater monitors at nine (9) locashytions consisting of two (2) inch inside diameter PJpound with ten (10) feet of factory slotted pipe extending into the groundwater and terminating with a minimum of two (2) feet above ground level and capped
2 Establish elevations of the groundwater monitors for the top of each pipe and the groundwater elevashytion for each for a specific date Due to the shalshylow depth to groundwater from 51-112 inches the level is established by graduated tape and a light Each measurement will be performed a minimum of three times to assure accuracy to within one-eighth inch The location of each well and the established elevations will be represented on a general site plan showing the MITEC property
3 Groundwater samples are to be collected from each well on the same date by pump or baling Prior to - k ~ -~-|1bdquo--bdquobdquo f bdquo k bdquobdquobdquobdquobullbdquo ltv~ 11 1 1 v bdquo bdquo bdquo
acidification for metals preservation to assure ac curacy of the test results All samples are to be analyzed for copper cadmium nickel cyanide pH conductivity total chromium and hexavalent chrome
U Soil samples are to be collected as follows
GWM09 Saturated zone (aaprox 5) Overburden East side lagoon Composite from
two holes 5 apart-at-1 bullbull2 bullbull A below the-sur=mdash face and one in the saturated zone
North wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface 1 into the saturated zone
South wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface I1 into the saturated zone
Bottom of lagoon Composite offour test holes 8 apart one in the unsaturated zone
MITEC 104e 02460
MITEC Sampling Program
All samples are to be analyzed for the same constituents as required of the water testing
5 Collect separate samples of the groundwater after the above referenced purging process for storage in air-tight vials The samples which are to be colshylected from wells A-9 with only 5 and 7 analyzed initially by the GCMS- EPA method 62A If organics are detected in the first samples testing must be performed on 4 and 8 as well
6 All sampling will be performed with a State repshyresentative on-site and results of the testing to be forwarded to the State as soon as available
7 The contaminated soil within the lagoon will be removed by a Vermont certified contractor for disposhysal in an approved wastedepository The top one (1) foot of soil from the flood level and below will be extracted during the process
MITEC 104e 02461
i
o H
ON f J
o
bull I I bull
HA
OOO
x x z
bull
MITEC 104e 02463
WK miui w ci ivnui II i ici ILUI ujiyitb inc iii PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5108
ANALYSIS REPORT
Customer j H S c u a r t Associates Date 26 February 1985
Address P gt 0 gt B o x 3 6 7 Date Samples Received
Ci ty S t a t e Zip Essex Center VT 05A15 20 February^1985
Customer Order Nomber
Attent ion J o h n S t u a r t
Station 9
J
2
3
A
5
6
7
8
9
poundH
5A
58
52
5A
A5
53
53
55
59
j MITEC
Conductivity U mbos ( 25degC)
206
A18
21A
176__
208
230
205
16A
265
GROUNDWATER ANALYSIS
O01 0 OS bull
Cadmium Total Chromium (mRl) (mRl)
0A1 lt0025
006- 270
00A 012
bull005 189
005 023
001 lt0025
lt0C Hexavalent Chromium (mKI)
bull
lt0025
239
005
183
lt0025
lt0025
ampo
Zinc (mKl)
005
0A0
032
015
OU
003
Note Organic analyses to follow in two weeks
cc John Amadon
Signature jJfcrryyS 7lrifrylC
Offices ond loborotones located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02464
if jsznoi U hnvironmentol jiolysts Inc PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5138
ANALYSIS REPORT
Customer J H Stuart Associates Date 21 December 1984
Address PO Box 367 Date Samples Received 14 December 1984
City State Zip Essex Center VT 05451 Customer Order Number
Attention John Stuart
WATER ANALYSIS
PH 52 57 50 53 45 34
Conductivity (pmhos 25degC) 213 420 152 167 202 bull 225
O l Cadmium (mgl) lt001 lt001 001 v 028 bull 005 003
o pound Chromium Total (ng1) lt0025 lt0025 lt0025 lt0025 2-35 v 014 - -bullbull - bull - -bull V 013 bull^Chromium Hexavalent (mgl)1 0 11
gt1p Copper (mgl) lt002 lt002 lt002 lt002 bull 084 004
Q Cyanide (mgl) lt0005 lt0005 lt0005 lt0005 bull -lt0005 lt000E
Z Nickel (mgl) lt0025 lt0025 lt0025 lt0025 bull 010 003
fO 2inc (mgl) 0J1 UU1 0U3 001 038 030
Hexavalent chromium was only analyzed when total chromium was present
Signature fmnigt Mji fnt f VncL 7
Offices and laboratories located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02465
bull i
ANALYSIS REPORT
Customer J H Stuart Associates Date 22 January 1985
Address PO Box 367 Date Samples Received 14 December 1984
Ci ty State Zip Essex Center VT 05415 Customer Order Number
Attent ion John Stuart
bull shy
bull bull mdash bull bull bull bull bull - bull bull bull bull shy SOIL ANALYSIS1
Hexavalent Cyanide Chromium Chromium Cadmium Copper Nickel Zinc
poundH bull (mgl) (mgl) (mq1) bull (mq1) (mq1) (mgl) (bullmgl) -
2 442 lt0005 lt0025 lt0025 lt 001 lt 002 015 006
4 402 lt0005 lt0025 lt0025 lt 001 lt 002 lt002 001
7 504 lt0005 lt0025 lt0025 lt001 lt002 lt002 001
8 486 lt0005 lt0025 lt0025 lt001 lt002 lt002 bull 008
9 441 lt0005 lt0025 lt0025 lt001 lt602 lt002 004
10 444 0005 lt0025 lt0025 lt001 lt002 lt002 006
11 498 lt0005 lt0025 lt0025 lt001 003 lt002 009
30 532 lt0005 lt0025 008 lt001 005 lt002 010
31 544 lt0005 lt0025 lt0025 lt001 002 056 003
32 472 lt0005 lt0025 lt0025 lt001 lt002 024 003
36 536 0008 lt0025 011 lt001 005 lt002 011
37 490 lt0005 lt0025 lt0025 lt001 021 lt002 009
38 391 lt0005 0276 032 lt001 050 lt002 011
41 416 lt0005 0108 018 001 229 lt002 o5i
42 395 lt0005 0399 041 lt001 039 lt002 014
i
Signature Ltrf(7( ni W0 6M Analysis of EP toxicity extract
Offices ond loborotoriei locoted in Essex Junction Vermont Reseorch Triongle Pork North Corolino
MITEC 104e 02466
JHSTUART
A p r i l 2 9 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Hazardous Waste Materials Program Attn Cedric Sanborn Environmental Engineer Montpelier Vermont 05602
Re Mitec Systems Williston
Dear Cedric
I was phoned by David Gee today and informed that a truckload of the contaminated material was removed from the lagoon area as the result of a previous commitment entered into by Mitec Due to conflicting information about Mitecs responsibilities at this juncture I am recommending that any further work cease until a realistic program be agreed to by both parties I base that on the following
1 Following the trial pre-hearing the State was inshystructed to contact Mitec to develop a schedule for further dialogue and actions connected with the reshyhabilitation of the lagoon site To my knowledge there has not been any such attempt made on the part of the State to resolve issues that need clarificashytion
2 On April 18th I forwarded a letter to you outlinshying some new information with recommendations That correspondence has not been addressed yet Mitec has been ordered to continue with the soil removal
3 A letter from John Amadon on April 23rd notes the organic sampling to be invalid due to the time lapse and the method of storing the samples We do not take issue with this position however there is apshyparently some question about the validity of the GCMS method of analysis We have been instructed to re-sample but now there is a question about whether we should employ GC or GCMS
A On numerous occasions we have expressed the deshysire to tailor the soil removal process to a minimum
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 3C7 ESSEX CTR VERMONT 05451 TELEPHONE 802 876 bull 5171
MITEC 104e 02467
L
Mitec Page 2 April 29 1985
2- bull number of truckloads as they are projected to cost about $4000 for each load Mitec being in a startshyup phase of their operation cannot approach this operation with a blank check Chris Stone who was on hand today to represent the State indicated that many more loads may be necessary to effectively rid the site of contamination
Too many questions surround this project for my clishyent to understand his responsibilities and ultimate costs The requirements issued by your office either in writing or verbally on-site have changed repeatshyedly and unless we can mutually agree to a reasonshyable program that is connrifpH rnmdashyr r i ng Mitec has no other option but to let the court decide the isshysue
Again keep in mind there are questions that we feel must be resolved in order to reach a satisfactory conclusion
1 Provided that all Browneil Road houses are connected to the CWD system and thereby reshymoved from any threat of groundwater conshy
- p tamination what level of soil contamination is permissible From this limitation provishyded we concur as to its reasonableness an approximation can be developed as to how many loads of soil must be removed
2 If the soil is to be removed why is it neshyy cessary to conduct organics sampling unless
i t~ i s tne ulterior motive ot the State to direct renovation of the groundwater as well If that is the case the process will now be more expensive than at the outset due to the mobilization of the contaminants
3 If the contaminated soil is to be removed whv is additional groundwater monitoring
pound bull necessary Documentation of the degree of dilution is not considered acceptable
A If organic testing is to be performed y_hich -- method of analysis is to be used
As soon as we can receive a response to the quest-
MITEC 104e 02468
I um laquoi i laquo m mdash n r r j mdash i mdash
Mitec Page 3 April 29 1985
ions at hand then further discussion with the State will dnsue Also please be advised that at the dishyrection of Mitec all future correspondence communishycations requests for information or notification of site vists are to be forwarded to my office We also request that one person in your office be designated to process such information
tuart PE
JHSocc cc Mitec
Robert Cronin Esq
MITEC 104e 02469
jmfMraquoi w i f u m i
A u u raquo laquo F pound raquo laquobull= -
B C f U S t B C INC ENVIRONv i bullbullbull bullbull
5 GREEN MOUNTAIN DRIVE SOUTH BURLINGTON VERMONT 05401 TELEPHONE (802) 658-1074
February 17 1984
I I Mr Cedric Sanborn i
of Environmental Conservationi AgencAgencyy ox ampnvifoiuneniai Lonservdciun I i Dept of Water Resources and
Environmental Engineering Montpelier VT 05602
Dear Mr Sanborn j i
RE Mitec Clean-Up 84011 j
I am writing this letter to inform you of the work that has been completed thus far at Mitec Systems Corp The discharge of i rinsewater into the lagoon has stopped and the rinsewater is being batched and treated at Aquatec as I described in my letter to Stan Corneille dated February 3 1984
Although the chemical reduction and precipatation process works bull bull
very well we have found that the cost for design installation j septic design and installation and permit reviews is far above | Mitecs budget Aquatec has looked at a second alternative for bull the treatment and reduction of rinsewater that being ion exchange J The ion exchange system will be purchased from a vendor and will bull be installed by Aquatec to accomodate Mitecs rinsewater volumes i The rinsewater will be recirculated and will not require any discharge hence there will be no need for subsurface disposal [ permits I will send you specifications on the system and resins j that will be used I
The proposal for the out-door clean up work is enclosed Mr Kucer is currently discussing the cost estimate with his Montreal office I see no reason to intiate this work as soon as I get formal approval from your office and from Mitec
Please feel free to call me if you should have any questions
Sincerely
liytrl Zi [U$) John R Deigo Project Engineer
Enclosure cc Mr Steven Kucer
Hydrographic Studies and Analyses bull Water Quality Studies raquo Analytical Laboratories Ecological Studies bull Aquatic Nuisance Control - Industrial Waste Surveys
MITEC 104e 02472
Recommended Treatment of Rinsewater
Mitec System Corporation
Prepared By
Aquatec Inc
South Burlington Vermont
January 23 1984
MITEC 104e 02473
RE Mitec Groundwater Cleanup - 84011
The treatment of rinsewater will consist of a three stage rinse system with a batch chemical reduction treatment process Parts submersed in chromic acid solutions will be rinsed in a primary rinse bath The primary rinse bath will be a closed system and considered a rough rinse
The secondary rinse bath will also be a closed rinse system The third and final rinse will be a continuous overflow system Effluent from the tertiary system will flow directly into the septic system Tertiary effluent limits must be less than 005 mgl (ppm) before entering an underground septic system
The primary rinse bath will eventually become saturated with chromic acid solutions and require periodic batch treatment When the primary rinse water becomes spent it will be transferred into a 250 gal polyethylene plating tank The rinse water from the secondary rinse bath will be transferred into the primary rinse bath and the secondary bath will be refilled with fresh rinse water
When the tank reaches 80 of its capacity treatment will be initiated The treatment will consist of reducing hexavalent chromium to trivalent chromium by the addition of anhydrous sodium sulfite to a pH of lt2 The amount of sodium sulfite added will depend on the concentration and volume of rinsewater to be treated A portable electric mixer will be attached to the tank to ensure proper mixing The rinsewater in the reduced form will be gravity fed into a second 250 gallon polypropylene plating tank where lime will be added precipatlng out trivalent chromium as well as other heavy metals The mixer should be used to agitate the solution when the lime is added The mixer should be removed and the solids allowed to settle Once the solids have completely settled the treated water will be pumped into the tertiary effluent to allow for further dilution before it is discharged into a septic system
Periodic sampling of effluent waters should be incorporated to ensure that rinsewater discharged does not exceed 005 mgl (ppm)
Sludge will be properly stored and eventually disposed of by a certified hazardous waste carrier
MITEC 104e 02474
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Wildlife and Department of Forests Parks and Recreation Environmental Engineering Department of Water Resources amp Environmental Engineering Natural Resources Conservation Council State Geologist
January 4 1984
3 2ampov~ loo Mr J H Stuart
f i 2 Sm ^
P O Box 3 67 - - l ^ J ^ S M J Essec Center Vt 05451
SUBJECT Mitec Z 0~npJ^
1 o
Dear J o h n
I appreciate your sending me a copy of the recent Mitec water quality results It appears that there remains a detrimenshytal affect of the lagoon on the downgradient groundwater quality This is best demonstrated with the pH and chrome data While it appears that the downgradient well 5 has higher metalic concenshytration then well 6 in the middle of the lagoon I believe the Well 5 results are anamously high due to the turbidity or solids that we saw in the sample In talking with Cathy Cutting of IEA sample 5 was not filtered prior to acid digestion for the AAS analysis ^^
I would suggest that well s 4 5 and 6be resampled and analyzed along with the wells installed on CecT 17 amp 18 We would like to have a representative of our office on site when the sampling is performed so please contact me when a purging and sampling date is set in the near future The groundwater sample from test well 6 that you helped me obtain on December 17 with the teflon bailer was confirmed by our laboratory to contain volatile organics Therefore you must include the volatile orshyganics assay done by JGCMSjas a part of your analysis plan Adshyditionally I would suggest that you review the appropriate protocol for groundwater sampling and obtain the necessary equipshyment A sampling and analysis plan must be submitted for our apshyproval prior to commencing this second round of sampling The plan should be submitted by January 18 1985 with the sampling done within one month of our approval Please feel free to conshytact me with any comments or questions you may have
R f n r mdash i 1 Off ices - BarreEssex J c t P i t t s f o r d N Spr ing f ie ld S t Johnsbury
MITEC 104e 02844
J H Stuart Page 2
I do look forward to reviewing the results of the soils asshysays along with your report outlining the sampling protocol sampling locations data interpretations and projected course of action based on the results
Very truly yours
John F Amadon Hydrogeologist Hazardous Materials Management Program
JFAkp
cc Meredith Wright AG
MITEC 104e 02845
b v
HSTUART ASSOCIATES September 10 1984
Agency of Environmental Conservation Department of Water Resources and Environmental Engineering Air and Solid Waste Programs Attn Cedric Sanborn Air Pollution Control Engineer Montpelier Vermont 05602
Re M I T E C Corporation Williston Vermont
Dear Cedric
As Che result of our conversation on September 7th I am forwarding the information Chat we discussed
The CesCing program format was prepared prior Co our disshycussion and will be altered slightly based on some inforshymation that was collected
A boring was established in the cencer of Che disposal pic and Che wacer Cable as well as che Impeding layer were found to be located at 29 Inches below the surface The shallow depth will allow us co place addicional wells in che area co accuracely depicc Che groundwacer copography
The plan submiCCed herewith provides general information abouc che locaclon of che plane propercy lines and sugshygested positions for Che monitors The final location of che laccer will be decermined in che field once we collect more data on water table elevations
As we are most anxious to proceed with the program your expeditious review and responsewill be most appreciated
SCuart PE
JHSadt
cc David Gee MITEC
CIVIL ENVIRONMENTAL ENGINEERS 120 LAKE STREET BURLINGTON VERMONT 0S401 TELEPHONE 802-8640094
MITEC 104e 02846
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Game and Department of Forests Parks and Recreation
Department of Water Resources amp Environmental Engineering Environmental Engineering Natural Resources Conservation Council
September 19 1984
Mr John H Stuart PE JH Stuart Associates 120 Lake Street Burlington Vermont 05401
RE MITEC Project
Dear Mr Stuart
Chris Stone and I have reviewed the proposed soil sampling and groundwater monitoring plan for Mitec A summary of comments follows
1) The site plan did not show the location of the soil sampling sites Also we felt that additional boringmonitoring sites should be made closer to the facility The map has been re-marked to reflect these additional sites
2) It was not clear as to why the monitoring wells are to be installed 5 feet into the impeding layer However at least one boring should be made into the impeding layer to detershymine its thickness
3) Permeability tests should be performed on at least four of the test holes to determine aquifer characteristics
4) Since the water table is apparently close to the surface we feel that factory slotted pipe would be appropriate for the final monitoring wells
5) All soil1 ft 5 ft
samples 10 ft or
shouldto imp
be eding
takenlayer
at whic
depthshever
of comes
first
MITEC 104e 02847
Mr JH Stuart -2- September 19 1984
6) In addition to the soil sample in the center of the former lagoon four other locations within 2 feet of the edge of the lagoon must be sampled These locations are marked on the enclosed map
7) The State regulations do not address a level below which the metals are no longer hazardous as is done by EPA Toxicity Levels The level of contamination that is acceptable to the State is determined on a case by case basis
8) The analysis for chromium should include both hexavalent and total chromium
If you have any questions regarding our comments do not hesitate to contact us at 828-3395shy
Sincere
Sanborn C h r i s t o p h e r T Stone Environmental Engineer Hydrogeo log i s t Hazardous M a t e r i a l s Hazardous M a t e r i a l s Management Program Management Program
c r s - c t s a d e n c l o s u r e
MITEC 104e 02848
JHSTUART November 9 1984
Agency of Environmencal Conservation Deparcmenc of Wacer Resources and
Environmencal Engineering Hazardous MaCerials Management Program Attn Cedric Sanborn Environmental Engineer Mnotpelier Vermont 05602
Re M I T E C Corporation Williston Vermonc
Dear Cedric
There has been an apparent misunderstanding regarding your letter of September 19 1984 as soil and wacer sampling has been commenced ac che above location A call was placed Co your office on October 30th or 31sc and a message lefc for you indicating that we would begin on November 6ch at 8 AM
In the afternoon of November 6th I telephoned Chris Scone co inform him of our progress On che following morning you notishyfied MITEC that approval to begin had not been granced and chac work musC cease AC chac point we had completed che installashytion of five monitors and had extracted Cwo soil samples from the botcom of che wasce pic
On November 8ch I met with you and Chris to oucline che reshysulCs from our effores I was informed Chat we may have to inshystall one or Cwo additional monitors and Chac all future work muse be performed wich an Agency represenCacive in accendance
LaCe that afternoon Gerry Adams phoned Co notify me chat on short notice he was leaving to begin a large contract in rUasashychusetts and that it was unlikely that he would be back in the area for an extended period Had we been permitted to continue ttith our work on the 7th his portion of the project vould have been concluded
Enclosed you will find an updated version of the site plan orishyginally submitced wich my leCCer of Sepcember lOch A new plan will be developed buc Chis drawing will serve the purpose of locating existing and proposed wells
Whereas I am now withouc a drilling concracCor I would like chu
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05461 TELEPHONE 802 878 5171
MITEC 104e 02849
M I T E C Page 2 November 9 1984
authorization to determine groundwater elevations by auger and then establish one more monitor in a location agreed to by all che parcles I feel chac we have developed sufficient information co date to proceed in this manner
Furcher since Adams will noc be available I would also like Co extract che remaining soil samples wich a bucket auger IC can demonstrated chac che sample collected in chls manner will provide a good represencacion of che soil ac che level desired in Che profile
We are prepared co conclude chls phase of che sice evaluacion Samples from Che groundwacer monitors can be secured in a few days and I would like co follow wich che soil samples using che method described above
Please contact me at 878-5171 if you need additional informashytion
H Stuart PE
JHSadt
cc David Gee MITEC
MITEC 104e 02850
JHSTUART December 19 1984
M I T E C Corporation AtCn David Gee Manager IS Commerce Way Wllliscon Vermonc 05495
Dear David
Under Che Cerms of our agreemenc daced 10584 I wish Co proshyvide you wish an up-daCe of the project status
At the completion of 1219 we will have completed Items 1-4 as specified in the agreement specifically the soils sampling and initial set of water samples will have been collected and submitted for analysis As of chls momenC we still do not know the extent of the problem but will have a better indication once the test results are available in about a week My feelshying Is chac the problem is noc severe
We have compleCed all wells as prescribed however Che State is opting for an additional well Although the contract provides for only six the costs to date are below my target and it does not appear Chac any exCra will be necessary provided ChaC che driller concludes his work coday
The only work remaining afCer chls dace will be che collecCion of che second baCch of waCer samples and discussions wich Che State about any remedial action if necessary
Feel free to contacC me if you have any quescions
Regards
John H Stuart PE
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 878 bull 5171
MITEC 104e 02851
JHSTUART
M I T E C Corporation December 20 1984 ACCn David Gee Manager 15 Commerce Way Willaton VT 05495
Dear David
During our investigations yesterday Che work was completed on the additional monitor well as invoiced as well as drilling to the impeding layer The State decided however that two addishytional wells are required both of which will be Installed toshyday west of the Industrial park boundary line
A major change developed In Che method of testing the soils in the vicinity of the disposal pit that is not covered by our contract Instead of the four peripheral borings and one in Che center of che pic which would have produced flfceen soil samshyples che StaCe representatives decided Co require a different CesC paCCern Chac produced thirty seven samples I have collectshyed all of the samples but have Instructed the Cest lab to hold until authorization Is received Co proceed on Chls change as it Is a subsCanClal cost and will cause Che contract limit to be exceeded
Included is an invoice reflecting the additional wells the cost Co sample the groundwater for those monitors and the additional funds needed to run the soil tests I do not believe that any further surprises are in order
Regards
John H Stuart PE
JHSadt
CIVIL ft ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 06451 TELEPHONE 802 878 5171
MITEC 104e 02852
JHSTUART
December 28 1984
M I T E C Corporation Attn David Gee Manager 15 Commerce Way Williston VT 05495
Dear David
Enclosed are the results from the water quality analyses of the samples submitted to our lab I have noted in the left hand column the allowable limits for each element A copy of this information has been forwarded to John Ami-don per his request
There are several readings that are suspicious according to John The cadmium level in 4 may be an error and Che chromium found in 5 mosc likely Includes che CurbldlCy measured only in ChaC well Both should be resampled to confirm The cadmium and chromium levels in 06 exceed che allowable llmlCs but not excessively so The soil tesCs which have begun will reveal more about the ultimate disshyposition of these elemenCs
On the sewer Issue I spoke wich Frank Ailing again and his plans are Co now develop Che design and receive approval chis wincer for consCrucCion of the required Improvements this spring
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 5171
MITEC 104e 02853
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MITEC 104e 02855
JHSTUART January 28 1985
M I T E C Corporation Attn David Gee Manager 15 Commerce Drive WillistonVermont 05495
Dear David
On January 25th I met with John Amadon and Cedric Sanborn to discuss the contents of my 12385 letshyter The following resulted subject to confirmation by more senior members of the AEC staff
1 The water samples to be collected from wells 45 and 6 are to be checked for cadmium both chromiums and conductivity Wells 1 2 and 3 will be tested for conductivity and pH only
2 Samples will be collected from wells 4-9 for orshyganics but only wells 56 and 9 are to be checked at this time to determine the scope of contaminatshyion
3 The material to be removed from the pit is conshysidered as a hazardous waste and there are not any disposal sites located within Vermont certified to receive it I did obtain a listing of contractors that are approved for handling the material and I will provide this during our next meeting
4 Attached is a copy of the State lab results that address the organics problem
5 Based on the above we will have to amend our ashygreement to include the $1150 additional costs for the testing connected with Items 1 and 2
Call me if you have any questions
John H Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 raquo 878 bull 5171
MITEC 104e 02856
JHSTUART January 30 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Attn John Amadon Hydrogeologist Montpelier Vermont 05602
Re M I T E C
Dear John
I have had several discussions with MITEC relative to our meeting of last Friday In essence they have agreed to the program that you defined but with several provisos
They would like a letter from your office detailing the additional measures to be implemented together wich specific instructions as to what steps must be taken in the process of removing the contaminated soil
Further their acceptance to collect and sample for volatile organics is limited Perchloroethylene as I had indicated is not and has not been used by MITEC The materials stored on the premises as well as the list of suppliers for paints and solvents are available for inspection co corroborate that position MITEC will provide a complete analysis of all organics for the specified wells however fushyture testing for TCE will not be at the expense of MITEC unless its presence can be attributed to their operation
We are prepared to proceed as soon as we receive the requested notification
Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 bull 5171
MITEC 104e 02857
TABLE OF CONTENTS
PAGE
1 INTRODUCTION 1-1
2 STUDY AREA CONCEPTUAL MODEL 2-1 21 STUDY AREA LOCATION AND DESCRIPTION 2-1
22 STUDY AREA LAND USE 2-1
23 HYDROGEOLOGIC SETTING 2-1
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION 2-3
3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES 3-1 31 IDENTIFICATION OF ARAR S 3-1
32 REMEDIAL ACTION OBJECTIVES 3-1
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES 3-1
322 GROUNDWATER 3-1
323 SURFACE WATER 3-2
324 INDOOR AIR 3-3
33 INITIAL SCREENING 3-3
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES 3-4
4 DETAILED ANALYSIS OF ALTERNATIVES 4-1 41 ALTERNATIVE 1 NO ACTION 4-1
411 SHORT-TERM EFFECTIVENESS 4-1
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-2
413 LONG-TERM EFFECTIVENESS 4-2
414 COMPLIANCE WITH ARARS 4-3
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 4-4
416 IMPLEMENTABILITY 4-4
417 COSTS 4-5
42 ALTERNATIVE 2 MONITORING INSTITUTIONAL CONTROLS AND
HYDRAULIC CONTAINMENT 4-5 421 SHORT-TERM EFFECTIVENESS 4-8
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-9
423 LONG-TERM EFFECTIVENESS 4-9
424 COMPLIANCE WITH ARAR S 4-10
425 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-11
426 IMPLEMENTABILITY 4-11
427 COSTS 4-12
FOR ALLING INDUSTRIAL PARK MWP_DOCSW5J20OTALlIWFS9-00U0030929wro 11 HSI GSOTrflnS IflC
MITEC 104e 02354
TABLE OF CONTENTS (CONTINUED)
PAGE
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS
AND PERMEABLE REACTIVE BARRIER 4-13
431 SHORT-TERM EFFECTIVENESS 4-15
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-16
433 LONG-TERM EFFECTIVENESS 4-17
434 COMPLIANCE WITH ARARs 4-18 435 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-18
436 IMPLEMENTABILITY 4-19
437 COSTS 4-20
44 ALTERNATIVE 4 MONITORING INSTITUTIONAL CONTROLS
AND NATURAL ATTENUATION 4-20
441 SHORT-TERM EFFECTIVENESS 4-21
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-21
443 LONG-TERM EFFECTIVENESS 4-22
444 COMPLIANCE WITH ARARS 4-23
445 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-23
446 IMPLEMENTABILITY 4-23
447 COSTS 4-24
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION 4-25
451 SHORT-TERM EFFECTIVENESS 4-26
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-27
453 LONG-TERM EFFECTIVENESS 4-27
454 COMPLIANCE WITH ARARS 4-28
455 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-29
456 IMPLEMENTABILITY 4-29
457 COSTS 4-30
FOR ALLING INDUSTRIAL PARK MWPJXgtCSN7532000AUJNOFSlaquo)0I0030929WPD 111 HSI GeOTrSDS ItlC
MITEC 104e 02355
TABLE OF CONTENTS (CONTINUED)
PAGE
5 COMPARATIVE EVALUATION OF ALTERNATIVES 5-1 51 SHORT-TERM EFFECTIVENESS 5-1
52 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT 5 - 3 53 LONG-TERM EFFECTIVENESS 5-4
54 COMPLIANCE WITH ARARS 5-4
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 5-4
56 IMPLEMENTABILITY 5-5
57 COSTS 5-5
6 PREFERRED REMEDY 6-1 61 PREFERRED REMEDY 6-1
62 MONITORING PROGRAM 6-2
REFERENCES 7-1
APPENDIX A TWODAN INPUT FILES
FOR ALLING INDUSTRIAL PARK MWgt_DOCSW7532000WJJNGfS9^)0M00J(raquo9wpo I V H S I G S O T r a H S I n C
MITEC 104e 02356
LIST OF TABLES
PAGE
TABLE 3-1 REMEDIAL ACTION OBJECTIVES 3-7
TABLE 3-2 DESCRIPTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES 3-8
TABLE 3-3 SELECTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES
FOR DETAILED ANALYSIS 3-11
TABLE 41 COST ESTIMATES FOR REMEDIAL ALTERNATIVES 4-31
TABLE 6-1 SAMPLING LOCATIONS 6-5
TABLE 6-2 VOC ANALYTES 6-6
TABLE 6-3 PARAMETERS TO EVALUATE BIODEGRADATION 6-7
FOR ALLING INDUSTRIAL PARK MWP DOCSN7S32000AUJNOFS9-00I0030929 wro HSI GeoTrans inc
MITEC 104e 02357
LIST OF FIGURES
PAGE
FIGURE 1-1 STUDY AREA LOCATION MAP 1-2
FIGURE 1 -2 LATERAL BOUNDARIES OF REGION OF TCE-CONTAMINATED GROUNDWATER 1 -3
FIGURE 4-1 MODELED SITE-EXISTING CONDITIONS 4-33
FIGURE 4-2 MODELED SITE WITH THREE RECOVERY WELLS PUMPING AT 5 GPM 4-34
FIGURE 4-3 MODELED SITE WITH TEN RECOVERY WELLS PUMPING AT 5 GPM 4-35
FIGURE 4-4 ALTERNATIVE 3 PERMEABLE REACTIVE BARRIER 4-36
FIGURE 6-1 PROPOSED MONITORING LOCATIONS 6-8
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUUNOFS9-OOV 10030929 w r o VI HSI GeoTrans inc
MITEC 104e 02358
1 INTRODUCTION
This Corrective Action Feasibility Investigation is submitted on behalf of Mitec Telecom
Inc (Mitec) by HSI GeoTrans The investigation was done to evaluate potential remedial
alternatives for groundwater contaminated by trichloroethylene (TCE) and to a lesser extent
tetrachloroethylene (PCE) and petroleum related compounds (BTEX) at the Ailing Industrial
Park (the Study Area) A recently prepared Site Investigation Report (SIR) (HSI GeoTrans
2000) identified the nature and extent of contaminated groundwater within the Study Area
Figure 1-1 is a map ofthe Study Area and Figure 1-2 is a map that outlines the region of
contaminated groundwater for which potential remedial alternatives were evaluated
The SIR concluded that the TCE contamination was widespread across the Study Area
that residual TCE dense non-aqueous phase liquid (DNAPL) resulting from one or more releases
was a continuing source of contamination to groundwater and that under current conditions the
groundwater contamination does not pose an unacceptable risk to human health and the
environment Current conditions include the continued effective mitigation of indoor air vapors
at the residence at Lot 3-30 no other residences with basements below the water table and no
use of groundwater within the Study Area as a potable supply The SIR also concluded that if
groundwater were to be used as a potable supply a significant health risk would exist as a result
of exposure to groundwater through ingestion dermal contact and inhalation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^X)M0030929WPD 1 - 1 HSI GCOTrdnS ITC
MITEC 104e 02359
I - N -
Former Mitec Hold y
Meters
Explanation
Study Area TITLE
MITEC 104e 02360
Study Area Location Map
LOCATION
Williston Vermont CHECKED MS FIGURE HSI OfVFTED RMK
GEOTRANS RLE f s ~ Expa nd~S(tsdirq 1-1 A T I T M TICK C011irraquoraquoT DATE- 10600 ~
2 STUDY AREA CONCEPTUAL MODEL
The following discussion ofthe Study Area conceptual model is summarized from
information contained in the previously submitted SIR (HSI GeoTrans 2000)
21 STUDY AREA LOCATION AND DESCRIPTION
The Study Area is located at the Ailing Industrial Park and adjacent areas in Chittienden
County Williston VT The VT state plane coordinates for the Study Area are Northing
71210837 (44 27 T north latitude) and Easting 147576375 (73 7 50 west longitude) The
Study area is within the Winooski River watershed and has an elevation ranging from 330 to 350
feet above mean sea level (MSL) The ground surface has little relief and slopes gently to the
southwest A small unnamed brook flows in a southerly direction along the eastern edge of an
industrial park located within the Study Area There is unlimited public pedestrian access to the
Study Area
22 S T U D Y A R E A L A N D U S E
The land in the Study Area is currently zoned for mixed residential commercial and
industrial use The eastern portion ofthe Study area is primarily zoned for commercial use and
the western portion ofthe Study Area is predominantly residential The Study Area includes an
industrial park where there has been light industrial and commercial use since 1946 Three lots
in the industrial park have been previously identified as locations of former manufacturing andor
fabrication operations that resulted in release of contaminants to groundwater (Brinkerd 1996
TRC 1993 Griffin 1995)
23 HYDROGEOLOGIC SETTING
The unconsolidated geologic deposits beneath the Study Area consist of sand silt and
clay which were deposited in the former Champlain Sea overlying till The unconsolidated
deposits occur in four distinct layers The surficial deposits are medium to fine sand which
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generally becomes finer-grained with depth and extend to approximately 20 feet below ground
surface (bgs) Interbedded silts and fine sands are present from approximately 20 to 40 feet bgs
An areally-extensive clay layer underlies the interbedded silt and fine sands at a depth of
approximately 32 to 60 feet bgs Beneath the clay layer is a dense till which extends from about
60 to 100 feet bgs The underlying bedrock is comprised of massive gray limestone gray
dolomite and white marble ofthe Beckman formation This bedrock is of lower Ordovician age
and is part ofthe Hinesburg Synclinorium structure
The aquifer in the Study Area and surrounding regions is primarily the surficial medium
and fine sands although some water is capable of being extracted from the lower silt and fine
sand The residences and businesses within the Study Area are currently serviced by a public
water supply and the aquifer is not used for potable water supply within the Study Area The
hydraulic conductivity ofthe medium to fine sands was determined from a slug test to be about
20 feetday (Johnson 1999) The hydraulic conductivity ofthe interbedded silt and fine sand as
determined from rising and falling head slug tests (HSI GeoTrans 2000) ranged from 1 to 20
ftday with a geometric mean of 38 ftday A pumping test of well NO-1 yielded a hydraulic
conductivity estimate of about 2 to 30 ftday for the combined medium to fine sands and
underlying silt and fine sand There are no hydraulic conductivity data for the underlying clay
and till layers It is believed that the clay and till act as a lower confining layers restricting the
vertical flow of water between the overlying sand and the underlying bedrock
Beneath the Study Area the depth to water generally ranges from 3 to 11 feet below
ground surface In general groundwater flow beneath the Study Area is from the north to the
southeast and southwest There is a groundwater divide in the water table that runs generally
parallel to Commerce Street East ofthe divide groundwater flows toward and discharges to the
unnamed brook West ofthe divide groundwater flows toward Muddy Brook which is located
about 300 meters or 1000 feet west ofthe Study Area Groundwater recharge within the Study
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Area is primarily from infiltration of precipitation Prior to 1986 when a sewer line was
installed groundwater recharge also resulted from discharge to numerous on-site disposal
systems
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION
Figure 1-2 illustrates the 1999 distribution of TCE-contaminated groundwater within the
Study Area The lateral boundaries ofthe region of TCE-contaminated groundwater
approximately represent the lateral boundaries ofthe region of volatile organic compound
(VOC)-contaminated groundwater As discussed in the SIR (HSI GeoTrans 2000) VOCs
present in groundwater include TCE PCE and BTEX The compound detected at the highest
concentrations and over the largest portion ofthe Study Area is TCE PCE is generally detected
in the same area as TCE but at significantly lower concentrations BTEX compounds have been
detected in groundwater primarily in the eastern portion ofthe Study Area and are commingled
with but not coincident with TCE-contaminated groundwater The lateral boundaries shown in
Figure 1-2 approximately represent the lateral extent of groundwater contamination and are not
intended to indicate that all groundwater within those boundaries is contaminated This figure
includes data collected on behalf of Mitec as part ofthe SIR (HSI GeoTrans 2000) and data
collected in 1999 by the Johnson Company (Johnson 1999) Figure 4-2 A ofthe SIR (HSI
GeoTrans 2000) shows all TCE concentration data collected in 1999 as well as some data
collected in 1997 The SIR (HSI GeoTrans 2000) summarized previous investigations that
indicated that at least three properties have contributed to the region of VOC-contaminated
groundwater On Lot 19-11 there were a disposal lagoon and a leach field that resulted in the
release ofthe VOCs TCE and PCE (perhaps as an impurity in the TCE) Lot 19-12 once had
underground storage tanks from which a previous release of BTEX was discovered when the
tanks were removed Lot 19-2 contained a disposal pit and outfall pipe from which TCE was
reportedly released
Figure 1-2 of this report shows in plan view the areal distribution of TCE-contaminated
groundwater Where there were multiple 1999 data values for the same location preference was
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AL1JNOFS9-OOM0030929WPD 2-3 HSI GSOTraHS JHC
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given to samples collected by low-flow sampling done subsequent to well installation In
addition for those locations which had samples from different depths the sample with the
highest concentration was used Figure 1-2 illustrates that TCE-contaminated groundwater is
widespread beneath the Study Area and that the highest TCE concentrations are detected in
groundwater beneath the eastern portion ofthe Study Area The figure illustrates that TCE-
contaminated groundwater in the eastern portion ofthe Study Area discharges to the unnamed
brook No VOCs including TCE have been detected in groundwater samples collected from
wells on the eastern side of the unnamed brook Based on surface water and groundwater data
that have been collected the unnamed brook appears to limit the southeasterly extent ofthe
region of VOC-contaminated groundwater In the western portion ofthe Study Area the lateral
boundaries of contaminated groundwater were identified through vertical profile sampling at
several locations Figure 1-2 shows the location ofthe vertical profiling borings that define the
lateral extent of TCE-contaminated groundwater The SIR (HSI GeoTrans 2000) recommended
periodic sampling and analysis of wells in the western portion ofthe Study Area for the purpose
of determining whether this region of VOC-contaminated groundwater was stable or expanding
in size
While not evident from Figure 1-2 it was determined that throughout the Study Area the
highest TCE concentrations were detected in samples collected from the interbedded siltclay
layer As shown on Figure 4-2A ofthe SIR the higher TCE concentrations were generally
detected at a depth of about 35 feet below ground surface in the eastern portion ofthe Study
Area and at a depth of about 30 feet below ground surface in the western portion ofthe Study
Area It is believed that the current distribution of TCE contamination resulted from DNAPL
releases at one or more locations within the Study Area One such release area was at Lot 19-11
DNAPL migrated downward through the upper medium to coarse sands under the primary
influence of gravitational forces There would have been some lateral displacement along
preferential pathways provided by sloping unconsolidated deposits but the primary flow would
have been downward Upon encountering the more resistive capillary pressure forces associated
with the water-saturated finer-grained geologic units such as the interbedded silts and sands
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which exist beneath the upper medium to coarse sands the DNAPL downward migration would
have stopped The DNAPL would have accumulated on top ofthe capillary pressure barrier layer
and then would have spread laterally following preferential flow paths within the coarser-grained
geologic units above the interbedded silts and sands The amount of lateral spreading of
DNAPL from any release area would have been dependent upon the volume and frequency ofthe
releases As the DNAPL migrated it would have created a region of residual DNAPL This
region of residual DNAPL consists of isolated DNAPL droplets trapped within pore spaces ofthe
unconsolidated deposits The lateral migration ofthe DNAPL would have been affected by the
slope ofthe surface ofthe finer-grained units that halted downward migration ofthe DNAPL
and it would not necessarily have been coincident with the direction of hydraulic gradient or
groundwater flow The region of residual DNAPL is now a continuing source of contamination
to the groundwater which flows past and gradually dissolves the DNAPL The locations ofthe
residual DNAPL zones are not known
There were no direct observations of DNAPL during drilling and well installation but it
is expected that residual DNAPL generally exists within regions of higher concentration detected
in the eastern portion of the Study Area The residual DNAPL is not necessarily continuously
connected within that region Based on the vertical distribution of TCE concentrations it is also
expected that the residual DNAPL exists in a relatively thin zone within the interbedded silt and
clay Limited hydrodynamic dispersion within the interbedded silt and clay has resulted in a
relatively thin zone of relatively high TCE concentrations in groundwater The southeastward
and southwestward divergence of groundwater flow has resulted in a laterally extensive region of
TCE-contaminated groundwater
There has been no indication in any ofthe investigations done within the Study Area
including the SIR (HSI GeoTrans 2000) that there are locations within the Study Area where
DNAPL is present in sufficient volume to be recoverable in the DNAPL phase
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3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES
31 IDENTIFICATION OF ARARS
Two Applicable or Relevant and Appropriate Requirements (ARARs) were identified in
consultation with Mr Mike Smith ofthe Vermont Department of Environmental Conservation
(VTDEC) The first are the Groundwater Enforcement Standards as outlined in Appendix one of
the Chapter 12 Groundwater Protection Rule (VTDEC 1997) These standards apply to
concentrations of contaminants in groundwater in the Study Area (TCE PCE and BTEX) The
second are the Vermont Water Quality Criteria dated March 142000 (VTDEC 2000) which
specify surface water quality criteria and policy
32 REMEDIAL ACTION OBJECTIVES
The remedial action objectives (RAOs) for the Study Area are summarized in Table 3-1
and further described below
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES
One ofthe RAOs for the Study Area is the remediation of source areas Soil excavation
and removal has already occurred at the known release areas Not withstanding the fact that
previous DNAPL releases are suspected no areas of recoverable DNAPL have been detected in
the Study Area Concentrations of TCE in groundwater indicate it is present in some areas as
residual phase below the water table One purpose of this Corrective Action Feasibility
Investigation is to evaluate options for remediating residual DNAPL in the Study Area
322 GROUNDWATER
Attain VT Groundwater Enforcement Standards The ultimate goal of remediation is to
attain Groundwater Enforcement Standards for VOCs in groundwater This is in accordance
with the VT Groundwater Protection Rule and Strategy (VTDEC 1997) which states that If an
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enforcement standard has been reached or exceeded at a compliance point the goal is to take
appropriate action to retum the groundwater quality to below the enforcement standard if
possible
Prevent Expansion ofthe Dissolved Plume A risk assessment (Menzie Cura 2000a and
2000b) was included as part ofthe SIR (HSI GeoTrans 2000) The risk assessment concluded
that under current conditions concentrations of VOCs dissolved in groundwater in the Study Area
do not pose a risk to human health andor the environment The SIR (HSI GeoTrans 2000) also
indicated that the available monitoring data were not sufficient to determine whether the region
of VOC-contaminated groundwater in the southwestern portion ofthe Study Area was stable in
size or expanding This Corrective Action Feasibility Investigation explores options for
monitoring groundwater quality and preventing the region of VOC-contaminated groundwater
from expanding in size
Prevent Potable Use of Groundwater Within the Dissolved Plume Menzie Cura prepared
a June 1 2000 addendum (Menzie Cura 2000b) to the April 2000 risk assessment (Menzie Cura
2000a) The addendum evaluated risk posed by potable use of groundwater at the site The
addendum found there to be a human health risk associated with the use of groundwater at the
site for potable purposes One RAO of this Corrective Action Feasibility Investigation is to
propose institutional controls so that groundwater within the region of contaminated
groundwater would not be used as a potable supply until concentrations are suitable for such use
323 SURFACE WATER
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
under current conditions VOCs dissolved in surface water in the Study Area do not pose arisk to
human health or the environment Currently however surface water concentrations in the
unnamed brook exceed VT Water Quality Criteria (VTDEC 2000) One ofthe RAOs for the
site will be to meet these surface water quality standards in the unnamed brook
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324 INDOOR AIR
The VTDEC has conducted air sampling at several residences along Kirby Lane and
South Browneil Road The results have indicated the presence of TCE and PCE in indoor air at
some ofthe South Browneil Road residences (Brinkerd 1996) and unacceptable VOC
concentrations in the basement ofthe residence at Lot 3-30 on South Browneil Road The
presence of VOC vapors in the residence on Lot 3-30 is believed to have resulted from
volatilization of groundwater which infiltrated the basement through a continuously operating
sump pump The sump was vented to the exterior ofthe house as part of a state-sponsored
action and the indoor air concentration ofthe contaminants reduced to an acceptable
concentration Therefore one institutional control for the site will be to maintain the sump
venting as long as necessary to prevent health risks due to inhalation of VOC concentrations in
indoor air Also an institutional control in the form of a zoning restriction should be
implemented to prohibit the construction of new buildings with basements below the water table
in the region of contaminated groundwater The restriction should specify that in cases where it
is unavoidable to place the basement below the water table proper containment and venting of
the sump drainage system is required
33 INITIAL SCREENING
Four general categories of remedial technologies were evaluated The first monitoring
may be used alone or in conjunction with other remedies The second category includes
institutional controls to prevent exposure to contamination in groundwater and indoor air
Institutional controls could also be used alone or in conjunction with other remedies The third
category includes source removal technologies
The fourth category includes contaminated groundwater containment technologies such
as a hydraulic barrier or permeable reactive barrier Containment technologies can be applied in
two different ways Thefirst source control application would entail installing the containment
technology directly downgradient ofthe highest dissolved concentrations in an attempt to contain
the contaminated groundwater nearest the source Over time if new contamination is not
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allowed to migrate beyond the source VOC concentrations in the downgradient region of
contaminated groundwater should attenuate
The second application would entail installing the containment technology at the
downgradient edge ofthe region of Contaminated groundwater The containment would protect
downgradient receptors from impacts by the region of contaminated groundwater
Both containment technology approaches were considered for use in the event additional
monitoring data shows that the region of VOC-contaminated groundwater is expanding in size
or if VOC concentrations in groundwater discharging to the unnamed brook are increasing
Table 3-2 identifies the remedial technologies considered and summarizes the results ofthe
initial screening for applicability to addressing the ARARs
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES
The list of potentially viable technologies shown in Table 3-2 was subjected to an initial
screening process The purpose ofthe initial screening was to identify those technologies that are
potentially feasible in the Study Area prior to performing a more detailed technology screening
Many ofthe source removal technologies were removed from further consideration because of
the impracticability of remediating residual DNAPL at the site
As described in the SIR (HSI GeoTrans 2000) DNAPL is likely present in the Study
Area Although present DNAPL has not been directly observed in any location and there has
been no indication that there is recoverable DNAPL present The failure to detect DNAPL
directly is not an uncommon situation at DNAPL sites and commonly results from its
heterogeneous distribution or its presence only at residual saturation (US EPA 1992)
Groundwater extraction and treatment is not an effective technology for remediation of residual
DNAPL due to limitations resulting from the limited solubility of most DNAPL compounds and
the heterogeneous distribution ofthe DNAPL (US EPA 1993) Designing remedial strategies
for DNAPL is made difficult by the inability to accurately locate the DNAPL sources This
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inability to locate the DNAPL renders the use of targeted source remedies that might be cost
effective for a small readily definable source area ineffective These targeted source remedies
include excavation air sparging chemical oxidation in-situ thermal desorption and chemical
flushing technologies
Subsurface deposits in the Study Area are heterogeneous due to the interbedded nature of
the sands and silts overlying an areally extensive clay The presence of such heterogeneity
creates extremely variable and unpredictable groundwater flow velocities as well as flow paths
for DNAPL migration The contrast in permeability and porosity between different lithologies
results in the development of preferential flow pathways While preferential flow through coarse
sand and gravel zones provides higher than average groundwater flow rates and contaminant
flushing less preferential flow pathways such as silty sands silts and clays remain poorly
flushed even under forced hydraulic gradients created by extraction wells Contaminants
however may have migrated to these areas of less preferential flow as DNAPLs under
gravitational influence or by diffusion over long periods of time The low permeability zones
even if addressed by localized extraction of groundwater will transmit only small quantities of
water and hence contaminant flushing is slow This is compounded by the low solubility of
DNAPL constituents and the tendency for them to become trapped in soils by capillary pressure
forces
Specific source removal technologies which have been screened out as ineffective at this
stage include air sparging groundwater amendments excavation and in-situ thermal desorption
Low permeability zones prevent the migration of soil vapors or sparged air to the near-surface for
recovery due to the preferential flow caused by heterogenieties it is not possible to determine if
amendments which can be added to the groundwater or chemical flushing compounds which
displace the groundwater and help liberate residual DNAPL such as oxidants alcohol polymers
andor surfactant would reach the DNAPL Excavation which has already been used to remove
impacted surface soils in known release areas is not practical for removing residual DNAPL
deep below the water table The in-situ thermal desorption can be useful in some environments
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but can also induce downward DNAPL migration if hydraulic control ofthe system is not
complete Because the location of residual DNAPL is not known and because hydraulic control
ofthe underlying silt clay and till into which the DNAPL may migrate cannot be assured in-situ
thermal desorption is not feasible for this site
Monitoring and institutional controls are included in each option evaluated except for the
no-action alternative These are required to rule out possible future health risks due to expansion
ofthe region of VOC-contaminated groundwater or the creation of new contaminant exposure
pathways
The technologies remaining after the initial screening are presented in Table 3-3
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Table 3-1 Remedial action objectives
MEDIA REMEDIAL ACTION OBJECTIVE
Groundwater -Remove or control contaminant sources
bullAttain VT Groundwater Enforcement Standards
-Prevent expansion ofthe region of contaminated groundwater
-Prevent use of groundwater within the region of contaminated groundwater as a
potable water supply where contaminant concentrations exceed federal drinking
water standards
Surface Water -Attain VT Water Quality Criteria
Air -Prevent inhalation of concentrations in indoor air derived from groundwater
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-n Table 3-2 Description of potentially viable remediation technologies o w o
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R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Basement Sump Venting
Restriction on new buildings with basements set below the water table
Restrict Potable Use of Groundwater
Excavation
Natural Gradient Flushing
Air Sparging
RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
PROCESS DESCRIPTION OPTIONS
No Action No Action
Monitor groundwater concentrations to confirm that region of VOC-contaminated groundwater is not expanding in size
Monitor surface water concentrations in unnamed brook to ensure concentrations remain below risk levels
Continue to vent the sumps at Lot 3-30 on South Browneil Road
Restrict construction of any new buildings with basements set below the water table within the area of dissolved VOC contamination and require basement sump venting in those where a below water table basement is unavoidable
Place restrictions on potable use of groundwater at properties overlying the region of VOCshy contaminated groundwater
Excavation and removal of soils containing residual DNAPL
Continued dissolution and natural attenuation of residual DNAPL
Injection of air beneath the water table to volatilize residual DNAPL and dissolved concentrations in groundwater
INITIAL SCREENING C O M M E N T
Used as a baseline for comparison No cost Long remediation time
Can be used in conjunction with other response actions Will be required in the southwest portion ofthe region of contaminated groundwater since existing data are inconclusive regarding this issue
Can be used in conjunction with other response actions
Will be required until data show there is no longer a risk to indoor air from groundwater in the basement
Will be required until data show there is no risk of migration of VOCs to indoor air from groundwater
Will be required at all properties in the area of VOC-contaminated groundwater to prevent a risk to human health
Has been used at the site to remove residual DNAPL in soils in the release areas Impractical to recover residual DNAPL at depth The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Intermediate cost Short time frame to cleanup if all residual source can be removed
Higher permeability zones are preferentially remediated On-going monitoring required No installation or on-going maintenance costs Long time frame to cleanup
Small-scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Intermediate installation and high on-going maintenance costs
MITEC 104e 02374
5 T l O Description of potentially viable remediation technologies (continued) PO
Table 3-2 O
RESPONSE REMEDIAL PROCESS g 5 ACTION TECHNOLOGY OPTIONS 5 m
r-m Source Chemical Ozone m Removal Oxidation Sparging q JO o n o
o
Potassium Permanganate Injection
Fentonss Reagent Injection
i co
Source In-Situ Steam Removal Thermal Stripping
Desorption
Electrical Resistance Heating
I Radio (pound Frequency
O m Heating OH 3) gt Z 0)
DESCRIPTION
Injection of air and encapsulated ozone beneath the water table to oxidize dissolved DNAPL constituents such as TCE
KMn04 is injected below the water table to oxidize dissolved DNAPL constituents
Fentons Reagent is injected below the water table to oxidize dissolved DNAPL constituents
Stream injected below the water table As the groundwater and soil are heated residual DNAPL is mobilized and collected by groundwater and soil vapor extraciion techniques
Low frequency alternating current is applied below the water table to cause resistive heating ofthe soil and groundwater As the groundwater and soil heat residual DNAPL is mobilized Groundwater and soil vapor extraction techniques are used to collect dissolved and vaporized DNAPL constituents
Electromagnetic radiation is applied below the water table As the groundwater and soil heat residual DNAPL is mobilized
INITIAL SCREENING COMMENT
Presence of DNAPL will potentially require large quantities of ozone The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Small scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Ozone is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of KMn04 The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of Fentons Reagent The exact location of the residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Fentons Reagent is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Small scale heterogenieties can result in channeling during steam injection and reduce the recovery efficiency Shallow depth of application may preclude effective steam control The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeneity has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeniety has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult so target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
_ mdash_ mdash _ _
MITEC I04e 02375
bulln Table 3-2 Description of potentially viable remediation technologies (continued) o
R E S P O N S E
A C T I O N
tn Source Removal
Source Containment Plume Management
co bull
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REMEDIAL
TECHNOLOGY
Chemical Flushing
Hydraulic Containment
Impermeable Barrier
Permeable Reactive Barrier
Phytoshyremediation
PROCESS
OPTIONS
bull
DESCRIPTION
Injection and recovery of alcohol polymers andor surfactant below the water table to enhance dissolution of residual DNAPL
Pump groundwater in downgradient portion of VOC-contaminated region groundwater to intercept contamination before it reaches a receptor or downgradient ofthe highest concentrations as source containment
Impermeable barrier is installed in the subsurface to contain groundwater and reduce the pumping rate needed for containment Can be installed upgradient of a receptor to prevent exposure or downgradient of the highest concentrations as source containment
Reactive material such as zero valent iron placed in flow path of contaminated groundwater Contaminants are treated as the natural gradient causes groundwater to flow through the barrier
Extracting of contaminated groundwater by evaporation from high water use trees Organic contaminants may also be biodegraded by the root system or may adsorb to living or dead root tissue and become immobilized
INITIAL SCREENING C O M M E N T
Higher permeability zones are preferentially remediated The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Groundwater extraction is required to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent fulfresidual DNAPL removal Very high installation and operation cost
Effective in containing dissolved concentrations Relatively low installation cost moderate on-going maintenance costs
Effective in containing dissolved concentrations Requires groundwater extraction and treatment Moderate installation cost moderate on-going maintenance costs
Moderate installation costs Lifetime of reactive material difficult to predict and reinstallation may become necessary No on-going maintenance costs prior to replacement
Still experimental Hard to confirm water usage rates and prove containment Trees may require ongoing monitoring and replacement Low installation and maintenance costs Only operates during the growing season
MITEC 104e 02376
1 T l Table 3-3 Selection of potentially viable remediation technologies for detailed analysis 1
rt g g g
5
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spound r m rshymO
M nn o
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RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Indoor Air Monitoring
Basement Sump Venting
Potable Use of Groundwater
Restrict Basements Below Water Table
Excavation
Natural Gradient Flushing
Air Sparging
Chemical Oxidation
In-Situ Thermal Desorption
Chemical Flushing
PROCESS
OPTIONS
No Action
Ozone Sparging
Potassium Permanganate Injection
Fentonss Reagent Injection
Steam Stripping
Electrical Resistance Heating
Radio Frequency Heating
RETAINED
DISCARDED
Retained
Retained
Retained
Retained
Retained
Retained
Retained
Discarded
Retained
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
RATIONALE
Used as a baseline for comparison
Necessary to evaluate if the region of VOC-contaminated groundwater is expanding in size and if the VOC concentrations in groundwater discharging to the unnamed brook are increasing
Necessary to monitor that concentrations remain below health risk levels
May be required al new residences with basements below the water table built in Browneil Road area
The existing sump vents at Lot 3-30 on South Browneil Road will be required to mitigate indoor air risks
Restriction of potable use of groundwater at properties overlying the region of VOC-contaminated groundwater will be required to prevent dermal ingestion and inhalation exposure
Restriction of construction of new basements below the water table in the area of VOC-contamination will be required to prevent future inhalation risks
Residual DNAPL located too far below ground surface to make excavation feasible The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Excavation of known release areas has occurred
Longer time frame to clean up not a drawback at this site Lower cost is a benefit
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location of the residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL Steam control difficult
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
MITEC 104e 02377
2 Table 3-3 Selection of potentially viable of remediation technologies for detailed analysis (continued) a m RESPONS E R E M E D I A L PROCES S RETAINED RATIONALE
ACTION T E C H N O L O G Y OPTION S DISCARDED
Source Containment Hydraulic Containment Retained Proven effective at containing expansion ofthe region of contaminated groundwater Region of Contaminated
iisect
n n o
Groundwater Management
Impermeable Barrier Retained Proven effective at region of contaminated groundwater containment
Permeable Reactive Retained Proven effective at region of contaminated groundwater containment Barrier
Phyto-remediation Retained Experimental however there are no potential negative consequences in using the technology Low cost is a benefit
co i
IO
I (A O m OH 73 gtZ
MITEC 104e 02378
4 DETAILED ANALYSIS OF ALTERNATIVES
41 ALTERNATIVE 1 NO ACTION
The no-action alternative is included in accordance with EPAs Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA (EPA 1988) The no-action
alternative provides a baseline for comparison and involves taking no additional actions at the
Study Area This remedy assumes no continuing monitoring of dissolved concentrations in
groundwater surface water or concentrations in indoor air This remedy assumes no institutional
controls on basement sump venting at Lot 3-30 on South Browneil Road property no restrictions
on new buildings with basements set below the water table constructed within the area of VOC
concentrations in groundwater and no restrictions groundwater use for potable purposes within
the region of VOC-contaminated groundwater
411 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community The risk assessment completed for the SIR
(HSI GeoTrans 2000) concluded that current conditions at the Study Area do not pose a risk to
human health Current conditions include venting ofthe sump at Lot 3-30 on South Browneil
Road no buildings other than at Lot 3-30 with basements below the water table in VOC-
contaminated areas and no potable-use wells within the region of VOC-contaminated
groundwater Without institutional controls to ensure this there may be future risk The risk
evaluation indicated that concentrations in the unnamed brook resulting from contaminated
groundwater discharge while not above risk-based thresholds were close to levels that could
pose a risk to human health Therefore monitoring is advised to confirm that VOC
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7533000AUJNOFS9^010030929WPD 4 - 1 HSI GGOTrSOS jflC
MITEC 104e 02379
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of VOC-contaminated groundwater could result in health risks not
evaluated in the risk assessment
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative
Time to Achieve Remedial Action Objectives It is estimated that the time frame required
for natural attenuation of contaminants to meet the groundwater cleanup concentrations will
significantly exceed the two-year time frame used to evaluate short-term effectiveness
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment There is no treatment of contaminants under this option
Reduction in Toxicity Mobility or Volume Some reduction of residual DNAPL and
accompanying dissolved concentrations is expected through natural attenuation over time if no
action were pursued at the Study Area However no monitoring data would be available to
confirm the progress
Amount of Material Contained or Treated Natural attenuation may serve to contain the
entirety of the region of groundwater contaminated with dissolved VOCs
413 LONG-TERM EFFECTIVENESS
Residual Risk Therisk assessment completed for the SIR (HSI GeoTrans 2000)
concluded that current conditions at the Study Area do not pose a risk to human health
However the risk evaluation indicated that concentrations in the unnamed brook resulting from
contaminated groundwater discharge while not above risk-based thresholds were close to levels
that could pose a risk to human health Therefore monitoring is advised to confirm that VOC
FOR ALLING INDUSTRIAL PARK
M W P _ D O C S N 7 5 3 2 0 0 0 A L U N O F S W raquo I 0 0 3 0 9 2 9 W P D 4-2 HSI GeOTrdDS IflC
deg2380
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of contaminated groundwater could result in health risks not evaluated in
the risk assessment Without institutional controls to ensure basement sump venting at Lot 3-30
on South Browneil Road restrictions on new buildings with basements set below the water table
within the region of VOC-contaminated groundwater and prevention ofthe installation of wells
for potable supplies within the region of VOC concentrations in groundwater a residualrisk to
human health remains
Adequacy and Reliability of Controls This remedy does not assume the sump in the
basement ofthe residence at Lot 3-30 on South Browneil Road remains sealed and vented to the
outside and that the pump is maintained in operable condition to continue to keep groundwater
out ofthe basement Previous air sampling conducted by the VTDEC has confirmed that this is
necessary to control indoor air impacts to this residence This remedy relies on natural
attenuation to control the region of VOC-contaminated groundwater however there is no
continuing monitoring of dissolved VOC concentrations in groundwater Since monitoring to
date has not confirmed that the region of VOC-contaminated groundwater is not expanding in
size a remedy which has a natural attenuation component but does not include monitoring does
not provide adequate control
Permanence of Remedy In the very long-term natural gradient flushing should reduce
VOC concentrations in groundwater to acceptable levels
414 COMPLIANCE WITH ARARs
Groundwater Protection Rule and Strategy It is expected that natural attenuation would
over time reduce groundwater concentrations to below VT Groundwater Enforcement Standards
However a no-action response would not comply with VT Groundwater Protection Rule and
Strategy (VTDEC 1997) which allows for remediation of sites by natural attenuation if sufficient
monitoring is perfonned to document that expansion ofthe region of contaminated groundwater
is not occurring and that natural attenuation is occurring The no-action alternative would not
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AU1NGFS90010030929wro 4-3 HSI GSOTraFIS IflC
MITEC 104e 02381
allow for continued monitoring and would not meet this requirement
Surface Water Quality Standards It is expected that natural attenuation would over
time reduce surface water concentrations to below VT Water Quality Criteria for the protection
of human health and aquatic organisms (VTDEC 2000)
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
concentrations of VOCs adsorbed to soil and dissolved in groundwater in the Study Area do not
pose a risk to human health andor the environment under current uses There would be arisk if
groundwater within the region of VOC-contamination were used as a potable supply Therefore
if dissolved concentrations were not migrating beyond the limits ofthe region identified in the
SIR (HSI GeoTrans 2000) and groundwater were not used for potable purposes the no action
alternative would be protective of human health and the environment However there are not
sufficient data to determine whether the region of VOC-contaminated groundwater is stable or
decreasing in size If the region of contaminated groundwater were expanding beyond the limits
upon which the risk assessment was based there may be a future risk to human health and the
environment Also restrictions should be placed on properties overlying the region of VOC-
contaminated groundwater to prohibit construction of basements below the water table and the
use of groundwater as a potable supply and the venting ofthe sump at Lot 3-30 should continue
416 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000AlXINGFS900U0030929wro 4-4 HSI GGOTrdRS IflC
MITEC 104e 02382
Technical Feasibility The no-action alternative is technically feasible
bull Ability to Construct the Alternative The no-action alternative requires no
construction
bull Reliability ofthe Technology No technology would be applied under the no-
action alternative
bull Ease of Undertaking Additional Remedial Actions The no-action alternative
would not prevent future remedial actions
Administrative Feasibility The no-action alternative is administratively feasible
Availability of Services and Materials No services or materials are required to carry out
the no-action alternative
417 COSTS
There are no costs associated with the no-action alternative The no-action alternative is
shown on Table 41 for purposes of comparison
4 2 A L T E R N A T I V E 2 M O N I T O R I N G INSTITUTIONAL C O N T R O L S AND
H Y D R A U L I C C O N T A I N M E N T
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull institutional controls would be implemented to restrict construction of any
buildings with basements within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull groundwater extraction and treatment would be done to contain the region of
VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753laquo000WJJNoFS9JXI10030929wro 4 - 5 HSI GSOTraDS JllC
MITEC 104e 02383
Groundwater pumping is an effective technology for hydraulic containment of
contaminated groundwater Hydraulic containment can be used if the region of VOC-
contaminated groundwater is impacting a sensitive receptor or is expanding is size The risk
assessment (Menzie Cura 2000a and 2000b) showed that groundwater was not impacting any
receptors to a degree that would represent a human health risk or risk to the environment There
is not sufficient temporal data however to confirm that the region of VOC-contaminated
groundwater is not expanding is size Therefore an analysis of hydraulic containment has been
included in this Corrective Action Feasibility Investigation in the event that future monitoring
shows the region of VOC-contaminated groundwater is expanding and that containment is
necessary
If monitoring indicates that natural attenuation is not causing the region of VOC-
contaminated groundwater to be stable in size or to shrink then an active containment remedy
may be required Under this scenario a groundwater pump-and-treat system would be installed
and operated in the Study Area to hydraulically contain contaminated groundwater and prevent
expansion ofthe region of VOC-contaminated groundwater Pumping wells would be installed
in the overburden silts and sands to the clay layer Wells would be installed in the downgradient
portions of contaminated groundwater to the southeast and southwest Extracted groundwater
would be treated before discharge to surface water The primary treatment operation will be air
stripping with a low-profile stripper for the removal of VOCs primarily TCE Depending on
treatment efficiencies secondary treatment with granular activated carbon may be required In
addition a particulate filter may be added to remove iron prior to treatment and reduce iron
fouling ofthe air stripper and carbon Extracted and treated groundwater would be discharged to
surface water via an outfall Compliance sampling can be conducted at the outfall or at a
sampling point within the treatment building The outfall should be constructed to minimize
hydraulic impacts on the receiving water body
The number and location of pumping wells that may be required to capture and contain
the region of TCE-contaminated groundwater has been investigated using the two-dimensional
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9JXA10030929WO 4-6 HSI GSOTfanS IdC
MITEC 104e 02384
analytical element simulation code TWODAN (Fitts 1997) TWODAN is a commercially
available copyrighted program The input parameters to the model are based on the values
reported in the SIR (HSI GeoTrans 2000) Input data sets for the analyses contained in this
report are included in Appendix A The bottom elevation ofthe model is 306 ft which is
representative ofthe top ofthe continuous clay layer beneath the site The model represents the
interbedded silts and fine sand layer and the overlying medium to fine sand surficial unit as one
layer The hydraulic conductivity ofthe modeled layer is 184 ftday The estimated areal
recharge for the model is 10 inyr The basement sump at Lot 3-30 on South Browneil Road
pumps groundwater year round The resulting depression ofthe water table is represented by a
constant head of 33128 ft which is approximately 8ft below ground surface at that location
Groundwater elevations used in the model were based on an average ofthe July 1999 and
December 1999 potentiometric surface in wells with screened intervals intersecting the water
table The model representation of current hydrologic conditions at the Study Area is shown in
Figure 4-1 Groundwater elevations are shown in meters on this figure
Two containment scenarios were evaluated The first was a source control application in
which the TWODAN model was used to determine the number of wells and pumping rates
required to contain the 10000 to 20000+ ugL TCE concentration zone as shown in Figure 1-2
In this scenario pumping would contain the contaminated groundwater nearest the source(s)
Over time if new contamination is not allowed to migrate from the source(s) the VOC
concentrations in the rest ofthe region of contaminated groundwater would attenuate The
second scenario was a containment application in which the TWODAN model was used to
determine the number of wells and pumping rate required to contain the 1000 to 10000 (igL
TCE concentration zone as displayed in Figure 1-2 In this scenario pumping occurs in the
downgradient portions ofthe contaminated groundwater
Each recovery well was assumed to be 4 inches in diameter fully screened and have a
pumping rate of 5 gpm The pumping rate was based on the aquifer testing results reported in the
SIR (HSI GeoTrans 2000) applied to a fully screened extraction well The results ofthe model
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000A1XINOFS9JX)10030929WPD 4-7 HSI GSOTraDS IflC
MITEC 104e 02385
analyses indicate that a minimum of three 4-inch diameter recovery wells pumping at 5 gpm are
required to contain the 10000 to 20000+ ugL TCE concentration zone The results of this
model simulation are shown on Figure 4-2 The model analyses also indicated that a minimum
often 4-inch diameter recovery wells pumping at 5 gpm are required to contain the 1000 to
10000 ugL TCE concentration zone Figure 4-3 shows the results of this model simulation
Figures 4-2 and 4-3 also show that groundwater extraction for hydraulic containment may induce
infiltration of surface water in response to pumping thereby reducing the amount of water
flowing in the brook
421 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 2 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with extraction well construction and treatment plant construction Access by
unauthorized personnel would be restricted by fencing temporary barriers andor warning signs
The groundwater treatment building would be locked and secured A health and safety plan
(HASP) would be prepared for the remedial activities In conformance with Occupational Safety
and Health Administration (OSHA) regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative Suitable dust control measures would be implemented during
construction ofthe groundwater treatment system Additionally the treatment process is
expected to be relatively simple with a low potential for exceedance of discharge limitations
Monitoring ofthe treatment process would be performed
Time to Achieve Remedial Action Objectives The time estimated for well installation
system debugging and establishing hydraulic gradient control is three to six months The RAOs
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^XM0030929wro 4-8 HSI GSOTraOS IIIC
MITEC 104e 02386
for groundwater would be achieved when monitoring results indicated that VOC concentrations
had attenuated and groundwater standards had been met It is estimated that attenuation of VOC
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of recovered groundwater would remove some ofthe VOCs from
the aquifer This treatment would generate residuals such as used filters and spent carbon This
process is irreversible
Reduction in Toxicity Mobility or Volume Treatment ofthe extracted groundwater
would reduce its toxicity prior to surface water discharge Contaminants adsorbed to any
secondary carbon would ultimately be destroyed during the process of regenerating the carbon
Contaminants adsorbed to any particulate filters would be landfilled or incinerated along with the
filters The toxicity and volume of contamination in groundwater are nominally reduced by
extraction and treatment but effectiveness is limited as discussed in Section 421 above
Modeling shows that groundwater extraction would be effective in reducing the mobility ofthe
dissolved phase contamination
Amount of Material Contained or Treated The volume of contaminated groundwater
that would be treated on a long-term basis is estimated at about 8 million gallons per year for the
source containment option and about 26 million gallons per year for containment of all dissolved
TCE concentrations greater than 1000 ugl
423 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
FOR ALLING INDUSTRIAL PARK MWPJXXTSN75320(XAAUJNOFS9-OCM0030929WKgt 4-9 HSI GSOTrSDS IDC
MITEC 104e 02387
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Groundwater pumping would control any risks caused by expansion ofthe
region of contaminated groundwater Residual risk to human health would be controlled through
institutional controls
Adequacy and Reliability of Controls Extracted groundwater would be treated on-site to
standards required for discharge to surface water The extraction well pumps and groundwater
treatment equipment would require maintenance on a long-term basis Groundwater monitoring
to ensure that the contamination was being adequately contained by the groundwater extraction
would be necessary on a long-term basis
Permanence of Remedy The groundwater treatment plant would be enclosed and
designed as a modular system and its equipment would be readily replaceable if required The
extraction wells may need to be rehabilitated andor replaced during the life ofthe remedy
424 COMPLIANCE WITH A R A R S
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to return the
remaining groundwater to below Groundwater Enforcement Standards Groundwater extraction
would also eventually return the areas of highest groundwater contamination to below
Groundwater Enforcement Standards
Surface Water Quality Standards Hydraulic control of the groundwater migration would
interrupt and remove contaminates from groundwater thereby preventing discharge to the
unnamed brook resulting in achievement of Water Quality Criteria for the protection of human
health and aquatic organisms (VTDEC 2000)
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200OALUNoFS9^Kgtl0030929wro 4-10 HSI GOOTrSDS IDC
laquoTEC I04e 02388
425 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The hydraulic containment alternative would offer protection to both human health and
the environment if expansion ofthe region of contaminated groundwater were identified Since
the risk assessment (Menzie Cura 2000a) found that under current conditions groundwater and
surface water concentrations are below levels which constitute a risk to human health and since
hydraulic containment would ensure the region of VOC-contaminated groundwater remained in
the current configuration hydraulic containment would be protective of human health and the
environment This alternative assumes institutional controls will be in place to continue sump
venting in the basement at Lot 3-30 on South Browneil Road restrict the installation of
basements below the water table within the region of VOC-contaminated groundwater and
prevent potable use of groundwater within the region of VOC-contaminated groundwater
Protection would be achieved at the end ofthe construction period of three to six months The
residual risks posed by contaminated material remaining within the groundwater would not be
significant because all potential exposure routes would be addressed
426 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction which would present no special problems
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AUB4CFS9^10l0030929wro 4 - 1 1 HSI GGOTrdDS IDC
MITEC 104e 02389
bull Reliability ofthe Technology Hydraulic gradient control is a frequently used
alternative that has proven effective in preventing further expansion of areas with
- contamination in groundwater Filtration air stripping and carbon absorption
have frequently been used and proven effective in treating groundwater in other
applications
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the
gradient control system was inadequate to restrict the expansion ofthe region of
contaminated groundwater implementation of additional resources would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
operate maintain and monitor the well head portions ofthe treatment system Institutional
controls would also be needed to implement institutional controls to continue sump venting in
the basement at Lot 3-30 on South Browneil Road The town must pass zoning restriction which
would prevent construction of basements below the water table and potable use of groundwater
within the region of contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor the groundwater treatment system associated with the hydraulic containment option
are available
427 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 2 The
capital costs would be $207000 for the source control application and $732000 for the
containment option OampM costs include groundwater monitoring and maintenance ofthe
groundwater extraction and treatment system These are $77000 per year for the source control
application and $139000 per year for the containment option The present worth analysis
(calculated at a 7 discount rate interest for 30 years) yields a total of $1085403 for the source
control application and $2287474 for the plume containment option
FOR ALLING INDUSTRIAL PARK MWPJXXSN753U0OOALUNGFS9-tfW0030929wro 4-12 HSI GSOTrailS IRC
MITEC 104e 02390
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS AND
PERMEABLE REACTIVE BARRIER
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull and a permeable reactive barrier would be installed and maintained at a
downgradient location to reduce concentrations of TCE dissolved in groundwater
as it flows under natural gradient flow conditions if groundwater monitoring
shows the region of VOC-contaminated groundwater is expanding in size
PRBs consist of a permeable region of chemically reactive materials constructed to
intercept the path of a dissolved groundwater contaminants Reactive materials may include
bull zero-valent iron for reductive dehalogenation
precipitation agents such as gypsum to create insoluble metal salts
bull sorptive agents such as granular activated carbon to capture and immobilize organics
bull reducing agents such as dithionite and hydrogen sulfide to reduce and insolubilize metals
and
bull biologic electron acceptors such as lactic acid or nitrate to enhance aerobic
biodegradation
FOR ALLING INDUSTRIAL PARK MAWPJX)CSVN7532000AmNOFS9-OOU0030929wpo 4-13 HSI GSOTrSDS IDC
MITEC 104e 02391
Zero-valent iron and granular activated carbon are both applicable for use in the treatment
of TCE in a PRB Granular zero-valent iron has been widely applied in PRB installations and
promotes reductive dehalogenation of TCE to chloride ion ethane and ethene Activated carbon
has been used in a limited number of field and lab studies to simply adsorb dissolved organic
constituents as they pass through thePRB
Because ofthe costs ofthe reactive or adsorptive material PRBs are generally
constructed as a funnel and gate system The funnel portion ofthe PRB is a typical vertical
barrier wall constructed of sheet piles bentonite or other impermeable material which is
designed to direct groundwater flow to the gate portion ofthe PRB containing the reactive or
adsorptive material Funnel and gate sections ofthe PRB are keyed together and generally to a
low permeablility zone located at depth
The use of permeable reactive barriers is not directly applicable to treatment of DNAPL
The mechanism for groundwater remediation using a PRB would include
bull dissolution ofthe DNAPL into groundwater by natural processes
bull downgradient transport ofthe dissolved contaminants to the PRB location
artificial channeling ofthe contaminated groundwater to the reactive material located in
the gate by the barrier funnel and
bull reductive dehalogenation or adsorption of a portion ofthe VOC as is passes through the
gate
A variety of methods are available for emplacement ofthe PRB The most conventional
method includes excavation of a trench and backfill will a soilbentonite slurry for the funnel
portion and granular iron or carbon in the gate section Other methods such as sheet-piling jet
grouting continuous trenching fracturing and others are available For the subject site because
ofthe presence of sand in the formation it is likely that a continuous trenching method would be
the most applicable and cost effective
FOR ALLING INDUSTRIAL PARK MWPJX)CSN7S320O0ALUNGFSraquo-O0U0030929wro 4-14 HSI GGOTfaDS IOC
MITEC 104e 02392
Operation maintenance and monitoring ofthe PRB is relatively simple Groundwater
samples would be periodically collected from locations upgradient and downgradient ofthe gate
section(s) ofthe PRB to monitor its effectiveness Media installed in the gate (iron or carbon)
would require periodic replacement probably on a annual basis for carbon and every 5 to 10
years for iron
The placement depth width and length ofthe PRB would depend on the region of
VOC-contaminated groundwater that was desired to be intercepted the depth to the underlying
low permeability layer and the desired TCE concentration reduction (which determines resident
time required in the gate) As wilh hydraulic containment two scenarios were investigated The
first a source control option would intercept VOC-contaminated groundwater with TCE
concentrations greater than 10000 ugL A PRB of approximately 1200 feet in length would be
required The second a region of contaminated groundwater containment option would
intercept VOC-contaminated groundwater with TCE concentrations in excess of 1000 ugL A
PRB of approximately 2200 feet in length would be required The depth ofthe PRB in both
cases would likely extend from ground surface to about 40 feet below ground surface The PRB
would be installed into the underlying areally-extensive clay layer Figure 4-4 shows the
placement ofthe PRB under each opinion
431 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 3 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with PRB construction since either conventional or continuous trenching methods
would be employed during its construction However exposure hazards during construction
would be considerable since the emplacement requires excavation and handling of a large
volume of potentially contaminated soils During construction access by unauthorized personnel
would be restricted by fencing temporary barriers andor warning signs Following
FOR ALLING INDUSTRIAL PARK
MWP_DOCSN753 2000 AUJNCFS9^10 10030929 WPD 4-15 HSI GSOTrSPS IDC
MITEC 104e 02393
construction little to no hazards should be expected from the long-term operation ofthe PRB A
HASP would be prepared for the construction activities In conformance with OSHA
regulations site workers would be trained required to wear appropriate protective equipment
and as applicable would be enrolled in a medical monitoring program Groundwater monitoring
wells would be sampled to determine changes in VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative with proper controls Suitable dust control vapor monitoring and
stormwater runoff measures would be implemented during construction ofthe PRB
Time to Achieve Remedial Action Objectives The time estimated for PRB emplacement
is four to six months The RAOs for groundwater would be achieved when monitoring results
indicated that the VOC concentrations have attenuated and groundwater standards have been
met It is estimated that attenuation of contaminant concentrations to ARARS will significantly
exceed the two-year time frame for short-term effectiveness This is because the application of a
PRB at the site would not significantly alter groundwater flow or TCE dissolution from within
the source area Therefore it would not increase the rate at which concentrations of residual
DNAPL or dissolved constituents of DNAPL (TCE) were removed from the source area It
would however limit the size ofthe region of VOC-contaminated groundwater
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of groundwater flowing through the permeable sections ofthe PRB
would remove the dissolved TCE as is flows under natural gradient conditions from the source
area
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNGFS9^X)10030929WPO 4-16 HSI G G O T T S O S jflC
MITEC 104e 02394
Reduction in Toxicity Mobility or Volume Treatment ofthe groundwater would reduce
its toxicity Contaminants adsorbed to carbon (if used as the treatment media in the gate sections
ofthe PRB) would be excavated on a periodic basis and ultimately be destroyed during the
process of regenerating the carbon
Amount of Material Contained or Treated The volumetric flux of contaminated
groundwater through the PRB is estimated to be approximately two million gallons per year for
the 10000 (igL source containment option and approximately four million gallons per year for
containment of all dissolved TCE concentrations greater than 1000 ugL
433 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Treatment of groundwater intersecting the PRB would control any risks
caused by expansion ofthe region of contaminated groundwater to the southeast Residual risk
to human health would be controlled through institutional controls
Adequacy and Reliability of Controls Performance of PRBs in reducing concentrations
of chlorinated organics such as TCE using zero-valent iron has been mixed Most ofthe PRB
performance demonstrations indicate that a concentration reduction of 60 to 90 percent can be
expected Some applications however have been much less successful at reducing VOC
concentrations Although little experience is available for PRBs using activated carbon the
removal efficiency should be expected to be greater and more reliable than zero-valent iron but
far more costly Groundwater monitoring would ensure that the contamination was being
adequately contained by the PRB and would be necessary on a long-term basis
Permanence of Remedy Installation of a PRB would be considered a permanent remedy
although periodic maintenance and replacement of reactive material in the gate would be
required for both carbon and iron-based systems
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9^X)l0030929wro 4-17 HSI GGOTfSnS IDC
MITEC 104e 02395
434 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to reduce VOC
concentrations in the remaining groundwater to below Groundwater Enforcement Standards
Natural gradient flushing would also eventually reduce the areas of highest groundwater
contamination to below Groundwater Enforcement Standards
Surface Water Quality Standards VOC concentrations in groundwater discharging to the
unnamed brook would be reduced significantly Thus operation ofthe PRB would result in
achievement of Water Quality Criteria for the protection of human health and aquatic organisms
(VTDEC 2000)
435 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This downgradient containment alternative would offer protection to both human health
and the environment if VOC concentrations in groundwater discharging to the unnamed brook
were to increase or if the region of contaminated groundwater were to expand in size This
alternative assumes institutional controls will be in place to continue sump venting in the
basement at Lot 3-30 on South Browneil Road restrict installation of new basements below the
water table within the region of VOC-contaminated groundwater and prevent potable use of
groundwater within the contaminated region Protection relative to the risks posed by expansion
ofthe region of contaminated groundwater to the unnamed brook would be achieved at the end
ofthe construction period of four to six months The residual risks posed by contaminated
material remaining within the groundwater would not be significant because all potential
exposure routes would be addressed
FOR ALLING INDUSTRIAL PARK MWP JX3CSN753V2000AIXINOFS90Crl0O30929wPD 4-18 HSI GCOTtSHS IRC
MITEC 104e 02396
436 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
bull Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction Removal and handling of contaminated soils
presents potential risks to construction workers during construction which could
be minimized through health and safety controls
bull Reliability of the Technology Although many full-scale applications of this
approach have been conducted they have been relatively recent Long-term
reliability and effectiveness of PRBs has not been established
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the PRB
was inadequate to prevent expansion ofthe region of VOC-contaminated
groundwater implementation of additional resources would not be hampered by
this alternative
Administrative Feasibility Installing and maintaining the PRB will require access to
properties overlying the region of VOC-contaminated groundwater Additionally property
owner cooperation would be needed to operate maintain and monitor wells located upstream
and downstream ofthe gate sections ofthe PRB system Restrictions would also be needed to
implement institutional controls to continue sump venting in the basement at Lot 3-30 on South
Browneil Road restrict the construction of basements below the water table within the region of
VOC-contaminated groundwater and prevent potable use of groundwater within the region of
VOC contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UO(XAAUJNOFS9-O0 10030929 WPO 4-19 HSI GGOTrSMS IDC
MITEC 104e 02397
Availability of Services and Materials The materials equipment and personnel required
to design install and maintain the PRB are readily available
437 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 3 The
capital costs would be $572000 for the source control application and $1022000 for the
containment option OampM costs include groundwater monitoring and periodic replacement of
the permeable barrier These average $64000 per year for the source control application and
$112000 per year for the containment option The present worth analysis calculated at a 7
discount rate over a 30-year duration yields a total of $1277356 for the source control option
and $2248691 for the containment option
4 4 A L T E R N A T I V E 4 M O N I T O R I N G I N S T I T U T I O N A L C O N T R O L S AND
N A T U R A L A T T E N U A T I O N
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water
The chief mechanisms contributing to reduction of contaminant concentrations in
groundwater by natural attenuation include biotransformation dilution dispersion and discharge
through advective flow and volatilization (EPA 1998) Volatilization is not likely a major
mechanism at the Study Area since contaminated groundwater is located at depth below the
FOR ALLING INDUSTRIAL PARK
MWP_DOCSW7S3U000WXINoFS9-001003O929wro 4-20 HSI GGOTfaDS IDC
MITEC 104e 02398
water table A natural attenuation evaluation will be conducted to better identify the mechanisms
contributing to concentration reduction through natural attenuation Monitoring to be completed
for this evaluation is included in Section 62 EPAs Technical Protocol for Evaluating Natural
Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) was used as the basis for the
design ofthe natural attenuation evaluation
441 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community A HASP would be prepared for the remedial
activities In conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Groundwater monitoring wells would be sampled to determine changes in
VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative
Time to Achieve Remedial Action Objectives The RAOs for groundwater would be
achieved when monitoring results indicated that the region of contaminated groundwater had
naturally attenuated and groundwater standards had been met It is estimated that natural
attenuation of contaminants to ARARS will exceed the two-year time frame for short-term
effectiveness
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0ALUNOFS9^X)M0030929wro 4-21 HSI GGOTfaflS jflC
MITEC 104e 02399
Treatment This alternative involves only natural in-situ processes No remediation
wastes would be generated
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area
Amount of Material Contained or Treated Natural attenuation may serve to contain the
region of VOC-contaminated groundwater at the Study Area Treatment may be accomplished
through biotransformation ofthe contaminants to environmentally acceptable compounds
443 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation of VOC-contaminated groundwater at the Study Area
would eventually achieve the ARARs Residual risk to human health would be controlled
through institutional controls Implementing institutional controls to maintain the sump venting
at Lot 3-30 on South Browneil Road restrict the construction of basements below the water table
within the region of VOC-contaminated groundwater and to control the use of groundwater
within the region of VOC-contaminated groundwater for potable purposes would provide
protection against the potential for exposure
Adequacy and Reliability of Controls Monitoring for VOC concentration reductions in
groundwater and institutional controls would be the main controls of this alternative Sump
venting at Lot 3-30 on South Browneil Road would prevent indoor air impacts at this location
and restrictions on construction of basements below the water table would prevent future indoor
air impacts Control ofthe use of groundwater within the region of VOC-contaminated
groundwater for potable purposes would minimize potential use of groundwater with VOCs
above federal and state drinking water standards Groundwater monitoring would ensure that
attenuation of VOC concentrations was proceeding and provide for periodic assessment ofthe
region of VOC-contaminated groundwater in the Study Area
FOR ALLING INDUSTRIAL PARK bull MWPJXXSN7532000AUINOFS9-00I0O30929WPD 4 - 2 2 HSI GGOTPaMS IRC
MITEC 104e 02400
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time
444 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
445 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
446 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK _
M W P _ D O C S N 7 5 3 U O O O A L U N O F S 9 - O O U 0 0 3 0 9 2 9 W P O 4-23 HSI GGOT 13118 IflC
MITEC 104e 02401
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
bull Ability to Construct the Alternative No major construction is included in this
alternative
bull Reliability ofthe Technology Ongoing monitoring and evaluation on would
ensure that natural attenuation was controlling and remediating the contaminated
groundwater
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation was not restricting the size ofthe region of VOC-contaminated
groundwater implementation of additional remedial actions would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
sample and maintain monitoring wells Restrictions would also be needed to implement
institutional controls to continue sump venting in the basement at Lot 3-30 on South Browneil
Road restrict construction of basements below the water table in VOC-contaminated
groundwater and prevent potable use of groundwater within the region of VOC-contaminated
groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor natural attenuation are also available
447 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 4 The
capital costs would be $55000 and include the initial natural attenuation evaluation and the
implementation of institutional controls OampM costs include groundwater monitoring These are
$9000 per year The present worth analysis yields a total of $163083 for this 30-year
alternative
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0AUJNOFS9^X)10030929wro 4-24 HSI GGOTraDS 1110
MTECl04e 02402
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water and
phytoremediation would be used to intercept TCE-contaminated groundwater
where it discharges to the unnamed brook
In this alternative all components of Alternative 4 would be implemented and
phytoremediation would be implemented in the area where TCE- contaminated groundwater
intersects the unnamed brook to intercept the contaminated groundwater and reduce the amount
of VOCs reaching the brook Phytoremediation of VOCs is still an experimental technology
Several field studies have used hybrid poplars (EPA 2000) to extract TCE- contaminated
groundwater It has been shown that TCE is removed along with groundwater by the trees and
metabolized as well as transpired from the leaves The rate of TCE contaminant removal from
the groundwater and its discharge to air by transpiration varies based on site specific conditions
and season Therefore contaminant or groundwater removal rates are impossible to predict at
this time without field studies Trees may be subject to destruction by natural disasters and pests
Their condition must be monitored and they may require replacement
F O R ALLING INDUSTRIAL PARK MWPJXXSN7532OOOWXINGFS9JraquoIOO30929WPO 4 - 2 5 H S I G G O T r S D S IOC
MITEC 104e 02403
In order for interception ofthe region of contaminated groundwater to be effective the
trees must be planted so that the root zone intercepts the contaminated groundwater Due to the
depth ofthe higher VOC concentrations in most areas ofthe site phytoremediation would be
ineffective in containing expansion ofthe region of contaminated groundwater An exception to
this is the area near the unnamed brook According to the SIR (HSI GeoTrans 2000) VOC-
contaminated groundwater appears to be discharging upward in groundwater into the unnamed
brook Trees planted along the border ofthe brook may help to intercept this contaminated
groundwater before it discharges into the brook
451 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 5 are as follows
Protection of Workers and the Community Normal landscaping hazards would be
associated with installation ofthe trees A HASP would be prepared for the remedial activities
In conformance with OSHA regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative Suitable dust control measures would be implemented during
planting of trees
Time to Achieve Remedial Action Objectives The time required for maximum
interception ofthe contaminated groundwater by the trees would depend on site specific
conditions such as root growth rate and tree survival rate The RAOs for groundwater would be
achieved when monitoring results indicated that VOC concentrations had attenuated and
groundwater standards had been met It is estimated that natural attenuation of contaminant
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
FOR ALLING INDUSTRIAL PARK MWP J X 3 C S N 7 5 3 2 0 0 0 A U J N O F S 9 ^ ) 0 1 0 0 3 0 9 2 9 W P D 4-26 HSI G G O T H S I I S IDC
MITEC 104e 02404
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment This alternative involves only in-situ treatment ofthe groundwater Plant
tissue would be analyzed for the presence of VOCs Plant materials can bio-accumulate metals
present in soil and groundwater If concentrations are high enough dead plant matter may have
to be disposed in an appropriate manner
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area Phytoremediation may
metabolize some ofthe VOCs
Amount of Material Contained or Treated Natural attenuation and phytoremediation
may serve to prevent expansion ofthe region of VOC-contaminated groundwater at the Study
Area Treatment is accomplished with biotransformation ofthe contaminants to environmentally
acceptable compounds
453 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation ofthe region of VOC-contaminated groundwater and
phytoremediation at the Study Area would eventually achieve the ARARs Implementing
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil Road
restrictions on construction of basements below the water table in regions of VOC-contaminated
groundwater and to control the use of groundwater for potable purposes within the region of
VOC-contaminated groundwater would provide protection against the potential for exposure
FOR ALLING INDUSTRIAL PARK MWP_IXXSW532000ALL1NOFS9^)0I0030929WTO 4-27 HSI GCOTraDS IflC
M l T E C l 0 4 e 0240S
Therefore despite the fact that an extended time period may be required to reduce VOC
concentrations to an acceptable level the residual risk associated with this alternative would be
minimal Trees planted near the unnamed brook may serve to intercept contaminated
groundwater before it discharges to this receptor
Adequacy and Reliability of Controls Groundwater monitoring for natural attenuation
institutional controls and interception of contaminated groundwater before it reaches the
unnamed brook would be the main controls of this alternative Sump venting at Lot 3-30 on
South Browneil Road would prevent indoor air impacts at this location and restriction on the
construction of new basements below the water table within the region of VOC-contaminated
groundwater would prevent future indoor air impacts at other locations Control ofthe use of
groundwater for potable purposes within the region of VOC-contaminated groundwater would
minimize potential use of groundwater with VOCs above federal and state drinking water
standards Groundwater monitoring would ensure that natural attenuation of contaminants was
proceeding and provide for periodic assessment ofthe region of VOC-contaminated groundwater
in the Study Area Groundwater and surface water monitoring would also be conducted to
monitor success ofthe phytoremediation in intercepting contaminated groundwater before it
reaches the unnamed brook
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time Trees must be monitored and will be replaced in
the event of destruction by severe weather pests or other reasons
454 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUINOFS9-00I0030929WPD 4-28 HSI GGOTraflS IllC
MITEC 104e 02406
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
Phytoremediation at the edge ofthe unnamed brook would further reduce the VOC
concentrations in groundwater discharging to the brook
455 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
456 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
Ability to Construct the Alternative Installation of this alternative requires
landscaping skills which are readily available
bull Reliability ofthe Technology Ongoing monitoring and evaluation would ensure
that natural attenuation was controlling and remediating the contaminated
groundwater Ongoing monitoring ofthe condition ofthe trees would also be
required to ensure they are continuing to grow and do not need replacement
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^)OM0030929WPD 4-29 HSI GGOTfaDS jflC
MITEC 104e 02407
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation and phytoremediation were not restricting the size ofthe region of
VOC-contaminated groundwater implementation of additional resources would
not be hampered by this alternative
Administrative Feasibility Planting trees and if necessary installing and monitoring
additional wells might require access to private property Additionally property owner
cooperation would be needed to sample and maintain monitoring wells Restrictions would also
be needed to implement institutional controls to continue sump venting in the basement at Lot 3shy
30 on South Browneil Road restrict construction of new basements below the water table in
regions of VOC-contaminated groundwater and prevent potable use of groundwater within the
region of VOC-contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to plant the trees and monitor natural attenuation are also available
457 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 5 The
capital costs would be $80000 and include the initial natural attenuation evaluation the
implementation of institutional controls and installation of a phytoremedial barrier of poplars
OampM costs include groundwater monitoring and maintenance ofthe phytoremedial barrier
These are $11000 per year The present worth analysis yields a total of $209397 for this 30shy
year alternative
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000ALLINOFS9^)0I0030929WPD 4-30 HSI GGOTfaDS IPC
MITEC 104e 02408
r TI Table 41 Cost estimates for remedial alternatives i deg 5 70
8 P
QUANTITY UNITS UNIT C O S T CAPITA L C O S T ANNUAL
OampM C O S T
5 n Alternative I No Action 8 O a Q
na na $0 $0 $0 a sect
Total $0 $0
Alternative 2 Monitoring Institutional Controls and Hydraulic Containment
1) Implement Institutional Controls 32 properties $10000 $32000
2) Groundwater Monitoring $9000
3) Pumping System
Option 1 Source Containment
Extraction wellspiping $50000 $15000
Electrical distributioncontrol $25000 $8000
Construction oversight $25000
Groundwater treatment system $75000 $45000
Total Option 1 $207000 $77000
Option 2 region of contaminated
groundwater Containment
Extraction wellspiping $175000 $35000
w Electrical distributioncontrol $50000 $20000
O
o H mO Construction oversight $125000
o n gt Groundwater treatment system $350000 $75000
o z 0) Tolal Option 2 $732000 $139000
i deg QUANTITY UNITS UNI T C O S T
5 so
Alternative 3 Monitoring Institutional Controls and Permeable Barrier
m t - 1) Implement Institutional Controls 32 properties $10000
9 O 2) Groundwater Monitoring
| o 3) Permeable Harrier
Option I Source Containment
Barrier installation 1200 feel $450
Total Option 1
Option 2 region of contaminated
groundwater Containment
Barrier Installation 2200 feet $450
w Total Option 2 NJ
Alternative 4 Monitoring Institutional Controls and Natural Gradient Flushing
1) Implement Institutional Controls 32 properties $10000
2) Groundwater Monitoring
3) Natural Attenuation Evaluation
Total
Alternative 5 Monitoring Institutional Controls Natural Gradient Flushing and Phytoremediation
1) Implement Institutional Controls 32 properties $10000 X (A 2) Groundwater Monitoring
reg 3
o m O H
3) Natural Attenuation Evaluation
4) Phytoremediation
gt z Total (A
Notes na = not applicable
CAPITAL C O S T
$32000
$540000
$572000
$990000
$1022000
$32000
$23000
$55000
$32000
$23000
$25000
$80000
ANNUAL
OampM C O S T
$9000
$55000
$64000 1
$103000
$112000
$9000
$9000
$9000
$2000
$11000
MODEL CALCULATED GROUNDWATER CONTOUR IN FEET ABOVE MEAN SEA LEVEL
APPROXIMATE PROPERTY BOUNDARY
M6-2 raquo EXISTING MONITORING WELL
CP-6 bull EXISTING SOIL BORING
M 8 - 2 raquo MONITORING WELL (RESAMPLED)
bull SMALL DIAMETER BORING - BELOW CLAY
bull BEDROCK MONITORING WELL
A S I - 2 I H S I GEOTRANS WELL CLUSTER LOCATION
U-TRIB-8a SURFACE WATER SAMPLING LOCATION R S - U
a PASSIVE SAMPLER LOCATION
T2-2 PROFILE SAMPLE LOCA1ION (JOHNSON COMPANY 1999)
WELL DESTROYED
TEF Concentrat ions ( u g A l
1000 - 10000
iry IOOOO - 20000
bull 20000 + NOTES AREA WHERE TCE CONCENTRATION IS
M l LOCATIONS APPROXIMATE INTERPOLATED THERE IS NO TCE
BASE PUN DEVELOPED FROM DATA FROM THESE AREAS
1 TOWN OF WUUSION PARCEL BOUNOART MAP (SHIPPED 121597) PROVIDED ST (VS (BURUNCTON VT) IN DXF FORMAT
2 PLAN DEVELOPED BT HEINDEL AND NOTES (BURUNCTON VT) FOR THE BATES PROPER1Y 1NVESIBAT10N AND PROVIDED TO THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION HASTE MANAGEMENT DIVISION 1997
3 ORTHOPHOTO SHEET 100216 VERMONT STATE MAPPING PROJECT 1988
4 TORN OF WIUJSTON ASSESSORS MAP 1997
5 VARIOUS SITE PUVQ CN RLE WITH THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION WASTE HMUGElENr OOVBON
6 DM FROM JOHNSON DD REPORT UNTIED GROUNDWXIER IHVESI1CAH0M ALLWC INDUSTRIAL PARK DATED 7 W FDR THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Modeled Site - Existing Conditions copy H
pound n Williston Vermont o CHECKED MS HSI
DRAFTED RMK GEOTRANS FU fa-Site-mod-ECdwg 4 - 1 A TITIA T t n HBVAIT
DATE 10600
5 COMPARATIVE EVALUATION OF ALTERNATIVES
The purpose of this section is to compare the remedial alternatives on the basis ofthe
evaluation criteria developed and discussed in Section 4 and provide a recommended alternative
These criteria include overall protection of human health and the environment short-term
effectiveness reduction of toxicity mobility or volume long-term effectiveness and
permanence compliance with ARARs implementability and cost
The comparative analysis is conducted to highlight significant differences between
identified alternatives All alternatives for the Study Area groundwater except the no-action
alternative include the following
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater and
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
The no-action alternative is not included in the comparison provided in the following
sections since it would not meet the RAOs All four ofthe remaining alternatives would meet
the RAOs stated in Section 32
51 SHORT-TERM EFFECTIVENESS
Protection of Workers and the Community Groundwater would be monitored under all
scenarios to look for any changes in VOC concentration which might result in increased risk
The containment options in Alternatives 2 3 and 5 would be more protective ofthe community
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320MAUINOFSWWI0030929WPD 5 - 1 HSI GSOTrSflS IflC
MITEC 104e 02415
if the region of VOC-contaminated groundwater were shown to be expanding and presenting
increased risk However in the event that the region of VOC-contaminated groundwater is not
expanding Alternative 4 would be equally protective Under all options a HASP would be
prepared and in conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Alternatives 2 3 and 5 would involve normal construction hazards during
installation of pumping wells piping trenches treatment enclosures permeable reactive barrier
trenches or planting of trees In addition under Alternative 5 release of VOCs to air through
transpiration may need to be measured to prevent creation of a new exposure pathway and health
risk through air
Environmental Impacts Minor additional impacts may occur during installation of
Alternatives 2 3 and 5 due to dust and sediment production Groundwater would need to be
treated to regulatory discharge limits before discharge under Alternative 2 and treatment may be
temporarily hampered in the event of treatment system mechanical failure Because ofthe
experimental nature of phytoremediation greater uncertainty exists that the trees will be effective
in acting as a barrier to expansion ofthe region of contaminated groundwater to the unnamed
brook under Alternative 5 If it is shown that expansion ofthe region of contaminated
groundwater toward the unnamed brook poses a future health risk additional measures may
become necessary to contain the contaminated groundwater
Time to Achieve Remedial Action Objectives None ofthe alternatives has an appreciably
shorter time frame than the others in reducing groundwater concentrations to VT Groundwater
Enforcement Standards and VT Water Quality Criteria This is because while Alternatives 2 3
and 5 rely on engineered remedies to contain the region of contaminated groundwater residual
TCE DNAPL and geologic heterogenieties will cause the contaminant source to persist for an
extended time As discussed in Section 34 active DNAPL removal alternatives were removed
during the preliminary screening DNAPL has never been directly observed at the Study Area
and is assumed to be present based on dissolved concentrations of TCE DNAPL distribution is
FOR ALLING INDUSTRIAL PARK MWP_DOCSW753200OALLINOFS9-00M0O30929wPD 5-2 HSI GGOTr3nS IflC
MITEC 104e 02416
expected to occur heterogeneously at residual saturation and it is infeasible to locate the DNAPL
to treat it directly Because of this each ofthe remedies is expected to exceed the two-year time
frame for short term effectiveness
52 R E D U C T I O N O F T O X I C I T Y M O B I L I T Y O R V O L U M E T H R O U G H
T R E A T M E N T
Treatment All ofthe proposed alternatives would treat the residual DNAPL source of
contamination through dissolution and natural gradient flushing While Alternatives 2 3 and 5
are intended primarily for containment and not groundwater restoration these alternatives would
actively treat some concentrations in groundwater
Reduction in Toxicity Mobility or Volume The containment Alternatives 2 3 and 5
may result in decreased mobility ofthe region of contaminated groundwater However
groundwater monitoring may show that the region of contaminated groundwater is not
expanding under existing conditions If this were the case containment would not result in any
additional decrease in size ofthe region of VOC-contaminated groundwater
Since Alternatives 2 3 and 5 treat concentrations in groundwater without treating the
residual DNAPL source and the amount of contaminants that can be removed from groundwater
by these methods would likely equal the amount added by continued dissolution ofthe DNAPL
sources alternatives 2 3 and 5 would not result in a greater reduction in the total volume of
contaminant than Alternative 4
Amount of Material Contained or Treated As described above the amount of material
contained under Alternatives 2 3 and 5 would not be any greater than under Alternative 4 unless
the size ofthe region of VOC-contaminated groundwater is not presently contained by natural
attenuation If natural attenuation is currently controlling the size ofthe region of VOC-
contaminated groundwater then the amount of contaminants being removed by natural processes
equals the amount added by dissolution of residual DNAPL In this case intercepting and
removing contaminants from the groundwater using one ofthe containment alternatives will not
result in a significant increase in the amount of contaminant treated
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000ALUNOFS9-OOUM30929WPD 5-3 HSI GGOTrdHS jflC
MITEC 104e 02417
53 LONG-TERM EFFECTIVENESS
Residual Risk Implementing institutional controls to maintain the sump venting at Lot 3shy
30 on South Browneil Road to restrict construction of buildings with basements below the water
table within the region of VOC-contaminated groundwater and to control the use of groundwater
for potable purposes within the region of VOC-contaminated groundwater would provide
protection against the potential for exposure to existing concentrations in groundwater
Therefore despite the fact that some ofthe remedial alternatives may be required to operate for
an extended time the residual risk associated with any ofthe alternatives would be minimal
Adequacy and Reliability of Controls Alternative 5 has the least reliable controls
because ofthe difficulty in predicting the effectiveness of phytoremediation The second least
reliable alternative would be Alternative 2 because of its reliance on mechanical equipment to
maintain containment and to meet discharge standards
Permanence of Remedy All ofthe proposed alternatives would rely on permanent
destruction of contaminants through natural attenuation over time If one ofthe containment
technologies are required maintenance and periodic replacement would be necessary to ensure
containment was maintained until expansion ofthe region of VOC-contaminated groundwater
was no longer a threat This maintenance would be straight-forward and easy to continue for any
of the containment alternatives
54 COMPLIANCE WITH ARARs
All ofthe alternatives would eventually reduce contaminant concentrations within the
current region of contaminated groundwater to below VT Groundwater Enforcement Standards
and VT Water Quality Criteria
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Each ofthe alternatives would rely on groundwater monitoring and institutional controls
on venting basement sumps at Lot 3-30 on South Browneil Road restrictions on the construction
of new basements below the water table within the region of VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWPJX3CSN7S3UOOOAUJNGFS9-OOUM30929wro 5-4 HSI GOTr3nS IflC
MITEC 104e 02418
and potable use of groundwater from within the region of VOC-contaminated groundwater to
maintain conditions protective of human health and the environment If monitoring shows that
natural attenuation is not restricting the size ofthe region of VOC-contaminated groundwater
then one ofthe containment alternatives would be more protective than Alternative 4
56 IMPLEMENTABILITY
The most easily implemented alternativewould be Alternative 4 as it would not require
any installation but only groundwater monitoring to gauge the progress of natural attenuation
Alternative 5 requires all the components of Alternative 4 and adds trees along the unnamed
brook Alternatives 2 and 3 are the most difficult to implement as they require disruptive and
invasive installation techniques However the necessary equipment materials workers and
specialists required to implement all the alternatives are available
57 COSTS
The present worth costs range form a low of $163083 for Alternative 4 to a high of
$2287474 for the containment option of Alternative 3 These present worth costs were based on
a 30-year service period and an annual discount rate of seven percent
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALLINOFS9-OOM0030929WPD 5-5 HSI GGOTfaDS IflC
MITEC 104e 02419
6 PREFERRED REMEDY
61 PREFERRED REMEDY
Alternatives 2 34 and 5 are all protective of human health and the environment and rely
on the following technologies
bull groundwater monitoring to evaluate spatial and temporal trends in VOC
concentration
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil
Road
restrictions on the construction of new buildings within the region of VOC-
contaminated groundwater to prevent unacceptable concentrations of volatile
compounds in indoor air and
institutional controls to restrict the use of groundwater for potable purposes within
the region of VOC-contaminated groundwater
All ofthe alternatives rely on dissolution and natural gradient flushing to treat the
residual DNAPL source of groundwater contamination Therefore none ofthe alternatives has
an appreciably shorter time frame than the others in reducing groundwater concentrations to VT
Groundwater Enforcement Standards and VT Water Quality Criteria
Alternative 4 includes remediation by natural attenuation There is no active containment
technology associated with Alternative 4 As such it is simpler less costly and easier to
implement than Alternatives 2 3 and 5 which include some form of active containment ofthe
region of VOC-contaminated groundwater Containment could become necessary under
Alternative 4 if future groundwater quality monitoring indicates the region of VOC-contaminated
groundwater is impacting a sensitive receptor or is expanding in size and not contained by natural
attenuation The SIR (HSI GeoTrans 2000) risk assessment (Menzie Cura 2000a and 2000b)
showed that under current conditions groundwater was not impacting any receptors to a degree
FOR ALLING INDUSTRIAL PARK MWPJXXrSN7532000ALUNcFS9-OOU0030929WO 6 - 1 HSI GSOTraflS jflC
MITEC 104e 02420
that would represent a human health risk or risk to the environment Therefore containment is
not necessary to protect any sensitive receptors currently being impacted by the region of
contaminated groundwater Continued groundwater monitoring is required to demonstrate
whether the region of VOC-contaminated groundwater is stable in size or expanding
Alternative 4 has been selected as the preferred remedy On-going monitoring ofthe
effectiveness of natural attenuation in containing and remediating the region of VOC-
contaminated groundwater is part ofthe remedy Further details on this proposed monitoring are
provided in Section 62 If monitoring shows that size ofthe VOC-contaminated region is not
contained by natural attenuation then one ofthe other technologies could be used to supplement
Alternative 4 based on the nature ofthe expansion ofthe region of contaminated groundwater
If monitoring data indicates that VOC concentrations in the groundwater discharging to the
unnamed brook have increased and pose an unacceptable risk to human health and the
environment then phytoremediation could be considered in this location Phytoremediation
would be less costly than installation of a permeable reactive barrier or active groundwater
extraction system Phytoremediation would be ineffective in containing expansion ofthe region
of contaminated groundwater in the rest ofthe Study Area however because contaminated
groundwater is further below ground surface in these regions and phytoremediation is limited by
the depth ofthe roots ofthe selected plant If monitoring data indicates that the southwestern
portion ofthe region of VOC-contaminated groundwater is expanding then Alternative 4 could
be supplemented with extraction wells or a PRB for hydraulic containment
62 MONITORING PROGRAM
In its guidance document Use of Monitored Natural Attenuation at Superfund RCRA
Corrective Action and Underground Storage Tank Sites (EPA 1999) EPA states that long-term
performance monitoring will be a fundamental component of any remedy which relies on
monitored natural attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000 A1XINOFS9-00 I0030929 WPO 6-2 HSI GSOTrSDS IMC
MITEC 104e 02421
The SIR (HSI GeoTrans 2000) concluded that there were not sufficient temporal data to
determine whether the region of VOC-contaminated groundwater was stable in size or
expanding Continued monitoring for the compounds of concern will be necessary to confirm
that the region of VOC-contaminated groundwater is not expanding Table 6-1 identifies
locations which are proposed to be monitored annually to evaluate spatial and temporal trends in
VOC concentration These locations are shown in Figure 6-1
There are several mechanisms by which natural attenuation occurs These include
dilution of contaminant concentrations sorption ofthe contaminant onto the soil matrix and
biodegradation ofthe contaminant to a less toxic form Further study is necessary to determine
the contribution of each of these mechanisms to overall attenuation ofthe area of VOC
contamination
Evidence of biodegradation can be obtained by collecting three types of data of increasing
complexity (National Research Council 1993)
bull documentation of contaminant loss or transformation in the field
bull the presence of electron donors and acceptors andor alteration of groundwater
chemistry consistent with intrinsic biodegradation processes and
microcosm studies which provide direct microbiological evidence that indigenous
bacteria are capable of mediating the contaminant transformations observed
Microcosm studies are typically not employed unless the contaminant is unique or the
transformation which is being observed is not well documented in the literature For the
transformations anticipated in the Study Area numerous laboratory and field studies have
established that naturally-occurring bacteria are capable of mediating the contaminant
transformations of contaminants of concern For that reason microcosm studies will not be
performed as part of this study
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^)OM0030929 WPO 6-3 HSI GSOTrSHS jflC
MITEC 104e 02422
Of particular concern to the determination of biodegradation is the delineation of aerobic
and anaerobic zones within the contaminant area because these zones dictate the types of
biological degradation that would be expected to occur Oxygen is the primary electron acceptor
during aerobic oxidation Anaerobic processes including denitrification iron-reduction sulfate-
reduction and methanogenesis occur in the absence of oxygen and use nitrate iron (III) sulfate
and carbon dioxide respectively as primary electron acceptors Reductive dehalogenation of
TCE has been observed under iron-reducing sulfate-reducing and methanogenic conditions
although very low redox (ie methanogenic) conditions may be necessary for production of
ethene and ethane
Further sampling and analysis of selected parameters in groundwater will be conducted to
assess the potential for biodegradation in accordance with EPAs Technical Protocol for
Evaluating Natural Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) The
twelve sampling locations shown in Table 6-1 used to monitor ofthe area of VOC contamination
will also be sampled for parameters used to evaluate biodegradation The parameters include
compounds of concern and compounds which are degradation products ofthe compounds of
concern shown in Table 6-2 Table 6-3 lists parameters chosen to evaluate the presence of
electron donors and a groundwater chemical environment conducive to biologic reductive
dechlorination These parameters will be sampled once unless evaluation ofthe data indicates
that further sampling would be beneficial to calculate a rate of attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000ALUNCFS9JraquoM0030929 WPD 6-4 HSI GSOTfaHS IDC
MITEC 104e 02423
Table 6-1 Sampling locations
LOCATION
ID
ASI-32D2
RB-1
ASI-26D2
ASI-I6D2
ASI-13D2
ASI-23D2
ASI-18D2
ASI-12D2
ASI-01D2
ASI-09D2
U-TRIB-5
SW-I
Notes BGS =
SCREENED
INTERVAL
DEPTH BGS
35-40
35-40
35-40
30-35
31-36
25-30
32-37
35-40
31-36
31-36
surface
surface
Below Ground Surface
RATIONALE
Upgradient of region of highest VOC concentrations
Closest to lot 19-11 former lagoon and septic leach field source areas
Within area of highest concentrations
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient ofthe region of VOC concentrations in the southwest direction
Downgradient of source area within region of VOC concentrations in southeast direction
Downgradient of source area within region of VOC concentrations in southeast direction
At downgradient edge of region of VOC concentrations in southeast direction
Stream upgradient of VOC discharge from groundwater
Stream at location of VOC discharge from groundwater
(
FOR ALLING INDUSTRIAL PARK MWP DOCSN7532000ALUNCFS9^X)VI0030929WPO 6-5 HSI GeoTrans inc
MITEC 104e 02424
Table 6-2 VOC analytes
PARAMETER
TCE
PCE
11-DCE
cis 12-DCE
trans 12-DCE
Vinyl Chloride
Benzene
Toluene
Ethylbenzene
Xylenes
ANALYTICAL METHOD
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
8260A
8260A
8260A
8260A
RATIONALE |
Contaminant of Concern
Contaminant of Concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
Notes SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical
Methods SW-846 US EPA 3ri edition 1986
TCE = Trichloroethene
PCE = Tetrachloroethene
11-DCE = 11-Dichloroethene
cis 12-DCE = cis 12-Dichloroethene
trans 12-DCE = trans 1 2-Dichloroethene
FOR ALLING INDUSTRIAL PARK MAWP DOCSN75320laquoMLUNOFS9^XM0030929WPO 6-6 HSI GeoTrans inc
MITEC 104e 02425
Table 6-3 Parameters to evaluate biodegradation
PARAMETER ANALYTICAL METHOD RATIONALE
Field Parameters
Alkalinity as CaCO Hach Alkalinity Test Kit Model ALP Positive correlation between microbial activity and
MG-L alkalinity Measures the buffering capability of
groundwater
Total Ferrous Iron Hach Method 8146 May indicate anerobic degradation
Dissolved Hydrogen Reducing Gas Detector Predicts possibility for reductive dechlorination
Dissolved Oxygen Direct Meter Reading Indicates probability of aerobic vs aerobic
degradation
PH Direct Meter Reading Aerobic and anaerobic biological processes are pH
sensitive
Redox potential (Eh) A2580B An indicator ofthe relative tendency of a solution
to accept or transfer electrons
Specific Conductivity Direct Meter Reading Used to determine when purging of a well for
sampling is complete
Temperature Direct Meter Reading Affects the metabolic activity of bacteria and the
solubility of dissolved gasses
Laboratory Analyses
Dissolved Organic Carbon SW 9060 Carbon and energy source which can drive
dechlorination
Nitrate-N IC Method E300 At higher concentrations may compete with
reductive pathway
Total Manganese EPA 2007 or 2009 To determine if anaerobic biological activity is
solubilizing Mn for the aquifer matrix
Chloride SW 9250 Can be used as a conservative tracer to estimate
biodegredation rates
Sulfate IC Method E300 May be used as an electron acceptor for
biodegradation after dissolved oxygen and nitrate
are depleted
Sulfide IC Method E300 Indicates if reductive pathway is possible
Ethane SW 3810 Modified Daughter product of Ethene
Ethene SW 3810 Modified Daughter product of Vinyl Chloride
Methane SW 3810 Modified Ultimate reductive daughter product
Notes Rationales taken from USEPA 1998
Hach refers to Hach Company Catalogue
A refers to Standard Methods for the Examination of Water and (fostewater 18 edition 1992
E refers to Methods for Chemical Analysis of Water and Wastes US EPA 1983
SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical Methods SW-846 US EPA 31 edition
1986
FOR ALLING INDUSTRIAL PARK | C I nr A^Twmrmr bullbullltlaquo MWP DOCSN7532000ALLINCFS9-0Ol0030929wro 6-7
MITEC 104e 02426
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REFERENCES
Brinkerd 1996 Site Investigation Ailing Industrial Park Williston Vermont April to
September 1996 October 1996
Fitts C R 1997 TWODAN documentation prepared by Dr Charles Fitts Scarborough Maine
Griffin 1995 Monitor Well Log (MW-4) and Analytical Data Bove-Fagan Ice Cream
Distribution Investigation Williston VT Griffin International Inc
HSI GeoTrans Inc 2000 Site Investigation Report June 15 2000
Johnson 1999 Limited Groundwater Investigation N753 July 6 1999
Menzie Cura 2000a Screening Level Risk Characterization April 2000
Menzie Cura 2000b Addendum to Screening Level Risk Characterization June 1 2000
NRC 1993 National Research Council Committee on Bioremediation In Situ Bioremediation
When Does it Work Washington DC National Academy Press 1993
TRC 1993 Site Inspection-Ailing Industrial Park Williston Vermont VTD982748477 Final
Report
US EPA 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies
Under CERCLA OSWER Directive 93553-01
U S EPA 1992 Estimating Potential for Occurrence of DNAPL at Superfund Sites OSWER
Number 93554-07FS 9p
FOR ALLING INDUSTRIAL PARK MWP_DOCSW75JV20(XKALUNOFS9-0(AI0030929WPD 7 - 1 HSI GeOTTSHS irtC
MITEC 104e 02428
US EPA 1993 Guidance for Evaluating the Technical Impractibility of Groundwater
Restoration EPA540-R-93-080
US EPA 1998 Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents
in Ground Water EPA600R-9812~8
US EPA 1999 Use of Monitored Natural Attenuation at Superfund RCRA Corrective Action
and Underground Storage Tank Sites EPA Directive 92004-17P
US EPA 2000 Introduction to Phytoremediation EPA600R-99107
VTDEC 1996 Site Investigation Guidance August 1996
VTDEC 1997 Chapter 12 Groundwater Protection Rule and Strategy October 1997
VTDEC 2000 Vermont Water Quality Standards March 2000
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(AAUJNGFS9^)OM0030929WPD 7-2 HSI GSOTfanS tC
MITEC I04e 02429
APPENDIX A
TWODAN INPUT FILES
FOR ALUNG INDUSTRIAL PARK MWP_DOCSVN7S3200(AALUNOFS9-0(AI0030929WPO HSi GfiOTfanS WC
MITEC 104e 02430
i - i i a a o U 0 t A X H i d t l Z 018J UaiUEAJJLKATia Htj v j pound
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MITEC 104e 02431
15
6 Lancaster County Road HSI Harvard Massachusetts
GEOTRANS 01451 A TETRA TECH COMPANY 97^772-7557 FAX 978-772-6183
R E C E i ^ D PNN753-001
CUTLER A8TANPIELD Campltf December 11997
Mr Michael Smith Vermont Department of Environmental Conservation Waste Management Division 103 South Main Street Waterbury VT 05671-0404
Subject Proposed Surface Water Sampling MITEC Site Williston VT
Dear Michael
This letter describes the proposed surface water sampling at the MITEC site that we discussed during our meeting of November 201997 Our intention is to complete this work as soon as possible to avoid the complications of colder weather and possible freezing ofthe stream My understanding is that you are prepared to review and approve this plan fairly quickly and also to assist us with obtaining property access and appropriate maps to locate these sampling sites We appreciate this help In future we anticipate that the constraints of weather will not require such an expedited field mobilization process and that we will all have more time to prepare
Purpose and Extent of Sampling
The purpose ofthe surface water sampling is to further assess impacts to the unnamed tributary and to make preliminary inferences regarding the extent ofthe TCE plume currently migrating to the southeast across the Ailing Industrial Park by measuring the effects of its discharge to the stream To this end sampling locations have been chosen to 1) provide better spatial resolution in the area east of Commerce Street toward its southern end (SW-1 SW-2 SW-3 and S W-5) 2) assess the quality of surface water contributed by other tributaries (SW-4 SW-6) and 3) make preliminary estimates ofthe downgradient extent of impacts (SW-7 and SW-8) Samples from previously established sampling locations UTrib-6 7 8 1014 and 18 will also be obtained A total of 14 samples will be collected The proposed sampling locations
L-W7jni20iiooonl
MITEC 104e 02432
Michael Smith 2 December 11997
are indicated on the attached maps which depict the site at two different scales The first is a site map taken from the Binkerd report and shows the previous sampling locations east of Commerce Street as well as proposed new locations SW-1 SW-2 and SW-3 The second map shows the site and the surrounding area including the more downstream locations
Methods
At each proposed location a number of water quality indicators will be measured including temperature pH redox potential dissolved oxygen and conductivity Samples for volatile organic compound (VOC) analysis will be obtained in triplicate using a stainless steel sampling container samples will be transferred immediately to 40 mL glass vials with teflon septa and preserved with hydrochloric acid Each sample will be submitted to a local analytical laboratory for a screening level analysis of VOCs Three selected samples will also be analyzed using EPA Method 8260 The appropriate level of documentation will be generated for these samples such that laboratory analytical results can be validated to EPA Region 1 level Tier II This will require the collection and analysis of a duplicate sample a trip blank a field blank and matrix spikematrix spike duplicate samples
Sincerely
f i t mdash Peter ZeebPhD Senior Hydrogeologist
cc Sandy Feldman Sheila Jones
PZmm
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HSI GEOTRANS
LEGEND O Honrtorog Veil
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Figure 11 Station location map O Surface Water
Qfor monitoring wells borings and surface water MITEC 104e
02434
HD BINKERD ENVIRONMENTAL
HSI bull bull
GEOTRANS if prsTAOC
6 Cancaster County Road
A TETRA TECH COMPANY
Harvard Massachusetts 01451 faL32 HMETER 3 4 r t
Sheila Jones Esq Cutler and Stanfield 700 Fourteenth Street NW Washington DC 200052010
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Harvard Massachusetts 01451 GEOTRANS
A T E T R A T E C H C O M P A N Y 978-772-7557 FAX 978-772-6183
PN N753-002
May 111999 RECEIVED
MAY t 3 1999 Mr Michael Smith
CUTLER ampSTANrlc-uAgency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Dear Mike
Based on the site walkover and well inventory ofthe existing monitoring well network completed on April 201999 HSI GeoTrans determined that several monitoring wells proposed for sampling and monitoring in the Work Plan are not accessible or are damaged or missing Outlined below are the actions we will undertake to resolve the outstanding issues with the monitoring well network
As ofthe date of this letter access to the Bates well network has not been obtained The Work Plan identified eleven off property well clusters installed by the Bates and two wells installed by the State on the Bates property to be included in the sampling and monitoring activities for the Site Investigation (BW-2 BW-5 BW-7 BW-8 BW-9 BW-11 BW-12 BWshy13 BW-17 BW-18 BW-19) Ten ofthe off property clusters were included in the sampling plan and all eleven were included in the site water level round The wells installed by the State on the Bates property were included in the both sampling and water level rounds Replacement of eight ofthe well clusters slated for groundwater sampling is recommended (BW-5 BW-8 BW-9 BWshy12 BW-13 BW-17 BW-18 BW-19) The remaining Bates wells do not require replacement in order to achieve the goals ofthe Site Investigation Note that two ofthe original well clusters in the Work Plan BW-17 and BW-18 have been destroyed and would require replacement even if access is granted by Bates In addition HSI GeoTrans well clusters had already been proposed adjacent to BW-2 BW-7 and BW-11 and will provide the required data at these locations
It is our understanding that the two monitoring wells installed by the State on the Bates property JB-1 and JB-2 are accessible to the State for sampling and water level monitoring and that the State will sample and monitor these wells to fulfill the goals ofthe Site Investigation IF this is not the case please let me know at your earliest convenience
M WP DOCS NT^VWMiSimbW wpd
MITEC 104e 02438
Mr Michael Smith 2 May 11 1999
Several ofthe remaining wells (BF-1 BF-3 NO-2 and OE-1) were observed to be damaged during the inspection We propose to repair the wells which have been damaged The repairs will involve installation of protective casing or road boxes re-development and reshysurveying of the new measuring points The other wells are missing and presumed destroyed (ARC-2 ARC-3 BF-2 BM-2 MB-1 PO-SOUTH and RB-1) We believe that only monitoring wells MB-1 and MB-1 A require replacement The remaining wells that could not be located during the site inspection do not require replacement in order to achieve the goals ofthe Site Investigation
Based on our telephone conference on May 10 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MWgt_DOCSN753l9Wlaquo310l600raquopd M l 1 XA ~r
02439
HSI GEOTRANS
Mr Michael Smith 3 May 11 1999
bcc Sheila Jones
snwp_DocjN7sni9wcmoi6i)iraquoplti TVflTEC 1046
02440
HSI GEOTRANS
X_l ^ T 6 Lancaster Countv Road
Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-11 i 5
PN N753-002
June 25 1999
Mr Michael Smith Agency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Work Plan Modifications Ailing Industrial Park Site Williston VT
Dear Mike
This letter documents changes to the work plan for the Ailing Industrial Park Site in accordance with a telephone conference between you myself and Peter Zeeb On the results of the Site Investigation to date as well as additional data collection by the DEC we agreed that several revisions to the work plan are warranted The revisions for the work plan include the location and method of installation for the bedrock monitoring wells and the sampling of shallow monitoring wells recently installed Outlined below are the revisions to the specific tasks that we will undertake
Re-location of Bedrock Monitoring Weil BR-1
The DECs Source Area investigative work in the original location of BR-1 identified high levels (100 mgL) of VOCs present at or near the silt clay interface DEC believes that drilling through the clay layer in this location creates an unacceptable risk ofthe migration of contaminants into the underlying units HSI GeoTrans will relocate the bedrock well BR-1 adjacent to ASI-16 as located on the attached site plan
Bedrock Well Installation Method
Geophysical work at the site has refined our estimation of the depth to bedrock Depth to bedrock was initially anticipated to be greater than 150 feet below ground surface We currently anticipate bedrock at 100 to 140 feet below ground surface The shallower depth to Bedrock will
M AWPDOCStfnSIMnWUJIIW mft
MITEC 104e 02441
Mr Michael Smith 2 June 25 1999
enable us to reduce the size ofthe pilot hole needed for the well installation At locations BR-1 and BR-2 drillers will advance and set 4 in casing several feet into the clay unit and chop and wash the annulus ofthe casing All cuttings and wash water will be contained for proper disposal The casing will be refilled with potable water and the hole will be advanced with a 3 in roller bit When telescoping becomes necessary to prevent caving 3 in casing will be installed The 3 in casing will be advanced to the bedrock surface and seated The coring of bedrock will follow the original work plan specifications
Shallow Monitoring Well Sampling
The field GC water quality data obtained during small diameter installation at the site has demonstrated that contaminant concentrations in the upper portion ofthe aquifer to be low (lt 10 MgL) or non-detect in most locations This has led to the revision of our sampling plan Select shallow wells will be sampled to confirm the field GC data If these data are confirmed the low level and none detect shallow wells will not be sampled The shallow wells to be used for confirmation sampling are listed below
ASI-01 ASI-02 ASI-03 ASI-05 ASI-08 ASI-10 ASM 2 ASI-08
Based on our telephone conference on June 24 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MXTECl04e 02442
HSI GEOTRANS
Mr Michael Smith 3 June 25 1999
bcc Sheila Jones
MITEC I04e
02443
HSI GEOTRANS
1 0 T 2 shyCylty
T-TCT 6 Lancaster County Road _ _ _ Harvard Massachusetts
GEOTRANS OH 5 1
A TETRA TECH COMPANY 978-772-7557 FAX 978-772-6183
PN 753-010
July 9 1999
Mr Michael Smith Agency of Natural Resources Vermont Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Bedrock Monitoring Well Installation Ailing Industrial Park Site Williston VT
Dear Michael
On July 8 we became aware that a drill casing was advanced through the sand clay and till strata at the Ailing Industrial Park (site) without being sealed at the sandclay interface Although for the reasons described below we do not believe any vertical migration of contaminates occurred this method of drilling is contrary to the work plan for the site Therefore we are notifying you of this incident
On June 4 shallow direct push monitoring wells were installed at location ASI-06 where a deeper bedrock monitoring well is planned Groundwater quality profiling data from this location is provided on the attached boring log TCE is present in groundwater here at concentrations as high as 2270 ugl at 31 - 36 ft below ground surface (bgs) decreasing to 262 ugL at 41 - 44 ft bgs A soil boring (D-2) was advanced at this location on June 22 Field screening data from soil samples obtained in this boring are also provided on the attached log As apparent from the log fine to medium sand occurs to a depth of approximately 15 ft at this location grading to silt at depth A clay layer is encountered at 40 ft bgs Glacial till is present from 57 to 100 ft bgs where the bedrock surface is located Prior to drilling through the clay and glacial till a direct push well screen was advanced through the clay and into the till to a depth of 58 bgs and no groundwater recharge to the well screen occurred at any of five sampling depths
MWP_DOCSN753 199M7M1600 wpd
MITEC 104e 02444
Mr Michael Smith 2 July 9 1999
Drilling of bedrock monitoring well BR-2 began on June 29 Four inch casing was advanced to a depth of 44 ft and sealed within the clay layer Three inch casing was then advanced through the till layer to the bedrock surface During seating ofthe casing in the bedrock the casing was damaged and was subsequently withdrawn from the borehole
On July 7 a different drill rig was used to continue drilling the same location In accordance with both the drillers proposal to HSI GeoTrans and the work plan for the site investigation the driller was to seat a casing in the clay establish a seal and drill through the clay and till with smaller casing prior to coring bedrock Instead the drilling contractor withdrew the previously installed four inch casing without grouting it changed the drive shoe on the casing to a spin shoe and advanced the four inch casing directly to the bedrock surface Upon arrival at the site to log the coring of bedrock on July 8 HSI GeoTrans ascertained that the borehole had not been sealed at the clay surface prior to drilling deeper as was specified HSI GeoTrans then instructed the drilling contractor to immediately remove the casing and to seal the borehole with grout in the process
It is our intention to have a new drilling contractor complete the installation of BR-2 at an adjacent location in a manner that limits the potential for introducing contaminated unconsolidated deposits groundwater to the bedrock as specified in the work plan for this site investigation Within one week of completing the installation of BR-2 groundwater quality data collected from BR-2 will be evaluated with respect to the potential for contaminant migration along the unsealed borehole that existed at this location for approximately 24 hours As the casing was advanced by spinning providing a relatively good seal between the casing wall and the formation we do not anticipate that vertical migration along the casing was significant
If you have any questions regarding this letter please contact me at (978) 772-7557
Sincerely yours
Peter Zeeb PhD Senior Hydrogeologist
PZcas
MWP OOCSVN7S3M999070ll600wpri
MITEC 104e 02445
HSI GEOTRANS
1 HSI | 9pound9TPpoundSpound SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
LOCATION Williston VT CASING TYPEDIAMETER None
DRILUNG METHOD Drive and Wash Direct Push SCREEN TYPESLOT None
SAMPLING METHOD ss shelbv GRAVEL PACK TYPE None
GROUND ELEVATION GROUT TYPEQUANTITY Bentonite Portland Slurry
TOP OF CASING DEPTH TO WATER
LOGGED BY NSB GROUND WATER ELEVATION
REMARKS This log compiles the results o the all methods used to comolete the borehole over its entire depth
gtshyci IT UJ t o UJ E t shygt z L oi lti LITHOLOGIC DESCRIPTION 3Q O bdquo a UJ lt a ca sect 1a UJ
o amp UJ _ a 1 Oi i ai o UJ a E 03 5 1 - X X X
cc -S
Moderate olive Brown - Olive Grey m-f SAND w trace fines wet poorty graded
bull bull bull
- 5 shy
J
bull bull
- 1 0 shyD2-SS01 21 13 NO 7 NO 13
A12 7
bull bull
Light olive Brown SILT w trace fine sand wet poorly - 1 5 shy graded
O2-SS02 4 7 11 8
A7
6 7
- 2 0 shy Dark greenish Grey SILT wet poorly graded
O2-SS03 2 0 41 1
WOR WOR l
D2-SS04 2 4 2 X - 2 5 shy4
D2 13 1159
3
1 D2-SS05 2 5 39 v
WOR AWOR WOR - 3 0 shyD2-SS06 4 921 WOR
XWOR WOR
02-SS07 8 2270 1
X1 2 3
Continued Next Page 1 OF 3 02446
HSI GEOTRANS SOIL BORING LOG BR-02 A T E T R A T E C H C O M P A N Y
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
9 gtshyOC
UJ - j a
UJ gt o ^ r-6 LITHOLOGIC DESCRIPTION
ui
CD U UJ S oc =
o o
uj _ Q pound iT O
o
Medium Grey dayey SILT wet poorly graded
D2-SS09 4 S
28 1572
3 6
D2-SS10 WOR 1 18 13
4 6
D2-SS11 3 3 20 NO Medium Grey CLAY wet poorly graded 262
4 5
BR2-SS01 1 2 20 ND Soft Olive Grey CLAY moist laminated coheisive 2 4
BR2-SS02 20 NO
- 5 0 -
BR2-SS03 20 NO - 5 5 -
Dense Light olive Grey sandy GRAVEL w few fines
BR2-SS04 16 19 24
ND
bull60
moist poorly graded
21
Very dense Light olive Grey gravelly SAND w little fines moist well graded angular
BR2-SS05 40 51
13 ND 6 5 shy
60 66
I-7 0 shySO BR2-SS06 11 ND 50 100
5000
MITEC 104e 02447
Continued Next Page PAGE 2 OF 3
HSI GEOTRANS A T E T R A T E C H C O M P A N Y SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
a UJ
Q
05
i i m u
gt ac ui gtO bdquo UJ 3 oc S
o o
0 CO UJ _ Q pound LL C5
LITH0L0GIC DESCRIPTION 9 LU O
BR2-SS07 81 1004
10 NO E 8 0 shy
BR2-SS08 30 59 68
16 ND w8 5 shy
BR2-SS09 1005 NO 9 0 shy
BR2-SS10 89 1944
ND E bull95shy
- 1 0 0 shyND
Limestone
MITEC 104e 02448
PAGE 3 OF 3
Mr Michael Smith 3 July 9 1999
bcc Sheila Jones bcc Jerry Amman
MWPJXXSN753M9MW70J160Owpd
MITEC 104e 02449
6 Lancaster Countv Road HSI Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6 I i 5
PN N753-014
Septembers 1999
Mr Michael Smith Agency of Natural Resource Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in die Site Investigation Ailing Industrial Park Williston IT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and die Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation ore outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste waler lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot IV-11 using small-diameter wells and afield GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
bull perform one day ofwellpoint permeability testing at selected monitoring wells
mwFDocwsiMwwwnoootd MITEC 104e 02450
Mr Michael Smith September 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
M l T ECl04e 02451
U laquo OOCTN791Mtm01IOOOraquofrl
HSI GEOTRANS
HSI GEOTRANS
6 Lancaster County Road Harvard Massachusetts
01451
A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6183
PNN753-014
Septembers 1999 amp y gt
Mr Michael Smith D oJ Agency of Natural Resource Km Jt Department of Environmental Conservation i j f i l Waste Management Division ft y^y( 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park ft Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and the Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation are outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
bull perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste water lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot 19-11 using small-diameter wells and a field GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
MITEC 104e perform one day ofwellpoint permeability testing at selected monitoring wells 02452
000060 MlWP_OOCSN73Iirmraquo01|rngtlaquo|gtl
Mr Michael Smith Septembers 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
MITEC 104e 02453
000061 Mwr_cocS4miinmogtmoltsri
HSI GEOTRANS
T T Q T 6 Lancaster County Road ^ Harvard Massachusetts
GEOTRANS laquolaquo A TETRA TECH-COMPANY 978-772-7557 FAX 978-772-6183
PNN753-014
October 151999
Mr Michael Smith vZ Agency of Natural Resource J Department of Environmental Conservation Waste Management Division I 103 South Main StreetWest Building j Waterbury VT 05671-0404
Re Ailing Industrial Park Source Area Investigation
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants Evaluation of field data has determined the extent ofthe dissolved phase contamination migrating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) HSI GeoTrans will begin a Source Area Investigation on October 181999 to determine the nature and areal extent ofthe suspected contaminant source The investigation will be undertaken to gather the data necessary to complete the Site Investigation Report and the Feasibility Study which was set forth by the Agreement Between Mitec Telecom INC and Vermont Concerning the Ailing Industrial Park (1999) The Source Investigation will focus on the property owned by Beatrice Ailing and former MITEC lease hold (Lot 19-11 Williston plat map) and the area ofthe Ailing Industrial Park which has exhibited elevated contaminant concentrations during Site Investigation activities We are submitting this letter to The Vermont Department of Conservation(VTDEC) as an addendum to the approved Site Investigation Work Plan The addendum Source Investigation Work Plan will outline the tasks and methodologies to be utilized during the investigative work
Jack Guswa and I met with you on September 101999 to present the plans to investigate the suspected source area in the Ailing Industrial Park You agreed with the additional work as presented with the addition of two upgradient wells to be located to the west ofthe suspected source area (Figurel-1 ASI-30 and ASI-31) The VTDEC also agreed during the meeting to arrange access to the property for the Source Area Investigation The VTDEC and HSI GeoTrans were subsequently granted access to the property on September 111999 In addition to the work presented at the meeting it is necessary to preform a 72 hour pump test to characterize the
000054 MwrDOCSW79JimMOUIIOOpd
MITEC 104e 02454
Mr Michael Smith 2 October 151999
hydrologic conditions at the site The additional Source Area Investigation activities to be undertaken are presented below
Site Reconnaissance Ground Penetrating Radar (GPR) Survey Monitoring Well and Soil Boring Installation Low Flow Groundwater Sampling Hydraulic Characterization
The additional field work attributed to the Source Area Investigation will follow the standard operating procedures presented in the approved Site Investigation Work Plan (HSI GeoTrans 1999) The locations ofthe proposed well cluster installations and GPR survey are presented on Figure 1-1 The well cluster locations presented in Figure 1-1 were finalized during the September meeting between HSI GeoTrans and the VTDEC The GPR survey and hydraulic characterization tasks are presented below The Source Area Investigation field work will be completed within two week after its initiation The task specific outlines are presented below
Site Reconnaissance
The monitoring wells to be included in the site reconnaissance are monitoring wells MI-1 MI-2 MI-6 and RB-2 The monitoring wells on Lot 19-11 will be surveyed to a common datum with the existing site wide survey data Well integrity testing consisting of depth to bottom water level and visual inspection ofthe wells will be preformed Groundwater samples will be collected from selected monitoring wells based on the integrity testing Samples will be collected by the Low Flow Protocol set forth in the Site Investigation Work Plan (HSI GeoTrans 1999)
GPR Survey
A GPR survey will be preformed to identify on-site leach field septic tank or cesspool location remnants of waste water lagoon and any other subsurface anomalies We propose to use a 5 foot by 5 foot orthogonal grid survey to detect any near surface anomalies which exist on Lot 19-11 Geophysics GPR International will be performing the survey and will be utilizing a GSSI SR10 ground penetrating radar system with a high resolution 500 MHz antenna and a deep-penetration 100 MHZ antenna Any GPR response which indicate buried metal objects will be investigated with a Fisher TW6 pipe locator to augment the radar data All data will be analyzed in the field by GPR personnel and presented to HSI GeoTrans field personnel to determine the optimal location for well cluster ASI-28 If several anomalies are detected the VTDEC and HSI GeoTrans will evaluate the anomalies and modify the work plan accordingly
Well Installation and Soil Boring Advancement MITEC 104e 02455
The well clustes will consist of a small diameter shallow monitoring well and a deeper conventional well screened across the zone of highest concentration Well cluster installation will be performed in accordance with the Site Investigation Work Plan (HSI GeoTrans 1999) yjth 0 0 5 5
MWP_DOCSK731IW9M OOSIIOOprl
HSI GEOTRANS
Mr Michael Smith 3 October 151999
the exception ofthe deep wells The site conditions observed during previous field work prohibit the use of standard commercially available screen slot sizes The deep wells will be advanced by a large diameter Geoprobereg rod and installed using an outer filter sock to prohibit the infiltration offine sediments in to the well The well cluster installations will be performed jointly by Checkpoint Environmental and Twin State Environmental HSI GeoTrans will be provide oversite ofthe contractors and analysis of groundwater samples using afield Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999) The rationale for the selected well cluster locations is presented below
Monitoring well clusters ASI-25 through ASI-27 are located down gradient ofthe suspected source area The well clusters will be installed to more adequately define the areal extent ofthe concentrated portion ofthe contaminant plume A single soil boring will be advanced at location ASI-26 The soil boring will be screened as it is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-28 will be located after the GPR survey has been completed shyThe cluster will help define the suspected source area and the vertical migration of contaminants in the area The location will be determined in thefield after review ofthe GPR survey is completed The location will be based on any anomalies observed in the GPR data A single soil boring will be advanced at location ASI-28 The soil will be screened with a Flame Ionization Detector as the soil boring is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-29 will be located upgradient ofthe suspected source area The cluster will define the upgradient boundary andor any additional upgradient source areas The ASI-29 well will be paired with the existing shallow monitoring well AL-14
Monitoring well clusters ASI-30 and ASI-31 will be installed to the west cross gradient from the suspected source area to document the areal distribution of dissolved phase contamination emanatingfrom the Ailing Industrial Park The locations selected for these wells should define the northwestern and western extent of contamination
Low Flow Sampling
The additional monitoring well clusters will be sampled in accordance with the approved Site Investigation Work Plan (HSI GeoTrans 1999) Lowflow sampling procedures will be used to sample the newly installed deep wells in their respective clusters ASI-25 through ASI-31
MITEC 104e 02456
000056 MWP_DOCSgtK15JlWMOWllltraquoraquoprl
HSI GEOTRANS
Mr Michael Smith 4 October 151999
Hydraulic Characterization
HSI GeoTrans will conduct a 72 hour pumping test on the deep well at cluster ASM 2 The test is being undertaken to more adequately characterize hydraulic conditions at the site The data from this test will be used in the evaluation of remedial alternatives in the Feasibility Study The pump test will be performed as a step-drawdown test The pumping rates will ultimately be determined in the field from observed conditions Preliminary calculations indicate that pumping rates of 2 5 and 10 gallons per minute will be necessary to achieve the desired drawdown at observation wells The water level data will be recorded at observation wells ASI-06 ASI-13 ASI-25 ASI-26 NO-1 NO-2 and NO-3 The water level data will be recorded using pressure transducers and dataloggers
The effluent water from the pumping test will be treated by liquid phase granular activated carbon filters provided by Carbtrol Inc Two 175 pound carbon filters will be connected in series to treat the pump test effluent The effluent will be discharged to the unnamed brook upon approval from Randy Bean ofthe VTDEC The effluent will be periodically sampled between the carbon units and at the discharge point to detect break through ofthe carbon units The effluent samples will be analyzed utilizing a field Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999)) If the effluent sample between the carbon canisters exceeds 1000 ugL Trichloroethene (TCE) the discharge point sample will be analyzed If concentration of TCE in the discharge point sample exceed 300 ugl the test will be discontinued
We hope that this letter addendum to the Site Investigation Work Plan for the Source Investigation is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJmm MITEC I04e
02457
000057 MWFDOCSN731imu00SI 100 bullpd
HSI GEOTRANS
JHSTUART March 1 1985
Agency of Environmental Conservation D e partment of Water Resources und
E nvironmental Engineering H a z a r d o u s Materials Management Program A t t n John A m i d o n H y d r o g e o l o g i s t M o n t p e l i e r Vermont 05602
R e M I T E C Systems Corp W i l liston
Dear J o h n
During our meeting at MITEC on February 20th you noted that some additional information was needed to c omplete the initial phase of testing as well as the d o c umentation of the activities under takentodate Outline d~ beTow-Ts ~t h e~1 n f o r m a ti o n t h a t y o u r e q u e s t shyed
1 Attac hed here to is the plan used to install the grou ndwat er moni t o r s collection and analysis of the grou ndwa t er samp les for metals and organics and the extr actio n of and testing of soils from the area of the dispo sal site 2 A rev ised sit e pla n has been incl uded refl ecting the new well posi tions and the e leva t ions of t he top of t he mo ni to r s and th e groundwa ter 1e vels as of F e shybr ua ry 0th As note d in our m ost r ecent tel ephone conv i on th e lat ter have r isen 14-15 inc hes as er sa t the It o f th e rec ent thaw Two copie s of the resu plan be f orw ar ded to Winslo w Lad ue as req uested will and pla ns t 0 sur vey all ho uses on Br owne 11 Rd MITEC _tp tain if there are ajiy shallo w wel I sources ltis ce r with e dr aina ge ar ea a f fecte d by the 1agoo n in th 3 ngla nd Ma r ine C o m r a c t o r has been con tacted New E for remo va 1 of th e lagoon soil a nd co ntra c tural the ar ra nts wil 1 be concluded du r ing t he comi ng ngeme week if ic at io n of work comme nceme nt wi II be proshy Not vide your off ice i n advance d to t m Resul t s of th e met als and or genies are expected shor tiy
f rom IEA and will be fo rwarded to your ofshyf ice oon as a va i la ble as s 5 R esul t
s fr om t he pr e vious soi 1 and water sampling have inc 1 ude d bee n
CIVIL 4 EfViROUMEI-L pound l j i t fcHpound P ) OGA lt i f r l h r l h w i l l n-- i i U - iO l i l ) bU i l I
MITEC 104e 02458
s
MITEC Page 2 March 1 1985
If you have any questions please do not hesitate to contact me
Stuart PE
JHSocc
MITEC 104e 02459
MITEC Systems Corporation Williston Vermont
Soil and Water Sampling Program
1 Install groundwater monitors at nine (9) locashytions consisting of two (2) inch inside diameter PJpound with ten (10) feet of factory slotted pipe extending into the groundwater and terminating with a minimum of two (2) feet above ground level and capped
2 Establish elevations of the groundwater monitors for the top of each pipe and the groundwater elevashytion for each for a specific date Due to the shalshylow depth to groundwater from 51-112 inches the level is established by graduated tape and a light Each measurement will be performed a minimum of three times to assure accuracy to within one-eighth inch The location of each well and the established elevations will be represented on a general site plan showing the MITEC property
3 Groundwater samples are to be collected from each well on the same date by pump or baling Prior to - k ~ -~-|1bdquo--bdquobdquo f bdquo k bdquobdquobdquobdquobullbdquo ltv~ 11 1 1 v bdquo bdquo bdquo
acidification for metals preservation to assure ac curacy of the test results All samples are to be analyzed for copper cadmium nickel cyanide pH conductivity total chromium and hexavalent chrome
U Soil samples are to be collected as follows
GWM09 Saturated zone (aaprox 5) Overburden East side lagoon Composite from
two holes 5 apart-at-1 bullbull2 bullbull A below the-sur=mdash face and one in the saturated zone
North wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface 1 into the saturated zone
South wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface I1 into the saturated zone
Bottom of lagoon Composite offour test holes 8 apart one in the unsaturated zone
MITEC 104e 02460
MITEC Sampling Program
All samples are to be analyzed for the same constituents as required of the water testing
5 Collect separate samples of the groundwater after the above referenced purging process for storage in air-tight vials The samples which are to be colshylected from wells A-9 with only 5 and 7 analyzed initially by the GCMS- EPA method 62A If organics are detected in the first samples testing must be performed on 4 and 8 as well
6 All sampling will be performed with a State repshyresentative on-site and results of the testing to be forwarded to the State as soon as available
7 The contaminated soil within the lagoon will be removed by a Vermont certified contractor for disposhysal in an approved wastedepository The top one (1) foot of soil from the flood level and below will be extracted during the process
MITEC 104e 02461
i
o H
ON f J
o
bull I I bull
HA
OOO
x x z
bull
MITEC 104e 02463
WK miui w ci ivnui II i ici ILUI ujiyitb inc iii PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5108
ANALYSIS REPORT
Customer j H S c u a r t Associates Date 26 February 1985
Address P gt 0 gt B o x 3 6 7 Date Samples Received
Ci ty S t a t e Zip Essex Center VT 05A15 20 February^1985
Customer Order Nomber
Attent ion J o h n S t u a r t
Station 9
J
2
3
A
5
6
7
8
9
poundH
5A
58
52
5A
A5
53
53
55
59
j MITEC
Conductivity U mbos ( 25degC)
206
A18
21A
176__
208
230
205
16A
265
GROUNDWATER ANALYSIS
O01 0 OS bull
Cadmium Total Chromium (mRl) (mRl)
0A1 lt0025
006- 270
00A 012
bull005 189
005 023
001 lt0025
lt0C Hexavalent Chromium (mKI)
bull
lt0025
239
005
183
lt0025
lt0025
ampo
Zinc (mKl)
005
0A0
032
015
OU
003
Note Organic analyses to follow in two weeks
cc John Amadon
Signature jJfcrryyS 7lrifrylC
Offices ond loborotones located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02464
if jsznoi U hnvironmentol jiolysts Inc PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5138
ANALYSIS REPORT
Customer J H Stuart Associates Date 21 December 1984
Address PO Box 367 Date Samples Received 14 December 1984
City State Zip Essex Center VT 05451 Customer Order Number
Attention John Stuart
WATER ANALYSIS
PH 52 57 50 53 45 34
Conductivity (pmhos 25degC) 213 420 152 167 202 bull 225
O l Cadmium (mgl) lt001 lt001 001 v 028 bull 005 003
o pound Chromium Total (ng1) lt0025 lt0025 lt0025 lt0025 2-35 v 014 - -bullbull - bull - -bull V 013 bull^Chromium Hexavalent (mgl)1 0 11
gt1p Copper (mgl) lt002 lt002 lt002 lt002 bull 084 004
Q Cyanide (mgl) lt0005 lt0005 lt0005 lt0005 bull -lt0005 lt000E
Z Nickel (mgl) lt0025 lt0025 lt0025 lt0025 bull 010 003
fO 2inc (mgl) 0J1 UU1 0U3 001 038 030
Hexavalent chromium was only analyzed when total chromium was present
Signature fmnigt Mji fnt f VncL 7
Offices and laboratories located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02465
bull i
ANALYSIS REPORT
Customer J H Stuart Associates Date 22 January 1985
Address PO Box 367 Date Samples Received 14 December 1984
Ci ty State Zip Essex Center VT 05415 Customer Order Number
Attent ion John Stuart
bull shy
bull bull mdash bull bull bull bull bull - bull bull bull bull shy SOIL ANALYSIS1
Hexavalent Cyanide Chromium Chromium Cadmium Copper Nickel Zinc
poundH bull (mgl) (mgl) (mq1) bull (mq1) (mq1) (mgl) (bullmgl) -
2 442 lt0005 lt0025 lt0025 lt 001 lt 002 015 006
4 402 lt0005 lt0025 lt0025 lt 001 lt 002 lt002 001
7 504 lt0005 lt0025 lt0025 lt001 lt002 lt002 001
8 486 lt0005 lt0025 lt0025 lt001 lt002 lt002 bull 008
9 441 lt0005 lt0025 lt0025 lt001 lt602 lt002 004
10 444 0005 lt0025 lt0025 lt001 lt002 lt002 006
11 498 lt0005 lt0025 lt0025 lt001 003 lt002 009
30 532 lt0005 lt0025 008 lt001 005 lt002 010
31 544 lt0005 lt0025 lt0025 lt001 002 056 003
32 472 lt0005 lt0025 lt0025 lt001 lt002 024 003
36 536 0008 lt0025 011 lt001 005 lt002 011
37 490 lt0005 lt0025 lt0025 lt001 021 lt002 009
38 391 lt0005 0276 032 lt001 050 lt002 011
41 416 lt0005 0108 018 001 229 lt002 o5i
42 395 lt0005 0399 041 lt001 039 lt002 014
i
Signature Ltrf(7( ni W0 6M Analysis of EP toxicity extract
Offices ond loborotoriei locoted in Essex Junction Vermont Reseorch Triongle Pork North Corolino
MITEC 104e 02466
JHSTUART
A p r i l 2 9 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Hazardous Waste Materials Program Attn Cedric Sanborn Environmental Engineer Montpelier Vermont 05602
Re Mitec Systems Williston
Dear Cedric
I was phoned by David Gee today and informed that a truckload of the contaminated material was removed from the lagoon area as the result of a previous commitment entered into by Mitec Due to conflicting information about Mitecs responsibilities at this juncture I am recommending that any further work cease until a realistic program be agreed to by both parties I base that on the following
1 Following the trial pre-hearing the State was inshystructed to contact Mitec to develop a schedule for further dialogue and actions connected with the reshyhabilitation of the lagoon site To my knowledge there has not been any such attempt made on the part of the State to resolve issues that need clarificashytion
2 On April 18th I forwarded a letter to you outlinshying some new information with recommendations That correspondence has not been addressed yet Mitec has been ordered to continue with the soil removal
3 A letter from John Amadon on April 23rd notes the organic sampling to be invalid due to the time lapse and the method of storing the samples We do not take issue with this position however there is apshyparently some question about the validity of the GCMS method of analysis We have been instructed to re-sample but now there is a question about whether we should employ GC or GCMS
A On numerous occasions we have expressed the deshysire to tailor the soil removal process to a minimum
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 3C7 ESSEX CTR VERMONT 05451 TELEPHONE 802 876 bull 5171
MITEC 104e 02467
L
Mitec Page 2 April 29 1985
2- bull number of truckloads as they are projected to cost about $4000 for each load Mitec being in a startshyup phase of their operation cannot approach this operation with a blank check Chris Stone who was on hand today to represent the State indicated that many more loads may be necessary to effectively rid the site of contamination
Too many questions surround this project for my clishyent to understand his responsibilities and ultimate costs The requirements issued by your office either in writing or verbally on-site have changed repeatshyedly and unless we can mutually agree to a reasonshyable program that is connrifpH rnmdashyr r i ng Mitec has no other option but to let the court decide the isshysue
Again keep in mind there are questions that we feel must be resolved in order to reach a satisfactory conclusion
1 Provided that all Browneil Road houses are connected to the CWD system and thereby reshymoved from any threat of groundwater conshy
- p tamination what level of soil contamination is permissible From this limitation provishyded we concur as to its reasonableness an approximation can be developed as to how many loads of soil must be removed
2 If the soil is to be removed why is it neshyy cessary to conduct organics sampling unless
i t~ i s tne ulterior motive ot the State to direct renovation of the groundwater as well If that is the case the process will now be more expensive than at the outset due to the mobilization of the contaminants
3 If the contaminated soil is to be removed whv is additional groundwater monitoring
pound bull necessary Documentation of the degree of dilution is not considered acceptable
A If organic testing is to be performed y_hich -- method of analysis is to be used
As soon as we can receive a response to the quest-
MITEC 104e 02468
I um laquoi i laquo m mdash n r r j mdash i mdash
Mitec Page 3 April 29 1985
ions at hand then further discussion with the State will dnsue Also please be advised that at the dishyrection of Mitec all future correspondence communishycations requests for information or notification of site vists are to be forwarded to my office We also request that one person in your office be designated to process such information
tuart PE
JHSocc cc Mitec
Robert Cronin Esq
MITEC 104e 02469
jmfMraquoi w i f u m i
A u u raquo laquo F pound raquo laquobull= -
B C f U S t B C INC ENVIRONv i bullbullbull bullbull
5 GREEN MOUNTAIN DRIVE SOUTH BURLINGTON VERMONT 05401 TELEPHONE (802) 658-1074
February 17 1984
I I Mr Cedric Sanborn i
of Environmental Conservationi AgencAgencyy ox ampnvifoiuneniai Lonservdciun I i Dept of Water Resources and
Environmental Engineering Montpelier VT 05602
Dear Mr Sanborn j i
RE Mitec Clean-Up 84011 j
I am writing this letter to inform you of the work that has been completed thus far at Mitec Systems Corp The discharge of i rinsewater into the lagoon has stopped and the rinsewater is being batched and treated at Aquatec as I described in my letter to Stan Corneille dated February 3 1984
Although the chemical reduction and precipatation process works bull bull
very well we have found that the cost for design installation j septic design and installation and permit reviews is far above | Mitecs budget Aquatec has looked at a second alternative for bull the treatment and reduction of rinsewater that being ion exchange J The ion exchange system will be purchased from a vendor and will bull be installed by Aquatec to accomodate Mitecs rinsewater volumes i The rinsewater will be recirculated and will not require any discharge hence there will be no need for subsurface disposal [ permits I will send you specifications on the system and resins j that will be used I
The proposal for the out-door clean up work is enclosed Mr Kucer is currently discussing the cost estimate with his Montreal office I see no reason to intiate this work as soon as I get formal approval from your office and from Mitec
Please feel free to call me if you should have any questions
Sincerely
liytrl Zi [U$) John R Deigo Project Engineer
Enclosure cc Mr Steven Kucer
Hydrographic Studies and Analyses bull Water Quality Studies raquo Analytical Laboratories Ecological Studies bull Aquatic Nuisance Control - Industrial Waste Surveys
MITEC 104e 02472
Recommended Treatment of Rinsewater
Mitec System Corporation
Prepared By
Aquatec Inc
South Burlington Vermont
January 23 1984
MITEC 104e 02473
RE Mitec Groundwater Cleanup - 84011
The treatment of rinsewater will consist of a three stage rinse system with a batch chemical reduction treatment process Parts submersed in chromic acid solutions will be rinsed in a primary rinse bath The primary rinse bath will be a closed system and considered a rough rinse
The secondary rinse bath will also be a closed rinse system The third and final rinse will be a continuous overflow system Effluent from the tertiary system will flow directly into the septic system Tertiary effluent limits must be less than 005 mgl (ppm) before entering an underground septic system
The primary rinse bath will eventually become saturated with chromic acid solutions and require periodic batch treatment When the primary rinse water becomes spent it will be transferred into a 250 gal polyethylene plating tank The rinse water from the secondary rinse bath will be transferred into the primary rinse bath and the secondary bath will be refilled with fresh rinse water
When the tank reaches 80 of its capacity treatment will be initiated The treatment will consist of reducing hexavalent chromium to trivalent chromium by the addition of anhydrous sodium sulfite to a pH of lt2 The amount of sodium sulfite added will depend on the concentration and volume of rinsewater to be treated A portable electric mixer will be attached to the tank to ensure proper mixing The rinsewater in the reduced form will be gravity fed into a second 250 gallon polypropylene plating tank where lime will be added precipatlng out trivalent chromium as well as other heavy metals The mixer should be used to agitate the solution when the lime is added The mixer should be removed and the solids allowed to settle Once the solids have completely settled the treated water will be pumped into the tertiary effluent to allow for further dilution before it is discharged into a septic system
Periodic sampling of effluent waters should be incorporated to ensure that rinsewater discharged does not exceed 005 mgl (ppm)
Sludge will be properly stored and eventually disposed of by a certified hazardous waste carrier
MITEC 104e 02474
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Wildlife and Department of Forests Parks and Recreation Environmental Engineering Department of Water Resources amp Environmental Engineering Natural Resources Conservation Council State Geologist
January 4 1984
3 2ampov~ loo Mr J H Stuart
f i 2 Sm ^
P O Box 3 67 - - l ^ J ^ S M J Essec Center Vt 05451
SUBJECT Mitec Z 0~npJ^
1 o
Dear J o h n
I appreciate your sending me a copy of the recent Mitec water quality results It appears that there remains a detrimenshytal affect of the lagoon on the downgradient groundwater quality This is best demonstrated with the pH and chrome data While it appears that the downgradient well 5 has higher metalic concenshytration then well 6 in the middle of the lagoon I believe the Well 5 results are anamously high due to the turbidity or solids that we saw in the sample In talking with Cathy Cutting of IEA sample 5 was not filtered prior to acid digestion for the AAS analysis ^^
I would suggest that well s 4 5 and 6be resampled and analyzed along with the wells installed on CecT 17 amp 18 We would like to have a representative of our office on site when the sampling is performed so please contact me when a purging and sampling date is set in the near future The groundwater sample from test well 6 that you helped me obtain on December 17 with the teflon bailer was confirmed by our laboratory to contain volatile organics Therefore you must include the volatile orshyganics assay done by JGCMSjas a part of your analysis plan Adshyditionally I would suggest that you review the appropriate protocol for groundwater sampling and obtain the necessary equipshyment A sampling and analysis plan must be submitted for our apshyproval prior to commencing this second round of sampling The plan should be submitted by January 18 1985 with the sampling done within one month of our approval Please feel free to conshytact me with any comments or questions you may have
R f n r mdash i 1 Off ices - BarreEssex J c t P i t t s f o r d N Spr ing f ie ld S t Johnsbury
MITEC 104e 02844
J H Stuart Page 2
I do look forward to reviewing the results of the soils asshysays along with your report outlining the sampling protocol sampling locations data interpretations and projected course of action based on the results
Very truly yours
John F Amadon Hydrogeologist Hazardous Materials Management Program
JFAkp
cc Meredith Wright AG
MITEC 104e 02845
b v
HSTUART ASSOCIATES September 10 1984
Agency of Environmental Conservation Department of Water Resources and Environmental Engineering Air and Solid Waste Programs Attn Cedric Sanborn Air Pollution Control Engineer Montpelier Vermont 05602
Re M I T E C Corporation Williston Vermont
Dear Cedric
As Che result of our conversation on September 7th I am forwarding the information Chat we discussed
The CesCing program format was prepared prior Co our disshycussion and will be altered slightly based on some inforshymation that was collected
A boring was established in the cencer of Che disposal pic and Che wacer Cable as well as che Impeding layer were found to be located at 29 Inches below the surface The shallow depth will allow us co place addicional wells in che area co accuracely depicc Che groundwacer copography
The plan submiCCed herewith provides general information abouc che locaclon of che plane propercy lines and sugshygested positions for Che monitors The final location of che laccer will be decermined in che field once we collect more data on water table elevations
As we are most anxious to proceed with the program your expeditious review and responsewill be most appreciated
SCuart PE
JHSadt
cc David Gee MITEC
CIVIL ENVIRONMENTAL ENGINEERS 120 LAKE STREET BURLINGTON VERMONT 0S401 TELEPHONE 802-8640094
MITEC 104e 02846
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Game and Department of Forests Parks and Recreation
Department of Water Resources amp Environmental Engineering Environmental Engineering Natural Resources Conservation Council
September 19 1984
Mr John H Stuart PE JH Stuart Associates 120 Lake Street Burlington Vermont 05401
RE MITEC Project
Dear Mr Stuart
Chris Stone and I have reviewed the proposed soil sampling and groundwater monitoring plan for Mitec A summary of comments follows
1) The site plan did not show the location of the soil sampling sites Also we felt that additional boringmonitoring sites should be made closer to the facility The map has been re-marked to reflect these additional sites
2) It was not clear as to why the monitoring wells are to be installed 5 feet into the impeding layer However at least one boring should be made into the impeding layer to detershymine its thickness
3) Permeability tests should be performed on at least four of the test holes to determine aquifer characteristics
4) Since the water table is apparently close to the surface we feel that factory slotted pipe would be appropriate for the final monitoring wells
5) All soil1 ft 5 ft
samples 10 ft or
shouldto imp
be eding
takenlayer
at whic
depthshever
of comes
first
MITEC 104e 02847
Mr JH Stuart -2- September 19 1984
6) In addition to the soil sample in the center of the former lagoon four other locations within 2 feet of the edge of the lagoon must be sampled These locations are marked on the enclosed map
7) The State regulations do not address a level below which the metals are no longer hazardous as is done by EPA Toxicity Levels The level of contamination that is acceptable to the State is determined on a case by case basis
8) The analysis for chromium should include both hexavalent and total chromium
If you have any questions regarding our comments do not hesitate to contact us at 828-3395shy
Sincere
Sanborn C h r i s t o p h e r T Stone Environmental Engineer Hydrogeo log i s t Hazardous M a t e r i a l s Hazardous M a t e r i a l s Management Program Management Program
c r s - c t s a d e n c l o s u r e
MITEC 104e 02848
JHSTUART November 9 1984
Agency of Environmencal Conservation Deparcmenc of Wacer Resources and
Environmencal Engineering Hazardous MaCerials Management Program Attn Cedric Sanborn Environmental Engineer Mnotpelier Vermont 05602
Re M I T E C Corporation Williston Vermonc
Dear Cedric
There has been an apparent misunderstanding regarding your letter of September 19 1984 as soil and wacer sampling has been commenced ac che above location A call was placed Co your office on October 30th or 31sc and a message lefc for you indicating that we would begin on November 6ch at 8 AM
In the afternoon of November 6th I telephoned Chris Scone co inform him of our progress On che following morning you notishyfied MITEC that approval to begin had not been granced and chac work musC cease AC chac point we had completed che installashytion of five monitors and had extracted Cwo soil samples from the botcom of che wasce pic
On November 8ch I met with you and Chris to oucline che reshysulCs from our effores I was informed Chat we may have to inshystall one or Cwo additional monitors and Chac all future work muse be performed wich an Agency represenCacive in accendance
LaCe that afternoon Gerry Adams phoned Co notify me chat on short notice he was leaving to begin a large contract in rUasashychusetts and that it was unlikely that he would be back in the area for an extended period Had we been permitted to continue ttith our work on the 7th his portion of the project vould have been concluded
Enclosed you will find an updated version of the site plan orishyginally submitced wich my leCCer of Sepcember lOch A new plan will be developed buc Chis drawing will serve the purpose of locating existing and proposed wells
Whereas I am now withouc a drilling concracCor I would like chu
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05461 TELEPHONE 802 878 5171
MITEC 104e 02849
M I T E C Page 2 November 9 1984
authorization to determine groundwater elevations by auger and then establish one more monitor in a location agreed to by all che parcles I feel chac we have developed sufficient information co date to proceed in this manner
Furcher since Adams will noc be available I would also like Co extract che remaining soil samples wich a bucket auger IC can demonstrated chac che sample collected in chls manner will provide a good represencacion of che soil ac che level desired in Che profile
We are prepared co conclude chls phase of che sice evaluacion Samples from Che groundwacer monitors can be secured in a few days and I would like co follow wich che soil samples using che method described above
Please contact me at 878-5171 if you need additional informashytion
H Stuart PE
JHSadt
cc David Gee MITEC
MITEC 104e 02850
JHSTUART December 19 1984
M I T E C Corporation AtCn David Gee Manager IS Commerce Way Wllliscon Vermonc 05495
Dear David
Under Che Cerms of our agreemenc daced 10584 I wish Co proshyvide you wish an up-daCe of the project status
At the completion of 1219 we will have completed Items 1-4 as specified in the agreement specifically the soils sampling and initial set of water samples will have been collected and submitted for analysis As of chls momenC we still do not know the extent of the problem but will have a better indication once the test results are available in about a week My feelshying Is chac the problem is noc severe
We have compleCed all wells as prescribed however Che State is opting for an additional well Although the contract provides for only six the costs to date are below my target and it does not appear Chac any exCra will be necessary provided ChaC che driller concludes his work coday
The only work remaining afCer chls dace will be che collecCion of che second baCch of waCer samples and discussions wich Che State about any remedial action if necessary
Feel free to contacC me if you have any quescions
Regards
John H Stuart PE
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 878 bull 5171
MITEC 104e 02851
JHSTUART
M I T E C Corporation December 20 1984 ACCn David Gee Manager 15 Commerce Way Willaton VT 05495
Dear David
During our investigations yesterday Che work was completed on the additional monitor well as invoiced as well as drilling to the impeding layer The State decided however that two addishytional wells are required both of which will be Installed toshyday west of the Industrial park boundary line
A major change developed In Che method of testing the soils in the vicinity of the disposal pit that is not covered by our contract Instead of the four peripheral borings and one in Che center of che pic which would have produced flfceen soil samshyples che StaCe representatives decided Co require a different CesC paCCern Chac produced thirty seven samples I have collectshyed all of the samples but have Instructed the Cest lab to hold until authorization Is received Co proceed on Chls change as it Is a subsCanClal cost and will cause Che contract limit to be exceeded
Included is an invoice reflecting the additional wells the cost Co sample the groundwater for those monitors and the additional funds needed to run the soil tests I do not believe that any further surprises are in order
Regards
John H Stuart PE
JHSadt
CIVIL ft ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 06451 TELEPHONE 802 878 5171
MITEC 104e 02852
JHSTUART
December 28 1984
M I T E C Corporation Attn David Gee Manager 15 Commerce Way Williston VT 05495
Dear David
Enclosed are the results from the water quality analyses of the samples submitted to our lab I have noted in the left hand column the allowable limits for each element A copy of this information has been forwarded to John Ami-don per his request
There are several readings that are suspicious according to John The cadmium level in 4 may be an error and Che chromium found in 5 mosc likely Includes che CurbldlCy measured only in ChaC well Both should be resampled to confirm The cadmium and chromium levels in 06 exceed che allowable llmlCs but not excessively so The soil tesCs which have begun will reveal more about the ultimate disshyposition of these elemenCs
On the sewer Issue I spoke wich Frank Ailing again and his plans are Co now develop Che design and receive approval chis wincer for consCrucCion of the required Improvements this spring
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 5171
MITEC 104e 02853
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MITEC 104e 02855
JHSTUART January 28 1985
M I T E C Corporation Attn David Gee Manager 15 Commerce Drive WillistonVermont 05495
Dear David
On January 25th I met with John Amadon and Cedric Sanborn to discuss the contents of my 12385 letshyter The following resulted subject to confirmation by more senior members of the AEC staff
1 The water samples to be collected from wells 45 and 6 are to be checked for cadmium both chromiums and conductivity Wells 1 2 and 3 will be tested for conductivity and pH only
2 Samples will be collected from wells 4-9 for orshyganics but only wells 56 and 9 are to be checked at this time to determine the scope of contaminatshyion
3 The material to be removed from the pit is conshysidered as a hazardous waste and there are not any disposal sites located within Vermont certified to receive it I did obtain a listing of contractors that are approved for handling the material and I will provide this during our next meeting
4 Attached is a copy of the State lab results that address the organics problem
5 Based on the above we will have to amend our ashygreement to include the $1150 additional costs for the testing connected with Items 1 and 2
Call me if you have any questions
John H Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 raquo 878 bull 5171
MITEC 104e 02856
JHSTUART January 30 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Attn John Amadon Hydrogeologist Montpelier Vermont 05602
Re M I T E C
Dear John
I have had several discussions with MITEC relative to our meeting of last Friday In essence they have agreed to the program that you defined but with several provisos
They would like a letter from your office detailing the additional measures to be implemented together wich specific instructions as to what steps must be taken in the process of removing the contaminated soil
Further their acceptance to collect and sample for volatile organics is limited Perchloroethylene as I had indicated is not and has not been used by MITEC The materials stored on the premises as well as the list of suppliers for paints and solvents are available for inspection co corroborate that position MITEC will provide a complete analysis of all organics for the specified wells however fushyture testing for TCE will not be at the expense of MITEC unless its presence can be attributed to their operation
We are prepared to proceed as soon as we receive the requested notification
Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 bull 5171
MITEC 104e 02857
TABLE OF CONTENTS (CONTINUED)
PAGE
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS
AND PERMEABLE REACTIVE BARRIER 4-13
431 SHORT-TERM EFFECTIVENESS 4-15
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-16
433 LONG-TERM EFFECTIVENESS 4-17
434 COMPLIANCE WITH ARARs 4-18 435 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-18
436 IMPLEMENTABILITY 4-19
437 COSTS 4-20
44 ALTERNATIVE 4 MONITORING INSTITUTIONAL CONTROLS
AND NATURAL ATTENUATION 4-20
441 SHORT-TERM EFFECTIVENESS 4-21
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-21
443 LONG-TERM EFFECTIVENESS 4-22
444 COMPLIANCE WITH ARARS 4-23
445 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-23
446 IMPLEMENTABILITY 4-23
447 COSTS 4-24
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION 4-25
451 SHORT-TERM EFFECTIVENESS 4-26
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME
THROUGH TREATMENT 4-27
453 LONG-TERM EFFECTIVENESS 4-27
454 COMPLIANCE WITH ARARS 4-28
455 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 4-29
456 IMPLEMENTABILITY 4-29
457 COSTS 4-30
FOR ALLING INDUSTRIAL PARK MWPJXgtCSN7532000AUJNOFSlaquo)0I0030929WPD 111 HSI GeOTrSDS ItlC
MITEC 104e 02355
TABLE OF CONTENTS (CONTINUED)
PAGE
5 COMPARATIVE EVALUATION OF ALTERNATIVES 5-1 51 SHORT-TERM EFFECTIVENESS 5-1
52 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT 5 - 3 53 LONG-TERM EFFECTIVENESS 5-4
54 COMPLIANCE WITH ARARS 5-4
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 5-4
56 IMPLEMENTABILITY 5-5
57 COSTS 5-5
6 PREFERRED REMEDY 6-1 61 PREFERRED REMEDY 6-1
62 MONITORING PROGRAM 6-2
REFERENCES 7-1
APPENDIX A TWODAN INPUT FILES
FOR ALLING INDUSTRIAL PARK MWgt_DOCSW7532000WJJNGfS9^)0M00J(raquo9wpo I V H S I G S O T r a H S I n C
MITEC 104e 02356
LIST OF TABLES
PAGE
TABLE 3-1 REMEDIAL ACTION OBJECTIVES 3-7
TABLE 3-2 DESCRIPTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES 3-8
TABLE 3-3 SELECTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES
FOR DETAILED ANALYSIS 3-11
TABLE 41 COST ESTIMATES FOR REMEDIAL ALTERNATIVES 4-31
TABLE 6-1 SAMPLING LOCATIONS 6-5
TABLE 6-2 VOC ANALYTES 6-6
TABLE 6-3 PARAMETERS TO EVALUATE BIODEGRADATION 6-7
FOR ALLING INDUSTRIAL PARK MWP DOCSN7S32000AUJNOFS9-00I0030929 wro HSI GeoTrans inc
MITEC 104e 02357
LIST OF FIGURES
PAGE
FIGURE 1-1 STUDY AREA LOCATION MAP 1-2
FIGURE 1 -2 LATERAL BOUNDARIES OF REGION OF TCE-CONTAMINATED GROUNDWATER 1 -3
FIGURE 4-1 MODELED SITE-EXISTING CONDITIONS 4-33
FIGURE 4-2 MODELED SITE WITH THREE RECOVERY WELLS PUMPING AT 5 GPM 4-34
FIGURE 4-3 MODELED SITE WITH TEN RECOVERY WELLS PUMPING AT 5 GPM 4-35
FIGURE 4-4 ALTERNATIVE 3 PERMEABLE REACTIVE BARRIER 4-36
FIGURE 6-1 PROPOSED MONITORING LOCATIONS 6-8
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUUNOFS9-OOV 10030929 w r o VI HSI GeoTrans inc
MITEC 104e 02358
1 INTRODUCTION
This Corrective Action Feasibility Investigation is submitted on behalf of Mitec Telecom
Inc (Mitec) by HSI GeoTrans The investigation was done to evaluate potential remedial
alternatives for groundwater contaminated by trichloroethylene (TCE) and to a lesser extent
tetrachloroethylene (PCE) and petroleum related compounds (BTEX) at the Ailing Industrial
Park (the Study Area) A recently prepared Site Investigation Report (SIR) (HSI GeoTrans
2000) identified the nature and extent of contaminated groundwater within the Study Area
Figure 1-1 is a map ofthe Study Area and Figure 1-2 is a map that outlines the region of
contaminated groundwater for which potential remedial alternatives were evaluated
The SIR concluded that the TCE contamination was widespread across the Study Area
that residual TCE dense non-aqueous phase liquid (DNAPL) resulting from one or more releases
was a continuing source of contamination to groundwater and that under current conditions the
groundwater contamination does not pose an unacceptable risk to human health and the
environment Current conditions include the continued effective mitigation of indoor air vapors
at the residence at Lot 3-30 no other residences with basements below the water table and no
use of groundwater within the Study Area as a potable supply The SIR also concluded that if
groundwater were to be used as a potable supply a significant health risk would exist as a result
of exposure to groundwater through ingestion dermal contact and inhalation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^X)M0030929WPD 1 - 1 HSI GCOTrdnS ITC
MITEC 104e 02359
I - N -
Former Mitec Hold y
Meters
Explanation
Study Area TITLE
MITEC 104e 02360
Study Area Location Map
LOCATION
Williston Vermont CHECKED MS FIGURE HSI OfVFTED RMK
GEOTRANS RLE f s ~ Expa nd~S(tsdirq 1-1 A T I T M TICK C011irraquoraquoT DATE- 10600 ~
2 STUDY AREA CONCEPTUAL MODEL
The following discussion ofthe Study Area conceptual model is summarized from
information contained in the previously submitted SIR (HSI GeoTrans 2000)
21 STUDY AREA LOCATION AND DESCRIPTION
The Study Area is located at the Ailing Industrial Park and adjacent areas in Chittienden
County Williston VT The VT state plane coordinates for the Study Area are Northing
71210837 (44 27 T north latitude) and Easting 147576375 (73 7 50 west longitude) The
Study area is within the Winooski River watershed and has an elevation ranging from 330 to 350
feet above mean sea level (MSL) The ground surface has little relief and slopes gently to the
southwest A small unnamed brook flows in a southerly direction along the eastern edge of an
industrial park located within the Study Area There is unlimited public pedestrian access to the
Study Area
22 S T U D Y A R E A L A N D U S E
The land in the Study Area is currently zoned for mixed residential commercial and
industrial use The eastern portion ofthe Study area is primarily zoned for commercial use and
the western portion ofthe Study Area is predominantly residential The Study Area includes an
industrial park where there has been light industrial and commercial use since 1946 Three lots
in the industrial park have been previously identified as locations of former manufacturing andor
fabrication operations that resulted in release of contaminants to groundwater (Brinkerd 1996
TRC 1993 Griffin 1995)
23 HYDROGEOLOGIC SETTING
The unconsolidated geologic deposits beneath the Study Area consist of sand silt and
clay which were deposited in the former Champlain Sea overlying till The unconsolidated
deposits occur in four distinct layers The surficial deposits are medium to fine sand which
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000VALUNoFS9^X)10030929wro 2 - 1 H S I G e O T r a f l S J n C
MITEC 104e 02362
generally becomes finer-grained with depth and extend to approximately 20 feet below ground
surface (bgs) Interbedded silts and fine sands are present from approximately 20 to 40 feet bgs
An areally-extensive clay layer underlies the interbedded silt and fine sands at a depth of
approximately 32 to 60 feet bgs Beneath the clay layer is a dense till which extends from about
60 to 100 feet bgs The underlying bedrock is comprised of massive gray limestone gray
dolomite and white marble ofthe Beckman formation This bedrock is of lower Ordovician age
and is part ofthe Hinesburg Synclinorium structure
The aquifer in the Study Area and surrounding regions is primarily the surficial medium
and fine sands although some water is capable of being extracted from the lower silt and fine
sand The residences and businesses within the Study Area are currently serviced by a public
water supply and the aquifer is not used for potable water supply within the Study Area The
hydraulic conductivity ofthe medium to fine sands was determined from a slug test to be about
20 feetday (Johnson 1999) The hydraulic conductivity ofthe interbedded silt and fine sand as
determined from rising and falling head slug tests (HSI GeoTrans 2000) ranged from 1 to 20
ftday with a geometric mean of 38 ftday A pumping test of well NO-1 yielded a hydraulic
conductivity estimate of about 2 to 30 ftday for the combined medium to fine sands and
underlying silt and fine sand There are no hydraulic conductivity data for the underlying clay
and till layers It is believed that the clay and till act as a lower confining layers restricting the
vertical flow of water between the overlying sand and the underlying bedrock
Beneath the Study Area the depth to water generally ranges from 3 to 11 feet below
ground surface In general groundwater flow beneath the Study Area is from the north to the
southeast and southwest There is a groundwater divide in the water table that runs generally
parallel to Commerce Street East ofthe divide groundwater flows toward and discharges to the
unnamed brook West ofthe divide groundwater flows toward Muddy Brook which is located
about 300 meters or 1000 feet west ofthe Study Area Groundwater recharge within the Study
FOR ALLING INDUSTRIAL PARK MAWPJgtOCSN753UOOOWXINOFS9-O0l0030929wro 2-2 HSI GCOTrdnS IDC
MITEC 104e 02363
Area is primarily from infiltration of precipitation Prior to 1986 when a sewer line was
installed groundwater recharge also resulted from discharge to numerous on-site disposal
systems
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION
Figure 1-2 illustrates the 1999 distribution of TCE-contaminated groundwater within the
Study Area The lateral boundaries ofthe region of TCE-contaminated groundwater
approximately represent the lateral boundaries ofthe region of volatile organic compound
(VOC)-contaminated groundwater As discussed in the SIR (HSI GeoTrans 2000) VOCs
present in groundwater include TCE PCE and BTEX The compound detected at the highest
concentrations and over the largest portion ofthe Study Area is TCE PCE is generally detected
in the same area as TCE but at significantly lower concentrations BTEX compounds have been
detected in groundwater primarily in the eastern portion ofthe Study Area and are commingled
with but not coincident with TCE-contaminated groundwater The lateral boundaries shown in
Figure 1-2 approximately represent the lateral extent of groundwater contamination and are not
intended to indicate that all groundwater within those boundaries is contaminated This figure
includes data collected on behalf of Mitec as part ofthe SIR (HSI GeoTrans 2000) and data
collected in 1999 by the Johnson Company (Johnson 1999) Figure 4-2 A ofthe SIR (HSI
GeoTrans 2000) shows all TCE concentration data collected in 1999 as well as some data
collected in 1997 The SIR (HSI GeoTrans 2000) summarized previous investigations that
indicated that at least three properties have contributed to the region of VOC-contaminated
groundwater On Lot 19-11 there were a disposal lagoon and a leach field that resulted in the
release ofthe VOCs TCE and PCE (perhaps as an impurity in the TCE) Lot 19-12 once had
underground storage tanks from which a previous release of BTEX was discovered when the
tanks were removed Lot 19-2 contained a disposal pit and outfall pipe from which TCE was
reportedly released
Figure 1-2 of this report shows in plan view the areal distribution of TCE-contaminated
groundwater Where there were multiple 1999 data values for the same location preference was
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AL1JNOFS9-OOM0030929WPD 2-3 HSI GSOTraHS JHC
MITEC 104e 02364
given to samples collected by low-flow sampling done subsequent to well installation In
addition for those locations which had samples from different depths the sample with the
highest concentration was used Figure 1-2 illustrates that TCE-contaminated groundwater is
widespread beneath the Study Area and that the highest TCE concentrations are detected in
groundwater beneath the eastern portion ofthe Study Area The figure illustrates that TCE-
contaminated groundwater in the eastern portion ofthe Study Area discharges to the unnamed
brook No VOCs including TCE have been detected in groundwater samples collected from
wells on the eastern side of the unnamed brook Based on surface water and groundwater data
that have been collected the unnamed brook appears to limit the southeasterly extent ofthe
region of VOC-contaminated groundwater In the western portion ofthe Study Area the lateral
boundaries of contaminated groundwater were identified through vertical profile sampling at
several locations Figure 1-2 shows the location ofthe vertical profiling borings that define the
lateral extent of TCE-contaminated groundwater The SIR (HSI GeoTrans 2000) recommended
periodic sampling and analysis of wells in the western portion ofthe Study Area for the purpose
of determining whether this region of VOC-contaminated groundwater was stable or expanding
in size
While not evident from Figure 1-2 it was determined that throughout the Study Area the
highest TCE concentrations were detected in samples collected from the interbedded siltclay
layer As shown on Figure 4-2A ofthe SIR the higher TCE concentrations were generally
detected at a depth of about 35 feet below ground surface in the eastern portion ofthe Study
Area and at a depth of about 30 feet below ground surface in the western portion ofthe Study
Area It is believed that the current distribution of TCE contamination resulted from DNAPL
releases at one or more locations within the Study Area One such release area was at Lot 19-11
DNAPL migrated downward through the upper medium to coarse sands under the primary
influence of gravitational forces There would have been some lateral displacement along
preferential pathways provided by sloping unconsolidated deposits but the primary flow would
have been downward Upon encountering the more resistive capillary pressure forces associated
with the water-saturated finer-grained geologic units such as the interbedded silts and sands
FOR ALLING INDUSTRIAL PARK MVWP_DOCSN7532000ALUNCFS9J3010030929wro 2 - 4 H S I G C O T r d n S I r t C
MITEC 104e 02365
which exist beneath the upper medium to coarse sands the DNAPL downward migration would
have stopped The DNAPL would have accumulated on top ofthe capillary pressure barrier layer
and then would have spread laterally following preferential flow paths within the coarser-grained
geologic units above the interbedded silts and sands The amount of lateral spreading of
DNAPL from any release area would have been dependent upon the volume and frequency ofthe
releases As the DNAPL migrated it would have created a region of residual DNAPL This
region of residual DNAPL consists of isolated DNAPL droplets trapped within pore spaces ofthe
unconsolidated deposits The lateral migration ofthe DNAPL would have been affected by the
slope ofthe surface ofthe finer-grained units that halted downward migration ofthe DNAPL
and it would not necessarily have been coincident with the direction of hydraulic gradient or
groundwater flow The region of residual DNAPL is now a continuing source of contamination
to the groundwater which flows past and gradually dissolves the DNAPL The locations ofthe
residual DNAPL zones are not known
There were no direct observations of DNAPL during drilling and well installation but it
is expected that residual DNAPL generally exists within regions of higher concentration detected
in the eastern portion of the Study Area The residual DNAPL is not necessarily continuously
connected within that region Based on the vertical distribution of TCE concentrations it is also
expected that the residual DNAPL exists in a relatively thin zone within the interbedded silt and
clay Limited hydrodynamic dispersion within the interbedded silt and clay has resulted in a
relatively thin zone of relatively high TCE concentrations in groundwater The southeastward
and southwestward divergence of groundwater flow has resulted in a laterally extensive region of
TCE-contaminated groundwater
There has been no indication in any ofthe investigations done within the Study Area
including the SIR (HSI GeoTrans 2000) that there are locations within the Study Area where
DNAPL is present in sufficient volume to be recoverable in the DNAPL phase
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3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES
31 IDENTIFICATION OF ARARS
Two Applicable or Relevant and Appropriate Requirements (ARARs) were identified in
consultation with Mr Mike Smith ofthe Vermont Department of Environmental Conservation
(VTDEC) The first are the Groundwater Enforcement Standards as outlined in Appendix one of
the Chapter 12 Groundwater Protection Rule (VTDEC 1997) These standards apply to
concentrations of contaminants in groundwater in the Study Area (TCE PCE and BTEX) The
second are the Vermont Water Quality Criteria dated March 142000 (VTDEC 2000) which
specify surface water quality criteria and policy
32 REMEDIAL ACTION OBJECTIVES
The remedial action objectives (RAOs) for the Study Area are summarized in Table 3-1
and further described below
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES
One ofthe RAOs for the Study Area is the remediation of source areas Soil excavation
and removal has already occurred at the known release areas Not withstanding the fact that
previous DNAPL releases are suspected no areas of recoverable DNAPL have been detected in
the Study Area Concentrations of TCE in groundwater indicate it is present in some areas as
residual phase below the water table One purpose of this Corrective Action Feasibility
Investigation is to evaluate options for remediating residual DNAPL in the Study Area
322 GROUNDWATER
Attain VT Groundwater Enforcement Standards The ultimate goal of remediation is to
attain Groundwater Enforcement Standards for VOCs in groundwater This is in accordance
with the VT Groundwater Protection Rule and Strategy (VTDEC 1997) which states that If an
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(MUJNOFS9^)OM0030929WPD 3 - 1 HSI GCOTranS IttC
MITEC 104e 02367
enforcement standard has been reached or exceeded at a compliance point the goal is to take
appropriate action to retum the groundwater quality to below the enforcement standard if
possible
Prevent Expansion ofthe Dissolved Plume A risk assessment (Menzie Cura 2000a and
2000b) was included as part ofthe SIR (HSI GeoTrans 2000) The risk assessment concluded
that under current conditions concentrations of VOCs dissolved in groundwater in the Study Area
do not pose a risk to human health andor the environment The SIR (HSI GeoTrans 2000) also
indicated that the available monitoring data were not sufficient to determine whether the region
of VOC-contaminated groundwater in the southwestern portion ofthe Study Area was stable in
size or expanding This Corrective Action Feasibility Investigation explores options for
monitoring groundwater quality and preventing the region of VOC-contaminated groundwater
from expanding in size
Prevent Potable Use of Groundwater Within the Dissolved Plume Menzie Cura prepared
a June 1 2000 addendum (Menzie Cura 2000b) to the April 2000 risk assessment (Menzie Cura
2000a) The addendum evaluated risk posed by potable use of groundwater at the site The
addendum found there to be a human health risk associated with the use of groundwater at the
site for potable purposes One RAO of this Corrective Action Feasibility Investigation is to
propose institutional controls so that groundwater within the region of contaminated
groundwater would not be used as a potable supply until concentrations are suitable for such use
323 SURFACE WATER
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
under current conditions VOCs dissolved in surface water in the Study Area do not pose arisk to
human health or the environment Currently however surface water concentrations in the
unnamed brook exceed VT Water Quality Criteria (VTDEC 2000) One ofthe RAOs for the
site will be to meet these surface water quality standards in the unnamed brook
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324 INDOOR AIR
The VTDEC has conducted air sampling at several residences along Kirby Lane and
South Browneil Road The results have indicated the presence of TCE and PCE in indoor air at
some ofthe South Browneil Road residences (Brinkerd 1996) and unacceptable VOC
concentrations in the basement ofthe residence at Lot 3-30 on South Browneil Road The
presence of VOC vapors in the residence on Lot 3-30 is believed to have resulted from
volatilization of groundwater which infiltrated the basement through a continuously operating
sump pump The sump was vented to the exterior ofthe house as part of a state-sponsored
action and the indoor air concentration ofthe contaminants reduced to an acceptable
concentration Therefore one institutional control for the site will be to maintain the sump
venting as long as necessary to prevent health risks due to inhalation of VOC concentrations in
indoor air Also an institutional control in the form of a zoning restriction should be
implemented to prohibit the construction of new buildings with basements below the water table
in the region of contaminated groundwater The restriction should specify that in cases where it
is unavoidable to place the basement below the water table proper containment and venting of
the sump drainage system is required
33 INITIAL SCREENING
Four general categories of remedial technologies were evaluated The first monitoring
may be used alone or in conjunction with other remedies The second category includes
institutional controls to prevent exposure to contamination in groundwater and indoor air
Institutional controls could also be used alone or in conjunction with other remedies The third
category includes source removal technologies
The fourth category includes contaminated groundwater containment technologies such
as a hydraulic barrier or permeable reactive barrier Containment technologies can be applied in
two different ways Thefirst source control application would entail installing the containment
technology directly downgradient ofthe highest dissolved concentrations in an attempt to contain
the contaminated groundwater nearest the source Over time if new contamination is not
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MITEC 104e 02369
allowed to migrate beyond the source VOC concentrations in the downgradient region of
contaminated groundwater should attenuate
The second application would entail installing the containment technology at the
downgradient edge ofthe region of Contaminated groundwater The containment would protect
downgradient receptors from impacts by the region of contaminated groundwater
Both containment technology approaches were considered for use in the event additional
monitoring data shows that the region of VOC-contaminated groundwater is expanding in size
or if VOC concentrations in groundwater discharging to the unnamed brook are increasing
Table 3-2 identifies the remedial technologies considered and summarizes the results ofthe
initial screening for applicability to addressing the ARARs
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES
The list of potentially viable technologies shown in Table 3-2 was subjected to an initial
screening process The purpose ofthe initial screening was to identify those technologies that are
potentially feasible in the Study Area prior to performing a more detailed technology screening
Many ofthe source removal technologies were removed from further consideration because of
the impracticability of remediating residual DNAPL at the site
As described in the SIR (HSI GeoTrans 2000) DNAPL is likely present in the Study
Area Although present DNAPL has not been directly observed in any location and there has
been no indication that there is recoverable DNAPL present The failure to detect DNAPL
directly is not an uncommon situation at DNAPL sites and commonly results from its
heterogeneous distribution or its presence only at residual saturation (US EPA 1992)
Groundwater extraction and treatment is not an effective technology for remediation of residual
DNAPL due to limitations resulting from the limited solubility of most DNAPL compounds and
the heterogeneous distribution ofthe DNAPL (US EPA 1993) Designing remedial strategies
for DNAPL is made difficult by the inability to accurately locate the DNAPL sources This
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320(XAALlJNoFS9^)010030929wro 3 - 4 H S I G C O T r a n S I n C
MITEC 104e 02370
inability to locate the DNAPL renders the use of targeted source remedies that might be cost
effective for a small readily definable source area ineffective These targeted source remedies
include excavation air sparging chemical oxidation in-situ thermal desorption and chemical
flushing technologies
Subsurface deposits in the Study Area are heterogeneous due to the interbedded nature of
the sands and silts overlying an areally extensive clay The presence of such heterogeneity
creates extremely variable and unpredictable groundwater flow velocities as well as flow paths
for DNAPL migration The contrast in permeability and porosity between different lithologies
results in the development of preferential flow pathways While preferential flow through coarse
sand and gravel zones provides higher than average groundwater flow rates and contaminant
flushing less preferential flow pathways such as silty sands silts and clays remain poorly
flushed even under forced hydraulic gradients created by extraction wells Contaminants
however may have migrated to these areas of less preferential flow as DNAPLs under
gravitational influence or by diffusion over long periods of time The low permeability zones
even if addressed by localized extraction of groundwater will transmit only small quantities of
water and hence contaminant flushing is slow This is compounded by the low solubility of
DNAPL constituents and the tendency for them to become trapped in soils by capillary pressure
forces
Specific source removal technologies which have been screened out as ineffective at this
stage include air sparging groundwater amendments excavation and in-situ thermal desorption
Low permeability zones prevent the migration of soil vapors or sparged air to the near-surface for
recovery due to the preferential flow caused by heterogenieties it is not possible to determine if
amendments which can be added to the groundwater or chemical flushing compounds which
displace the groundwater and help liberate residual DNAPL such as oxidants alcohol polymers
andor surfactant would reach the DNAPL Excavation which has already been used to remove
impacted surface soils in known release areas is not practical for removing residual DNAPL
deep below the water table The in-situ thermal desorption can be useful in some environments
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MITEC 104e 02371
but can also induce downward DNAPL migration if hydraulic control ofthe system is not
complete Because the location of residual DNAPL is not known and because hydraulic control
ofthe underlying silt clay and till into which the DNAPL may migrate cannot be assured in-situ
thermal desorption is not feasible for this site
Monitoring and institutional controls are included in each option evaluated except for the
no-action alternative These are required to rule out possible future health risks due to expansion
ofthe region of VOC-contaminated groundwater or the creation of new contaminant exposure
pathways
The technologies remaining after the initial screening are presented in Table 3-3
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MITEC 104e 02372
Table 3-1 Remedial action objectives
MEDIA REMEDIAL ACTION OBJECTIVE
Groundwater -Remove or control contaminant sources
bullAttain VT Groundwater Enforcement Standards
-Prevent expansion ofthe region of contaminated groundwater
-Prevent use of groundwater within the region of contaminated groundwater as a
potable water supply where contaminant concentrations exceed federal drinking
water standards
Surface Water -Attain VT Water Quality Criteria
Air -Prevent inhalation of concentrations in indoor air derived from groundwater
FOR ALLING INDUSTRIAL PARK MWP DOCSW7520(XMUJNOFS9^XM0030929WPO 3-7 HSI GeoTrans inc
MITEC 104e 02373
-n Table 3-2 Description of potentially viable remediation technologies o w o
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R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Basement Sump Venting
Restriction on new buildings with basements set below the water table
Restrict Potable Use of Groundwater
Excavation
Natural Gradient Flushing
Air Sparging
RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
PROCESS DESCRIPTION OPTIONS
No Action No Action
Monitor groundwater concentrations to confirm that region of VOC-contaminated groundwater is not expanding in size
Monitor surface water concentrations in unnamed brook to ensure concentrations remain below risk levels
Continue to vent the sumps at Lot 3-30 on South Browneil Road
Restrict construction of any new buildings with basements set below the water table within the area of dissolved VOC contamination and require basement sump venting in those where a below water table basement is unavoidable
Place restrictions on potable use of groundwater at properties overlying the region of VOCshy contaminated groundwater
Excavation and removal of soils containing residual DNAPL
Continued dissolution and natural attenuation of residual DNAPL
Injection of air beneath the water table to volatilize residual DNAPL and dissolved concentrations in groundwater
INITIAL SCREENING C O M M E N T
Used as a baseline for comparison No cost Long remediation time
Can be used in conjunction with other response actions Will be required in the southwest portion ofthe region of contaminated groundwater since existing data are inconclusive regarding this issue
Can be used in conjunction with other response actions
Will be required until data show there is no longer a risk to indoor air from groundwater in the basement
Will be required until data show there is no risk of migration of VOCs to indoor air from groundwater
Will be required at all properties in the area of VOC-contaminated groundwater to prevent a risk to human health
Has been used at the site to remove residual DNAPL in soils in the release areas Impractical to recover residual DNAPL at depth The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Intermediate cost Short time frame to cleanup if all residual source can be removed
Higher permeability zones are preferentially remediated On-going monitoring required No installation or on-going maintenance costs Long time frame to cleanup
Small-scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Intermediate installation and high on-going maintenance costs
MITEC 104e 02374
5 T l O Description of potentially viable remediation technologies (continued) PO
Table 3-2 O
RESPONSE REMEDIAL PROCESS g 5 ACTION TECHNOLOGY OPTIONS 5 m
r-m Source Chemical Ozone m Removal Oxidation Sparging q JO o n o
o
Potassium Permanganate Injection
Fentonss Reagent Injection
i co
Source In-Situ Steam Removal Thermal Stripping
Desorption
Electrical Resistance Heating
I Radio (pound Frequency
O m Heating OH 3) gt Z 0)
DESCRIPTION
Injection of air and encapsulated ozone beneath the water table to oxidize dissolved DNAPL constituents such as TCE
KMn04 is injected below the water table to oxidize dissolved DNAPL constituents
Fentons Reagent is injected below the water table to oxidize dissolved DNAPL constituents
Stream injected below the water table As the groundwater and soil are heated residual DNAPL is mobilized and collected by groundwater and soil vapor extraciion techniques
Low frequency alternating current is applied below the water table to cause resistive heating ofthe soil and groundwater As the groundwater and soil heat residual DNAPL is mobilized Groundwater and soil vapor extraction techniques are used to collect dissolved and vaporized DNAPL constituents
Electromagnetic radiation is applied below the water table As the groundwater and soil heat residual DNAPL is mobilized
INITIAL SCREENING COMMENT
Presence of DNAPL will potentially require large quantities of ozone The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Small scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Ozone is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of KMn04 The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of Fentons Reagent The exact location of the residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Fentons Reagent is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Small scale heterogenieties can result in channeling during steam injection and reduce the recovery efficiency Shallow depth of application may preclude effective steam control The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeneity has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeniety has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult so target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
_ mdash_ mdash _ _
MITEC I04e 02375
bulln Table 3-2 Description of potentially viable remediation technologies (continued) o
R E S P O N S E
A C T I O N
tn Source Removal
Source Containment Plume Management
co bull
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REMEDIAL
TECHNOLOGY
Chemical Flushing
Hydraulic Containment
Impermeable Barrier
Permeable Reactive Barrier
Phytoshyremediation
PROCESS
OPTIONS
bull
DESCRIPTION
Injection and recovery of alcohol polymers andor surfactant below the water table to enhance dissolution of residual DNAPL
Pump groundwater in downgradient portion of VOC-contaminated region groundwater to intercept contamination before it reaches a receptor or downgradient ofthe highest concentrations as source containment
Impermeable barrier is installed in the subsurface to contain groundwater and reduce the pumping rate needed for containment Can be installed upgradient of a receptor to prevent exposure or downgradient of the highest concentrations as source containment
Reactive material such as zero valent iron placed in flow path of contaminated groundwater Contaminants are treated as the natural gradient causes groundwater to flow through the barrier
Extracting of contaminated groundwater by evaporation from high water use trees Organic contaminants may also be biodegraded by the root system or may adsorb to living or dead root tissue and become immobilized
INITIAL SCREENING C O M M E N T
Higher permeability zones are preferentially remediated The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Groundwater extraction is required to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent fulfresidual DNAPL removal Very high installation and operation cost
Effective in containing dissolved concentrations Relatively low installation cost moderate on-going maintenance costs
Effective in containing dissolved concentrations Requires groundwater extraction and treatment Moderate installation cost moderate on-going maintenance costs
Moderate installation costs Lifetime of reactive material difficult to predict and reinstallation may become necessary No on-going maintenance costs prior to replacement
Still experimental Hard to confirm water usage rates and prove containment Trees may require ongoing monitoring and replacement Low installation and maintenance costs Only operates during the growing season
MITEC 104e 02376
1 T l Table 3-3 Selection of potentially viable remediation technologies for detailed analysis 1
rt g g g
5
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RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Indoor Air Monitoring
Basement Sump Venting
Potable Use of Groundwater
Restrict Basements Below Water Table
Excavation
Natural Gradient Flushing
Air Sparging
Chemical Oxidation
In-Situ Thermal Desorption
Chemical Flushing
PROCESS
OPTIONS
No Action
Ozone Sparging
Potassium Permanganate Injection
Fentonss Reagent Injection
Steam Stripping
Electrical Resistance Heating
Radio Frequency Heating
RETAINED
DISCARDED
Retained
Retained
Retained
Retained
Retained
Retained
Retained
Discarded
Retained
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
RATIONALE
Used as a baseline for comparison
Necessary to evaluate if the region of VOC-contaminated groundwater is expanding in size and if the VOC concentrations in groundwater discharging to the unnamed brook are increasing
Necessary to monitor that concentrations remain below health risk levels
May be required al new residences with basements below the water table built in Browneil Road area
The existing sump vents at Lot 3-30 on South Browneil Road will be required to mitigate indoor air risks
Restriction of potable use of groundwater at properties overlying the region of VOC-contaminated groundwater will be required to prevent dermal ingestion and inhalation exposure
Restriction of construction of new basements below the water table in the area of VOC-contamination will be required to prevent future inhalation risks
Residual DNAPL located too far below ground surface to make excavation feasible The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Excavation of known release areas has occurred
Longer time frame to clean up not a drawback at this site Lower cost is a benefit
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location of the residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL Steam control difficult
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
MITEC 104e 02377
2 Table 3-3 Selection of potentially viable of remediation technologies for detailed analysis (continued) a m RESPONS E R E M E D I A L PROCES S RETAINED RATIONALE
ACTION T E C H N O L O G Y OPTION S DISCARDED
Source Containment Hydraulic Containment Retained Proven effective at containing expansion ofthe region of contaminated groundwater Region of Contaminated
iisect
n n o
Groundwater Management
Impermeable Barrier Retained Proven effective at region of contaminated groundwater containment
Permeable Reactive Retained Proven effective at region of contaminated groundwater containment Barrier
Phyto-remediation Retained Experimental however there are no potential negative consequences in using the technology Low cost is a benefit
co i
IO
I (A O m OH 73 gtZ
MITEC 104e 02378
4 DETAILED ANALYSIS OF ALTERNATIVES
41 ALTERNATIVE 1 NO ACTION
The no-action alternative is included in accordance with EPAs Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA (EPA 1988) The no-action
alternative provides a baseline for comparison and involves taking no additional actions at the
Study Area This remedy assumes no continuing monitoring of dissolved concentrations in
groundwater surface water or concentrations in indoor air This remedy assumes no institutional
controls on basement sump venting at Lot 3-30 on South Browneil Road property no restrictions
on new buildings with basements set below the water table constructed within the area of VOC
concentrations in groundwater and no restrictions groundwater use for potable purposes within
the region of VOC-contaminated groundwater
411 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community The risk assessment completed for the SIR
(HSI GeoTrans 2000) concluded that current conditions at the Study Area do not pose a risk to
human health Current conditions include venting ofthe sump at Lot 3-30 on South Browneil
Road no buildings other than at Lot 3-30 with basements below the water table in VOC-
contaminated areas and no potable-use wells within the region of VOC-contaminated
groundwater Without institutional controls to ensure this there may be future risk The risk
evaluation indicated that concentrations in the unnamed brook resulting from contaminated
groundwater discharge while not above risk-based thresholds were close to levels that could
pose a risk to human health Therefore monitoring is advised to confirm that VOC
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7533000AUJNOFS9^010030929WPD 4 - 1 HSI GGOTrSOS jflC
MITEC 104e 02379
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of VOC-contaminated groundwater could result in health risks not
evaluated in the risk assessment
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative
Time to Achieve Remedial Action Objectives It is estimated that the time frame required
for natural attenuation of contaminants to meet the groundwater cleanup concentrations will
significantly exceed the two-year time frame used to evaluate short-term effectiveness
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment There is no treatment of contaminants under this option
Reduction in Toxicity Mobility or Volume Some reduction of residual DNAPL and
accompanying dissolved concentrations is expected through natural attenuation over time if no
action were pursued at the Study Area However no monitoring data would be available to
confirm the progress
Amount of Material Contained or Treated Natural attenuation may serve to contain the
entirety of the region of groundwater contaminated with dissolved VOCs
413 LONG-TERM EFFECTIVENESS
Residual Risk Therisk assessment completed for the SIR (HSI GeoTrans 2000)
concluded that current conditions at the Study Area do not pose a risk to human health
However the risk evaluation indicated that concentrations in the unnamed brook resulting from
contaminated groundwater discharge while not above risk-based thresholds were close to levels
that could pose a risk to human health Therefore monitoring is advised to confirm that VOC
FOR ALLING INDUSTRIAL PARK
M W P _ D O C S N 7 5 3 2 0 0 0 A L U N O F S W raquo I 0 0 3 0 9 2 9 W P D 4-2 HSI GeOTrdDS IflC
deg2380
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of contaminated groundwater could result in health risks not evaluated in
the risk assessment Without institutional controls to ensure basement sump venting at Lot 3-30
on South Browneil Road restrictions on new buildings with basements set below the water table
within the region of VOC-contaminated groundwater and prevention ofthe installation of wells
for potable supplies within the region of VOC concentrations in groundwater a residualrisk to
human health remains
Adequacy and Reliability of Controls This remedy does not assume the sump in the
basement ofthe residence at Lot 3-30 on South Browneil Road remains sealed and vented to the
outside and that the pump is maintained in operable condition to continue to keep groundwater
out ofthe basement Previous air sampling conducted by the VTDEC has confirmed that this is
necessary to control indoor air impacts to this residence This remedy relies on natural
attenuation to control the region of VOC-contaminated groundwater however there is no
continuing monitoring of dissolved VOC concentrations in groundwater Since monitoring to
date has not confirmed that the region of VOC-contaminated groundwater is not expanding in
size a remedy which has a natural attenuation component but does not include monitoring does
not provide adequate control
Permanence of Remedy In the very long-term natural gradient flushing should reduce
VOC concentrations in groundwater to acceptable levels
414 COMPLIANCE WITH ARARs
Groundwater Protection Rule and Strategy It is expected that natural attenuation would
over time reduce groundwater concentrations to below VT Groundwater Enforcement Standards
However a no-action response would not comply with VT Groundwater Protection Rule and
Strategy (VTDEC 1997) which allows for remediation of sites by natural attenuation if sufficient
monitoring is perfonned to document that expansion ofthe region of contaminated groundwater
is not occurring and that natural attenuation is occurring The no-action alternative would not
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AU1NGFS90010030929wro 4-3 HSI GSOTraFIS IflC
MITEC 104e 02381
allow for continued monitoring and would not meet this requirement
Surface Water Quality Standards It is expected that natural attenuation would over
time reduce surface water concentrations to below VT Water Quality Criteria for the protection
of human health and aquatic organisms (VTDEC 2000)
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
concentrations of VOCs adsorbed to soil and dissolved in groundwater in the Study Area do not
pose a risk to human health andor the environment under current uses There would be arisk if
groundwater within the region of VOC-contamination were used as a potable supply Therefore
if dissolved concentrations were not migrating beyond the limits ofthe region identified in the
SIR (HSI GeoTrans 2000) and groundwater were not used for potable purposes the no action
alternative would be protective of human health and the environment However there are not
sufficient data to determine whether the region of VOC-contaminated groundwater is stable or
decreasing in size If the region of contaminated groundwater were expanding beyond the limits
upon which the risk assessment was based there may be a future risk to human health and the
environment Also restrictions should be placed on properties overlying the region of VOC-
contaminated groundwater to prohibit construction of basements below the water table and the
use of groundwater as a potable supply and the venting ofthe sump at Lot 3-30 should continue
416 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000AlXINGFS900U0030929wro 4-4 HSI GGOTrdRS IflC
MITEC 104e 02382
Technical Feasibility The no-action alternative is technically feasible
bull Ability to Construct the Alternative The no-action alternative requires no
construction
bull Reliability ofthe Technology No technology would be applied under the no-
action alternative
bull Ease of Undertaking Additional Remedial Actions The no-action alternative
would not prevent future remedial actions
Administrative Feasibility The no-action alternative is administratively feasible
Availability of Services and Materials No services or materials are required to carry out
the no-action alternative
417 COSTS
There are no costs associated with the no-action alternative The no-action alternative is
shown on Table 41 for purposes of comparison
4 2 A L T E R N A T I V E 2 M O N I T O R I N G INSTITUTIONAL C O N T R O L S AND
H Y D R A U L I C C O N T A I N M E N T
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull institutional controls would be implemented to restrict construction of any
buildings with basements within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull groundwater extraction and treatment would be done to contain the region of
VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753laquo000WJJNoFS9JXI10030929wro 4 - 5 HSI GSOTraDS JllC
MITEC 104e 02383
Groundwater pumping is an effective technology for hydraulic containment of
contaminated groundwater Hydraulic containment can be used if the region of VOC-
contaminated groundwater is impacting a sensitive receptor or is expanding is size The risk
assessment (Menzie Cura 2000a and 2000b) showed that groundwater was not impacting any
receptors to a degree that would represent a human health risk or risk to the environment There
is not sufficient temporal data however to confirm that the region of VOC-contaminated
groundwater is not expanding is size Therefore an analysis of hydraulic containment has been
included in this Corrective Action Feasibility Investigation in the event that future monitoring
shows the region of VOC-contaminated groundwater is expanding and that containment is
necessary
If monitoring indicates that natural attenuation is not causing the region of VOC-
contaminated groundwater to be stable in size or to shrink then an active containment remedy
may be required Under this scenario a groundwater pump-and-treat system would be installed
and operated in the Study Area to hydraulically contain contaminated groundwater and prevent
expansion ofthe region of VOC-contaminated groundwater Pumping wells would be installed
in the overburden silts and sands to the clay layer Wells would be installed in the downgradient
portions of contaminated groundwater to the southeast and southwest Extracted groundwater
would be treated before discharge to surface water The primary treatment operation will be air
stripping with a low-profile stripper for the removal of VOCs primarily TCE Depending on
treatment efficiencies secondary treatment with granular activated carbon may be required In
addition a particulate filter may be added to remove iron prior to treatment and reduce iron
fouling ofthe air stripper and carbon Extracted and treated groundwater would be discharged to
surface water via an outfall Compliance sampling can be conducted at the outfall or at a
sampling point within the treatment building The outfall should be constructed to minimize
hydraulic impacts on the receiving water body
The number and location of pumping wells that may be required to capture and contain
the region of TCE-contaminated groundwater has been investigated using the two-dimensional
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9JXA10030929WO 4-6 HSI GSOTfanS IdC
MITEC 104e 02384
analytical element simulation code TWODAN (Fitts 1997) TWODAN is a commercially
available copyrighted program The input parameters to the model are based on the values
reported in the SIR (HSI GeoTrans 2000) Input data sets for the analyses contained in this
report are included in Appendix A The bottom elevation ofthe model is 306 ft which is
representative ofthe top ofthe continuous clay layer beneath the site The model represents the
interbedded silts and fine sand layer and the overlying medium to fine sand surficial unit as one
layer The hydraulic conductivity ofthe modeled layer is 184 ftday The estimated areal
recharge for the model is 10 inyr The basement sump at Lot 3-30 on South Browneil Road
pumps groundwater year round The resulting depression ofthe water table is represented by a
constant head of 33128 ft which is approximately 8ft below ground surface at that location
Groundwater elevations used in the model were based on an average ofthe July 1999 and
December 1999 potentiometric surface in wells with screened intervals intersecting the water
table The model representation of current hydrologic conditions at the Study Area is shown in
Figure 4-1 Groundwater elevations are shown in meters on this figure
Two containment scenarios were evaluated The first was a source control application in
which the TWODAN model was used to determine the number of wells and pumping rates
required to contain the 10000 to 20000+ ugL TCE concentration zone as shown in Figure 1-2
In this scenario pumping would contain the contaminated groundwater nearest the source(s)
Over time if new contamination is not allowed to migrate from the source(s) the VOC
concentrations in the rest ofthe region of contaminated groundwater would attenuate The
second scenario was a containment application in which the TWODAN model was used to
determine the number of wells and pumping rate required to contain the 1000 to 10000 (igL
TCE concentration zone as displayed in Figure 1-2 In this scenario pumping occurs in the
downgradient portions ofthe contaminated groundwater
Each recovery well was assumed to be 4 inches in diameter fully screened and have a
pumping rate of 5 gpm The pumping rate was based on the aquifer testing results reported in the
SIR (HSI GeoTrans 2000) applied to a fully screened extraction well The results ofthe model
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000A1XINOFS9JX)10030929WPD 4-7 HSI GSOTraDS IflC
MITEC 104e 02385
analyses indicate that a minimum of three 4-inch diameter recovery wells pumping at 5 gpm are
required to contain the 10000 to 20000+ ugL TCE concentration zone The results of this
model simulation are shown on Figure 4-2 The model analyses also indicated that a minimum
often 4-inch diameter recovery wells pumping at 5 gpm are required to contain the 1000 to
10000 ugL TCE concentration zone Figure 4-3 shows the results of this model simulation
Figures 4-2 and 4-3 also show that groundwater extraction for hydraulic containment may induce
infiltration of surface water in response to pumping thereby reducing the amount of water
flowing in the brook
421 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 2 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with extraction well construction and treatment plant construction Access by
unauthorized personnel would be restricted by fencing temporary barriers andor warning signs
The groundwater treatment building would be locked and secured A health and safety plan
(HASP) would be prepared for the remedial activities In conformance with Occupational Safety
and Health Administration (OSHA) regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative Suitable dust control measures would be implemented during
construction ofthe groundwater treatment system Additionally the treatment process is
expected to be relatively simple with a low potential for exceedance of discharge limitations
Monitoring ofthe treatment process would be performed
Time to Achieve Remedial Action Objectives The time estimated for well installation
system debugging and establishing hydraulic gradient control is three to six months The RAOs
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^XM0030929wro 4-8 HSI GSOTraOS IIIC
MITEC 104e 02386
for groundwater would be achieved when monitoring results indicated that VOC concentrations
had attenuated and groundwater standards had been met It is estimated that attenuation of VOC
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of recovered groundwater would remove some ofthe VOCs from
the aquifer This treatment would generate residuals such as used filters and spent carbon This
process is irreversible
Reduction in Toxicity Mobility or Volume Treatment ofthe extracted groundwater
would reduce its toxicity prior to surface water discharge Contaminants adsorbed to any
secondary carbon would ultimately be destroyed during the process of regenerating the carbon
Contaminants adsorbed to any particulate filters would be landfilled or incinerated along with the
filters The toxicity and volume of contamination in groundwater are nominally reduced by
extraction and treatment but effectiveness is limited as discussed in Section 421 above
Modeling shows that groundwater extraction would be effective in reducing the mobility ofthe
dissolved phase contamination
Amount of Material Contained or Treated The volume of contaminated groundwater
that would be treated on a long-term basis is estimated at about 8 million gallons per year for the
source containment option and about 26 million gallons per year for containment of all dissolved
TCE concentrations greater than 1000 ugl
423 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
FOR ALLING INDUSTRIAL PARK MWPJXXTSN75320(XAAUJNOFS9-OCM0030929WKgt 4-9 HSI GSOTrSDS IDC
MITEC 104e 02387
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Groundwater pumping would control any risks caused by expansion ofthe
region of contaminated groundwater Residual risk to human health would be controlled through
institutional controls
Adequacy and Reliability of Controls Extracted groundwater would be treated on-site to
standards required for discharge to surface water The extraction well pumps and groundwater
treatment equipment would require maintenance on a long-term basis Groundwater monitoring
to ensure that the contamination was being adequately contained by the groundwater extraction
would be necessary on a long-term basis
Permanence of Remedy The groundwater treatment plant would be enclosed and
designed as a modular system and its equipment would be readily replaceable if required The
extraction wells may need to be rehabilitated andor replaced during the life ofthe remedy
424 COMPLIANCE WITH A R A R S
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to return the
remaining groundwater to below Groundwater Enforcement Standards Groundwater extraction
would also eventually return the areas of highest groundwater contamination to below
Groundwater Enforcement Standards
Surface Water Quality Standards Hydraulic control of the groundwater migration would
interrupt and remove contaminates from groundwater thereby preventing discharge to the
unnamed brook resulting in achievement of Water Quality Criteria for the protection of human
health and aquatic organisms (VTDEC 2000)
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200OALUNoFS9^Kgtl0030929wro 4-10 HSI GOOTrSDS IDC
laquoTEC I04e 02388
425 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The hydraulic containment alternative would offer protection to both human health and
the environment if expansion ofthe region of contaminated groundwater were identified Since
the risk assessment (Menzie Cura 2000a) found that under current conditions groundwater and
surface water concentrations are below levels which constitute a risk to human health and since
hydraulic containment would ensure the region of VOC-contaminated groundwater remained in
the current configuration hydraulic containment would be protective of human health and the
environment This alternative assumes institutional controls will be in place to continue sump
venting in the basement at Lot 3-30 on South Browneil Road restrict the installation of
basements below the water table within the region of VOC-contaminated groundwater and
prevent potable use of groundwater within the region of VOC-contaminated groundwater
Protection would be achieved at the end ofthe construction period of three to six months The
residual risks posed by contaminated material remaining within the groundwater would not be
significant because all potential exposure routes would be addressed
426 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction which would present no special problems
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AUB4CFS9^10l0030929wro 4 - 1 1 HSI GGOTrdDS IDC
MITEC 104e 02389
bull Reliability ofthe Technology Hydraulic gradient control is a frequently used
alternative that has proven effective in preventing further expansion of areas with
- contamination in groundwater Filtration air stripping and carbon absorption
have frequently been used and proven effective in treating groundwater in other
applications
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the
gradient control system was inadequate to restrict the expansion ofthe region of
contaminated groundwater implementation of additional resources would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
operate maintain and monitor the well head portions ofthe treatment system Institutional
controls would also be needed to implement institutional controls to continue sump venting in
the basement at Lot 3-30 on South Browneil Road The town must pass zoning restriction which
would prevent construction of basements below the water table and potable use of groundwater
within the region of contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor the groundwater treatment system associated with the hydraulic containment option
are available
427 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 2 The
capital costs would be $207000 for the source control application and $732000 for the
containment option OampM costs include groundwater monitoring and maintenance ofthe
groundwater extraction and treatment system These are $77000 per year for the source control
application and $139000 per year for the containment option The present worth analysis
(calculated at a 7 discount rate interest for 30 years) yields a total of $1085403 for the source
control application and $2287474 for the plume containment option
FOR ALLING INDUSTRIAL PARK MWPJXXSN753U0OOALUNGFS9-tfW0030929wro 4-12 HSI GSOTrailS IRC
MITEC 104e 02390
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS AND
PERMEABLE REACTIVE BARRIER
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull and a permeable reactive barrier would be installed and maintained at a
downgradient location to reduce concentrations of TCE dissolved in groundwater
as it flows under natural gradient flow conditions if groundwater monitoring
shows the region of VOC-contaminated groundwater is expanding in size
PRBs consist of a permeable region of chemically reactive materials constructed to
intercept the path of a dissolved groundwater contaminants Reactive materials may include
bull zero-valent iron for reductive dehalogenation
precipitation agents such as gypsum to create insoluble metal salts
bull sorptive agents such as granular activated carbon to capture and immobilize organics
bull reducing agents such as dithionite and hydrogen sulfide to reduce and insolubilize metals
and
bull biologic electron acceptors such as lactic acid or nitrate to enhance aerobic
biodegradation
FOR ALLING INDUSTRIAL PARK MAWPJX)CSVN7532000AmNOFS9-OOU0030929wpo 4-13 HSI GSOTrSDS IDC
MITEC 104e 02391
Zero-valent iron and granular activated carbon are both applicable for use in the treatment
of TCE in a PRB Granular zero-valent iron has been widely applied in PRB installations and
promotes reductive dehalogenation of TCE to chloride ion ethane and ethene Activated carbon
has been used in a limited number of field and lab studies to simply adsorb dissolved organic
constituents as they pass through thePRB
Because ofthe costs ofthe reactive or adsorptive material PRBs are generally
constructed as a funnel and gate system The funnel portion ofthe PRB is a typical vertical
barrier wall constructed of sheet piles bentonite or other impermeable material which is
designed to direct groundwater flow to the gate portion ofthe PRB containing the reactive or
adsorptive material Funnel and gate sections ofthe PRB are keyed together and generally to a
low permeablility zone located at depth
The use of permeable reactive barriers is not directly applicable to treatment of DNAPL
The mechanism for groundwater remediation using a PRB would include
bull dissolution ofthe DNAPL into groundwater by natural processes
bull downgradient transport ofthe dissolved contaminants to the PRB location
artificial channeling ofthe contaminated groundwater to the reactive material located in
the gate by the barrier funnel and
bull reductive dehalogenation or adsorption of a portion ofthe VOC as is passes through the
gate
A variety of methods are available for emplacement ofthe PRB The most conventional
method includes excavation of a trench and backfill will a soilbentonite slurry for the funnel
portion and granular iron or carbon in the gate section Other methods such as sheet-piling jet
grouting continuous trenching fracturing and others are available For the subject site because
ofthe presence of sand in the formation it is likely that a continuous trenching method would be
the most applicable and cost effective
FOR ALLING INDUSTRIAL PARK MWPJX)CSN7S320O0ALUNGFSraquo-O0U0030929wro 4-14 HSI GGOTfaDS IOC
MITEC 104e 02392
Operation maintenance and monitoring ofthe PRB is relatively simple Groundwater
samples would be periodically collected from locations upgradient and downgradient ofthe gate
section(s) ofthe PRB to monitor its effectiveness Media installed in the gate (iron or carbon)
would require periodic replacement probably on a annual basis for carbon and every 5 to 10
years for iron
The placement depth width and length ofthe PRB would depend on the region of
VOC-contaminated groundwater that was desired to be intercepted the depth to the underlying
low permeability layer and the desired TCE concentration reduction (which determines resident
time required in the gate) As wilh hydraulic containment two scenarios were investigated The
first a source control option would intercept VOC-contaminated groundwater with TCE
concentrations greater than 10000 ugL A PRB of approximately 1200 feet in length would be
required The second a region of contaminated groundwater containment option would
intercept VOC-contaminated groundwater with TCE concentrations in excess of 1000 ugL A
PRB of approximately 2200 feet in length would be required The depth ofthe PRB in both
cases would likely extend from ground surface to about 40 feet below ground surface The PRB
would be installed into the underlying areally-extensive clay layer Figure 4-4 shows the
placement ofthe PRB under each opinion
431 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 3 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with PRB construction since either conventional or continuous trenching methods
would be employed during its construction However exposure hazards during construction
would be considerable since the emplacement requires excavation and handling of a large
volume of potentially contaminated soils During construction access by unauthorized personnel
would be restricted by fencing temporary barriers andor warning signs Following
FOR ALLING INDUSTRIAL PARK
MWP_DOCSN753 2000 AUJNCFS9^10 10030929 WPD 4-15 HSI GSOTrSPS IDC
MITEC 104e 02393
construction little to no hazards should be expected from the long-term operation ofthe PRB A
HASP would be prepared for the construction activities In conformance with OSHA
regulations site workers would be trained required to wear appropriate protective equipment
and as applicable would be enrolled in a medical monitoring program Groundwater monitoring
wells would be sampled to determine changes in VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative with proper controls Suitable dust control vapor monitoring and
stormwater runoff measures would be implemented during construction ofthe PRB
Time to Achieve Remedial Action Objectives The time estimated for PRB emplacement
is four to six months The RAOs for groundwater would be achieved when monitoring results
indicated that the VOC concentrations have attenuated and groundwater standards have been
met It is estimated that attenuation of contaminant concentrations to ARARS will significantly
exceed the two-year time frame for short-term effectiveness This is because the application of a
PRB at the site would not significantly alter groundwater flow or TCE dissolution from within
the source area Therefore it would not increase the rate at which concentrations of residual
DNAPL or dissolved constituents of DNAPL (TCE) were removed from the source area It
would however limit the size ofthe region of VOC-contaminated groundwater
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of groundwater flowing through the permeable sections ofthe PRB
would remove the dissolved TCE as is flows under natural gradient conditions from the source
area
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNGFS9^X)10030929WPO 4-16 HSI G G O T T S O S jflC
MITEC 104e 02394
Reduction in Toxicity Mobility or Volume Treatment ofthe groundwater would reduce
its toxicity Contaminants adsorbed to carbon (if used as the treatment media in the gate sections
ofthe PRB) would be excavated on a periodic basis and ultimately be destroyed during the
process of regenerating the carbon
Amount of Material Contained or Treated The volumetric flux of contaminated
groundwater through the PRB is estimated to be approximately two million gallons per year for
the 10000 (igL source containment option and approximately four million gallons per year for
containment of all dissolved TCE concentrations greater than 1000 ugL
433 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Treatment of groundwater intersecting the PRB would control any risks
caused by expansion ofthe region of contaminated groundwater to the southeast Residual risk
to human health would be controlled through institutional controls
Adequacy and Reliability of Controls Performance of PRBs in reducing concentrations
of chlorinated organics such as TCE using zero-valent iron has been mixed Most ofthe PRB
performance demonstrations indicate that a concentration reduction of 60 to 90 percent can be
expected Some applications however have been much less successful at reducing VOC
concentrations Although little experience is available for PRBs using activated carbon the
removal efficiency should be expected to be greater and more reliable than zero-valent iron but
far more costly Groundwater monitoring would ensure that the contamination was being
adequately contained by the PRB and would be necessary on a long-term basis
Permanence of Remedy Installation of a PRB would be considered a permanent remedy
although periodic maintenance and replacement of reactive material in the gate would be
required for both carbon and iron-based systems
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9^X)l0030929wro 4-17 HSI GGOTfSnS IDC
MITEC 104e 02395
434 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to reduce VOC
concentrations in the remaining groundwater to below Groundwater Enforcement Standards
Natural gradient flushing would also eventually reduce the areas of highest groundwater
contamination to below Groundwater Enforcement Standards
Surface Water Quality Standards VOC concentrations in groundwater discharging to the
unnamed brook would be reduced significantly Thus operation ofthe PRB would result in
achievement of Water Quality Criteria for the protection of human health and aquatic organisms
(VTDEC 2000)
435 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This downgradient containment alternative would offer protection to both human health
and the environment if VOC concentrations in groundwater discharging to the unnamed brook
were to increase or if the region of contaminated groundwater were to expand in size This
alternative assumes institutional controls will be in place to continue sump venting in the
basement at Lot 3-30 on South Browneil Road restrict installation of new basements below the
water table within the region of VOC-contaminated groundwater and prevent potable use of
groundwater within the contaminated region Protection relative to the risks posed by expansion
ofthe region of contaminated groundwater to the unnamed brook would be achieved at the end
ofthe construction period of four to six months The residual risks posed by contaminated
material remaining within the groundwater would not be significant because all potential
exposure routes would be addressed
FOR ALLING INDUSTRIAL PARK MWP JX3CSN753V2000AIXINOFS90Crl0O30929wPD 4-18 HSI GCOTtSHS IRC
MITEC 104e 02396
436 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
bull Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction Removal and handling of contaminated soils
presents potential risks to construction workers during construction which could
be minimized through health and safety controls
bull Reliability of the Technology Although many full-scale applications of this
approach have been conducted they have been relatively recent Long-term
reliability and effectiveness of PRBs has not been established
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the PRB
was inadequate to prevent expansion ofthe region of VOC-contaminated
groundwater implementation of additional resources would not be hampered by
this alternative
Administrative Feasibility Installing and maintaining the PRB will require access to
properties overlying the region of VOC-contaminated groundwater Additionally property
owner cooperation would be needed to operate maintain and monitor wells located upstream
and downstream ofthe gate sections ofthe PRB system Restrictions would also be needed to
implement institutional controls to continue sump venting in the basement at Lot 3-30 on South
Browneil Road restrict the construction of basements below the water table within the region of
VOC-contaminated groundwater and prevent potable use of groundwater within the region of
VOC contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UO(XAAUJNOFS9-O0 10030929 WPO 4-19 HSI GGOTrSMS IDC
MITEC 104e 02397
Availability of Services and Materials The materials equipment and personnel required
to design install and maintain the PRB are readily available
437 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 3 The
capital costs would be $572000 for the source control application and $1022000 for the
containment option OampM costs include groundwater monitoring and periodic replacement of
the permeable barrier These average $64000 per year for the source control application and
$112000 per year for the containment option The present worth analysis calculated at a 7
discount rate over a 30-year duration yields a total of $1277356 for the source control option
and $2248691 for the containment option
4 4 A L T E R N A T I V E 4 M O N I T O R I N G I N S T I T U T I O N A L C O N T R O L S AND
N A T U R A L A T T E N U A T I O N
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water
The chief mechanisms contributing to reduction of contaminant concentrations in
groundwater by natural attenuation include biotransformation dilution dispersion and discharge
through advective flow and volatilization (EPA 1998) Volatilization is not likely a major
mechanism at the Study Area since contaminated groundwater is located at depth below the
FOR ALLING INDUSTRIAL PARK
MWP_DOCSW7S3U000WXINoFS9-001003O929wro 4-20 HSI GGOTfaDS IDC
MITEC 104e 02398
water table A natural attenuation evaluation will be conducted to better identify the mechanisms
contributing to concentration reduction through natural attenuation Monitoring to be completed
for this evaluation is included in Section 62 EPAs Technical Protocol for Evaluating Natural
Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) was used as the basis for the
design ofthe natural attenuation evaluation
441 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community A HASP would be prepared for the remedial
activities In conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Groundwater monitoring wells would be sampled to determine changes in
VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative
Time to Achieve Remedial Action Objectives The RAOs for groundwater would be
achieved when monitoring results indicated that the region of contaminated groundwater had
naturally attenuated and groundwater standards had been met It is estimated that natural
attenuation of contaminants to ARARS will exceed the two-year time frame for short-term
effectiveness
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0ALUNOFS9^X)M0030929wro 4-21 HSI GGOTfaflS jflC
MITEC 104e 02399
Treatment This alternative involves only natural in-situ processes No remediation
wastes would be generated
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area
Amount of Material Contained or Treated Natural attenuation may serve to contain the
region of VOC-contaminated groundwater at the Study Area Treatment may be accomplished
through biotransformation ofthe contaminants to environmentally acceptable compounds
443 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation of VOC-contaminated groundwater at the Study Area
would eventually achieve the ARARs Residual risk to human health would be controlled
through institutional controls Implementing institutional controls to maintain the sump venting
at Lot 3-30 on South Browneil Road restrict the construction of basements below the water table
within the region of VOC-contaminated groundwater and to control the use of groundwater
within the region of VOC-contaminated groundwater for potable purposes would provide
protection against the potential for exposure
Adequacy and Reliability of Controls Monitoring for VOC concentration reductions in
groundwater and institutional controls would be the main controls of this alternative Sump
venting at Lot 3-30 on South Browneil Road would prevent indoor air impacts at this location
and restrictions on construction of basements below the water table would prevent future indoor
air impacts Control ofthe use of groundwater within the region of VOC-contaminated
groundwater for potable purposes would minimize potential use of groundwater with VOCs
above federal and state drinking water standards Groundwater monitoring would ensure that
attenuation of VOC concentrations was proceeding and provide for periodic assessment ofthe
region of VOC-contaminated groundwater in the Study Area
FOR ALLING INDUSTRIAL PARK bull MWPJXXSN7532000AUINOFS9-00I0O30929WPD 4 - 2 2 HSI GGOTPaMS IRC
MITEC 104e 02400
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time
444 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
445 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
446 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK _
M W P _ D O C S N 7 5 3 U O O O A L U N O F S 9 - O O U 0 0 3 0 9 2 9 W P O 4-23 HSI GGOT 13118 IflC
MITEC 104e 02401
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
bull Ability to Construct the Alternative No major construction is included in this
alternative
bull Reliability ofthe Technology Ongoing monitoring and evaluation on would
ensure that natural attenuation was controlling and remediating the contaminated
groundwater
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation was not restricting the size ofthe region of VOC-contaminated
groundwater implementation of additional remedial actions would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
sample and maintain monitoring wells Restrictions would also be needed to implement
institutional controls to continue sump venting in the basement at Lot 3-30 on South Browneil
Road restrict construction of basements below the water table in VOC-contaminated
groundwater and prevent potable use of groundwater within the region of VOC-contaminated
groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor natural attenuation are also available
447 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 4 The
capital costs would be $55000 and include the initial natural attenuation evaluation and the
implementation of institutional controls OampM costs include groundwater monitoring These are
$9000 per year The present worth analysis yields a total of $163083 for this 30-year
alternative
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0AUJNOFS9^X)10030929wro 4-24 HSI GGOTraDS 1110
MTECl04e 02402
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water and
phytoremediation would be used to intercept TCE-contaminated groundwater
where it discharges to the unnamed brook
In this alternative all components of Alternative 4 would be implemented and
phytoremediation would be implemented in the area where TCE- contaminated groundwater
intersects the unnamed brook to intercept the contaminated groundwater and reduce the amount
of VOCs reaching the brook Phytoremediation of VOCs is still an experimental technology
Several field studies have used hybrid poplars (EPA 2000) to extract TCE- contaminated
groundwater It has been shown that TCE is removed along with groundwater by the trees and
metabolized as well as transpired from the leaves The rate of TCE contaminant removal from
the groundwater and its discharge to air by transpiration varies based on site specific conditions
and season Therefore contaminant or groundwater removal rates are impossible to predict at
this time without field studies Trees may be subject to destruction by natural disasters and pests
Their condition must be monitored and they may require replacement
F O R ALLING INDUSTRIAL PARK MWPJXXSN7532OOOWXINGFS9JraquoIOO30929WPO 4 - 2 5 H S I G G O T r S D S IOC
MITEC 104e 02403
In order for interception ofthe region of contaminated groundwater to be effective the
trees must be planted so that the root zone intercepts the contaminated groundwater Due to the
depth ofthe higher VOC concentrations in most areas ofthe site phytoremediation would be
ineffective in containing expansion ofthe region of contaminated groundwater An exception to
this is the area near the unnamed brook According to the SIR (HSI GeoTrans 2000) VOC-
contaminated groundwater appears to be discharging upward in groundwater into the unnamed
brook Trees planted along the border ofthe brook may help to intercept this contaminated
groundwater before it discharges into the brook
451 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 5 are as follows
Protection of Workers and the Community Normal landscaping hazards would be
associated with installation ofthe trees A HASP would be prepared for the remedial activities
In conformance with OSHA regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative Suitable dust control measures would be implemented during
planting of trees
Time to Achieve Remedial Action Objectives The time required for maximum
interception ofthe contaminated groundwater by the trees would depend on site specific
conditions such as root growth rate and tree survival rate The RAOs for groundwater would be
achieved when monitoring results indicated that VOC concentrations had attenuated and
groundwater standards had been met It is estimated that natural attenuation of contaminant
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
FOR ALLING INDUSTRIAL PARK MWP J X 3 C S N 7 5 3 2 0 0 0 A U J N O F S 9 ^ ) 0 1 0 0 3 0 9 2 9 W P D 4-26 HSI G G O T H S I I S IDC
MITEC 104e 02404
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment This alternative involves only in-situ treatment ofthe groundwater Plant
tissue would be analyzed for the presence of VOCs Plant materials can bio-accumulate metals
present in soil and groundwater If concentrations are high enough dead plant matter may have
to be disposed in an appropriate manner
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area Phytoremediation may
metabolize some ofthe VOCs
Amount of Material Contained or Treated Natural attenuation and phytoremediation
may serve to prevent expansion ofthe region of VOC-contaminated groundwater at the Study
Area Treatment is accomplished with biotransformation ofthe contaminants to environmentally
acceptable compounds
453 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation ofthe region of VOC-contaminated groundwater and
phytoremediation at the Study Area would eventually achieve the ARARs Implementing
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil Road
restrictions on construction of basements below the water table in regions of VOC-contaminated
groundwater and to control the use of groundwater for potable purposes within the region of
VOC-contaminated groundwater would provide protection against the potential for exposure
FOR ALLING INDUSTRIAL PARK MWP_IXXSW532000ALL1NOFS9^)0I0030929WTO 4-27 HSI GCOTraDS IflC
M l T E C l 0 4 e 0240S
Therefore despite the fact that an extended time period may be required to reduce VOC
concentrations to an acceptable level the residual risk associated with this alternative would be
minimal Trees planted near the unnamed brook may serve to intercept contaminated
groundwater before it discharges to this receptor
Adequacy and Reliability of Controls Groundwater monitoring for natural attenuation
institutional controls and interception of contaminated groundwater before it reaches the
unnamed brook would be the main controls of this alternative Sump venting at Lot 3-30 on
South Browneil Road would prevent indoor air impacts at this location and restriction on the
construction of new basements below the water table within the region of VOC-contaminated
groundwater would prevent future indoor air impacts at other locations Control ofthe use of
groundwater for potable purposes within the region of VOC-contaminated groundwater would
minimize potential use of groundwater with VOCs above federal and state drinking water
standards Groundwater monitoring would ensure that natural attenuation of contaminants was
proceeding and provide for periodic assessment ofthe region of VOC-contaminated groundwater
in the Study Area Groundwater and surface water monitoring would also be conducted to
monitor success ofthe phytoremediation in intercepting contaminated groundwater before it
reaches the unnamed brook
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time Trees must be monitored and will be replaced in
the event of destruction by severe weather pests or other reasons
454 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUINOFS9-00I0030929WPD 4-28 HSI GGOTraflS IllC
MITEC 104e 02406
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
Phytoremediation at the edge ofthe unnamed brook would further reduce the VOC
concentrations in groundwater discharging to the brook
455 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
456 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
Ability to Construct the Alternative Installation of this alternative requires
landscaping skills which are readily available
bull Reliability ofthe Technology Ongoing monitoring and evaluation would ensure
that natural attenuation was controlling and remediating the contaminated
groundwater Ongoing monitoring ofthe condition ofthe trees would also be
required to ensure they are continuing to grow and do not need replacement
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^)OM0030929WPD 4-29 HSI GGOTfaDS jflC
MITEC 104e 02407
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation and phytoremediation were not restricting the size ofthe region of
VOC-contaminated groundwater implementation of additional resources would
not be hampered by this alternative
Administrative Feasibility Planting trees and if necessary installing and monitoring
additional wells might require access to private property Additionally property owner
cooperation would be needed to sample and maintain monitoring wells Restrictions would also
be needed to implement institutional controls to continue sump venting in the basement at Lot 3shy
30 on South Browneil Road restrict construction of new basements below the water table in
regions of VOC-contaminated groundwater and prevent potable use of groundwater within the
region of VOC-contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to plant the trees and monitor natural attenuation are also available
457 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 5 The
capital costs would be $80000 and include the initial natural attenuation evaluation the
implementation of institutional controls and installation of a phytoremedial barrier of poplars
OampM costs include groundwater monitoring and maintenance ofthe phytoremedial barrier
These are $11000 per year The present worth analysis yields a total of $209397 for this 30shy
year alternative
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000ALLINOFS9^)0I0030929WPD 4-30 HSI GGOTfaDS IPC
MITEC 104e 02408
r TI Table 41 Cost estimates for remedial alternatives i deg 5 70
8 P
QUANTITY UNITS UNIT C O S T CAPITA L C O S T ANNUAL
OampM C O S T
5 n Alternative I No Action 8 O a Q
na na $0 $0 $0 a sect
Total $0 $0
Alternative 2 Monitoring Institutional Controls and Hydraulic Containment
1) Implement Institutional Controls 32 properties $10000 $32000
2) Groundwater Monitoring $9000
3) Pumping System
Option 1 Source Containment
Extraction wellspiping $50000 $15000
Electrical distributioncontrol $25000 $8000
Construction oversight $25000
Groundwater treatment system $75000 $45000
Total Option 1 $207000 $77000
Option 2 region of contaminated
groundwater Containment
Extraction wellspiping $175000 $35000
w Electrical distributioncontrol $50000 $20000
O
o H mO Construction oversight $125000
o n gt Groundwater treatment system $350000 $75000
o z 0) Tolal Option 2 $732000 $139000
i deg QUANTITY UNITS UNI T C O S T
5 so
Alternative 3 Monitoring Institutional Controls and Permeable Barrier
m t - 1) Implement Institutional Controls 32 properties $10000
9 O 2) Groundwater Monitoring
| o 3) Permeable Harrier
Option I Source Containment
Barrier installation 1200 feel $450
Total Option 1
Option 2 region of contaminated
groundwater Containment
Barrier Installation 2200 feet $450
w Total Option 2 NJ
Alternative 4 Monitoring Institutional Controls and Natural Gradient Flushing
1) Implement Institutional Controls 32 properties $10000
2) Groundwater Monitoring
3) Natural Attenuation Evaluation
Total
Alternative 5 Monitoring Institutional Controls Natural Gradient Flushing and Phytoremediation
1) Implement Institutional Controls 32 properties $10000 X (A 2) Groundwater Monitoring
reg 3
o m O H
3) Natural Attenuation Evaluation
4) Phytoremediation
gt z Total (A
Notes na = not applicable
CAPITAL C O S T
$32000
$540000
$572000
$990000
$1022000
$32000
$23000
$55000
$32000
$23000
$25000
$80000
ANNUAL
OampM C O S T
$9000
$55000
$64000 1
$103000
$112000
$9000
$9000
$9000
$2000
$11000
MODEL CALCULATED GROUNDWATER CONTOUR IN FEET ABOVE MEAN SEA LEVEL
APPROXIMATE PROPERTY BOUNDARY
M6-2 raquo EXISTING MONITORING WELL
CP-6 bull EXISTING SOIL BORING
M 8 - 2 raquo MONITORING WELL (RESAMPLED)
bull SMALL DIAMETER BORING - BELOW CLAY
bull BEDROCK MONITORING WELL
A S I - 2 I H S I GEOTRANS WELL CLUSTER LOCATION
U-TRIB-8a SURFACE WATER SAMPLING LOCATION R S - U
a PASSIVE SAMPLER LOCATION
T2-2 PROFILE SAMPLE LOCA1ION (JOHNSON COMPANY 1999)
WELL DESTROYED
TEF Concentrat ions ( u g A l
1000 - 10000
iry IOOOO - 20000
bull 20000 + NOTES AREA WHERE TCE CONCENTRATION IS
M l LOCATIONS APPROXIMATE INTERPOLATED THERE IS NO TCE
BASE PUN DEVELOPED FROM DATA FROM THESE AREAS
1 TOWN OF WUUSION PARCEL BOUNOART MAP (SHIPPED 121597) PROVIDED ST (VS (BURUNCTON VT) IN DXF FORMAT
2 PLAN DEVELOPED BT HEINDEL AND NOTES (BURUNCTON VT) FOR THE BATES PROPER1Y 1NVESIBAT10N AND PROVIDED TO THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION HASTE MANAGEMENT DIVISION 1997
3 ORTHOPHOTO SHEET 100216 VERMONT STATE MAPPING PROJECT 1988
4 TORN OF WIUJSTON ASSESSORS MAP 1997
5 VARIOUS SITE PUVQ CN RLE WITH THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION WASTE HMUGElENr OOVBON
6 DM FROM JOHNSON DD REPORT UNTIED GROUNDWXIER IHVESI1CAH0M ALLWC INDUSTRIAL PARK DATED 7 W FDR THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Modeled Site - Existing Conditions copy H
pound n Williston Vermont o CHECKED MS HSI
DRAFTED RMK GEOTRANS FU fa-Site-mod-ECdwg 4 - 1 A TITIA T t n HBVAIT
DATE 10600
5 COMPARATIVE EVALUATION OF ALTERNATIVES
The purpose of this section is to compare the remedial alternatives on the basis ofthe
evaluation criteria developed and discussed in Section 4 and provide a recommended alternative
These criteria include overall protection of human health and the environment short-term
effectiveness reduction of toxicity mobility or volume long-term effectiveness and
permanence compliance with ARARs implementability and cost
The comparative analysis is conducted to highlight significant differences between
identified alternatives All alternatives for the Study Area groundwater except the no-action
alternative include the following
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater and
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
The no-action alternative is not included in the comparison provided in the following
sections since it would not meet the RAOs All four ofthe remaining alternatives would meet
the RAOs stated in Section 32
51 SHORT-TERM EFFECTIVENESS
Protection of Workers and the Community Groundwater would be monitored under all
scenarios to look for any changes in VOC concentration which might result in increased risk
The containment options in Alternatives 2 3 and 5 would be more protective ofthe community
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320MAUINOFSWWI0030929WPD 5 - 1 HSI GSOTrSflS IflC
MITEC 104e 02415
if the region of VOC-contaminated groundwater were shown to be expanding and presenting
increased risk However in the event that the region of VOC-contaminated groundwater is not
expanding Alternative 4 would be equally protective Under all options a HASP would be
prepared and in conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Alternatives 2 3 and 5 would involve normal construction hazards during
installation of pumping wells piping trenches treatment enclosures permeable reactive barrier
trenches or planting of trees In addition under Alternative 5 release of VOCs to air through
transpiration may need to be measured to prevent creation of a new exposure pathway and health
risk through air
Environmental Impacts Minor additional impacts may occur during installation of
Alternatives 2 3 and 5 due to dust and sediment production Groundwater would need to be
treated to regulatory discharge limits before discharge under Alternative 2 and treatment may be
temporarily hampered in the event of treatment system mechanical failure Because ofthe
experimental nature of phytoremediation greater uncertainty exists that the trees will be effective
in acting as a barrier to expansion ofthe region of contaminated groundwater to the unnamed
brook under Alternative 5 If it is shown that expansion ofthe region of contaminated
groundwater toward the unnamed brook poses a future health risk additional measures may
become necessary to contain the contaminated groundwater
Time to Achieve Remedial Action Objectives None ofthe alternatives has an appreciably
shorter time frame than the others in reducing groundwater concentrations to VT Groundwater
Enforcement Standards and VT Water Quality Criteria This is because while Alternatives 2 3
and 5 rely on engineered remedies to contain the region of contaminated groundwater residual
TCE DNAPL and geologic heterogenieties will cause the contaminant source to persist for an
extended time As discussed in Section 34 active DNAPL removal alternatives were removed
during the preliminary screening DNAPL has never been directly observed at the Study Area
and is assumed to be present based on dissolved concentrations of TCE DNAPL distribution is
FOR ALLING INDUSTRIAL PARK MWP_DOCSW753200OALLINOFS9-00M0O30929wPD 5-2 HSI GGOTr3nS IflC
MITEC 104e 02416
expected to occur heterogeneously at residual saturation and it is infeasible to locate the DNAPL
to treat it directly Because of this each ofthe remedies is expected to exceed the two-year time
frame for short term effectiveness
52 R E D U C T I O N O F T O X I C I T Y M O B I L I T Y O R V O L U M E T H R O U G H
T R E A T M E N T
Treatment All ofthe proposed alternatives would treat the residual DNAPL source of
contamination through dissolution and natural gradient flushing While Alternatives 2 3 and 5
are intended primarily for containment and not groundwater restoration these alternatives would
actively treat some concentrations in groundwater
Reduction in Toxicity Mobility or Volume The containment Alternatives 2 3 and 5
may result in decreased mobility ofthe region of contaminated groundwater However
groundwater monitoring may show that the region of contaminated groundwater is not
expanding under existing conditions If this were the case containment would not result in any
additional decrease in size ofthe region of VOC-contaminated groundwater
Since Alternatives 2 3 and 5 treat concentrations in groundwater without treating the
residual DNAPL source and the amount of contaminants that can be removed from groundwater
by these methods would likely equal the amount added by continued dissolution ofthe DNAPL
sources alternatives 2 3 and 5 would not result in a greater reduction in the total volume of
contaminant than Alternative 4
Amount of Material Contained or Treated As described above the amount of material
contained under Alternatives 2 3 and 5 would not be any greater than under Alternative 4 unless
the size ofthe region of VOC-contaminated groundwater is not presently contained by natural
attenuation If natural attenuation is currently controlling the size ofthe region of VOC-
contaminated groundwater then the amount of contaminants being removed by natural processes
equals the amount added by dissolution of residual DNAPL In this case intercepting and
removing contaminants from the groundwater using one ofthe containment alternatives will not
result in a significant increase in the amount of contaminant treated
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000ALUNOFS9-OOUM30929WPD 5-3 HSI GGOTrdHS jflC
MITEC 104e 02417
53 LONG-TERM EFFECTIVENESS
Residual Risk Implementing institutional controls to maintain the sump venting at Lot 3shy
30 on South Browneil Road to restrict construction of buildings with basements below the water
table within the region of VOC-contaminated groundwater and to control the use of groundwater
for potable purposes within the region of VOC-contaminated groundwater would provide
protection against the potential for exposure to existing concentrations in groundwater
Therefore despite the fact that some ofthe remedial alternatives may be required to operate for
an extended time the residual risk associated with any ofthe alternatives would be minimal
Adequacy and Reliability of Controls Alternative 5 has the least reliable controls
because ofthe difficulty in predicting the effectiveness of phytoremediation The second least
reliable alternative would be Alternative 2 because of its reliance on mechanical equipment to
maintain containment and to meet discharge standards
Permanence of Remedy All ofthe proposed alternatives would rely on permanent
destruction of contaminants through natural attenuation over time If one ofthe containment
technologies are required maintenance and periodic replacement would be necessary to ensure
containment was maintained until expansion ofthe region of VOC-contaminated groundwater
was no longer a threat This maintenance would be straight-forward and easy to continue for any
of the containment alternatives
54 COMPLIANCE WITH ARARs
All ofthe alternatives would eventually reduce contaminant concentrations within the
current region of contaminated groundwater to below VT Groundwater Enforcement Standards
and VT Water Quality Criteria
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Each ofthe alternatives would rely on groundwater monitoring and institutional controls
on venting basement sumps at Lot 3-30 on South Browneil Road restrictions on the construction
of new basements below the water table within the region of VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWPJX3CSN7S3UOOOAUJNGFS9-OOUM30929wro 5-4 HSI GOTr3nS IflC
MITEC 104e 02418
and potable use of groundwater from within the region of VOC-contaminated groundwater to
maintain conditions protective of human health and the environment If monitoring shows that
natural attenuation is not restricting the size ofthe region of VOC-contaminated groundwater
then one ofthe containment alternatives would be more protective than Alternative 4
56 IMPLEMENTABILITY
The most easily implemented alternativewould be Alternative 4 as it would not require
any installation but only groundwater monitoring to gauge the progress of natural attenuation
Alternative 5 requires all the components of Alternative 4 and adds trees along the unnamed
brook Alternatives 2 and 3 are the most difficult to implement as they require disruptive and
invasive installation techniques However the necessary equipment materials workers and
specialists required to implement all the alternatives are available
57 COSTS
The present worth costs range form a low of $163083 for Alternative 4 to a high of
$2287474 for the containment option of Alternative 3 These present worth costs were based on
a 30-year service period and an annual discount rate of seven percent
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALLINOFS9-OOM0030929WPD 5-5 HSI GGOTfaDS IflC
MITEC 104e 02419
6 PREFERRED REMEDY
61 PREFERRED REMEDY
Alternatives 2 34 and 5 are all protective of human health and the environment and rely
on the following technologies
bull groundwater monitoring to evaluate spatial and temporal trends in VOC
concentration
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil
Road
restrictions on the construction of new buildings within the region of VOC-
contaminated groundwater to prevent unacceptable concentrations of volatile
compounds in indoor air and
institutional controls to restrict the use of groundwater for potable purposes within
the region of VOC-contaminated groundwater
All ofthe alternatives rely on dissolution and natural gradient flushing to treat the
residual DNAPL source of groundwater contamination Therefore none ofthe alternatives has
an appreciably shorter time frame than the others in reducing groundwater concentrations to VT
Groundwater Enforcement Standards and VT Water Quality Criteria
Alternative 4 includes remediation by natural attenuation There is no active containment
technology associated with Alternative 4 As such it is simpler less costly and easier to
implement than Alternatives 2 3 and 5 which include some form of active containment ofthe
region of VOC-contaminated groundwater Containment could become necessary under
Alternative 4 if future groundwater quality monitoring indicates the region of VOC-contaminated
groundwater is impacting a sensitive receptor or is expanding in size and not contained by natural
attenuation The SIR (HSI GeoTrans 2000) risk assessment (Menzie Cura 2000a and 2000b)
showed that under current conditions groundwater was not impacting any receptors to a degree
FOR ALLING INDUSTRIAL PARK MWPJXXrSN7532000ALUNcFS9-OOU0030929WO 6 - 1 HSI GSOTraflS jflC
MITEC 104e 02420
that would represent a human health risk or risk to the environment Therefore containment is
not necessary to protect any sensitive receptors currently being impacted by the region of
contaminated groundwater Continued groundwater monitoring is required to demonstrate
whether the region of VOC-contaminated groundwater is stable in size or expanding
Alternative 4 has been selected as the preferred remedy On-going monitoring ofthe
effectiveness of natural attenuation in containing and remediating the region of VOC-
contaminated groundwater is part ofthe remedy Further details on this proposed monitoring are
provided in Section 62 If monitoring shows that size ofthe VOC-contaminated region is not
contained by natural attenuation then one ofthe other technologies could be used to supplement
Alternative 4 based on the nature ofthe expansion ofthe region of contaminated groundwater
If monitoring data indicates that VOC concentrations in the groundwater discharging to the
unnamed brook have increased and pose an unacceptable risk to human health and the
environment then phytoremediation could be considered in this location Phytoremediation
would be less costly than installation of a permeable reactive barrier or active groundwater
extraction system Phytoremediation would be ineffective in containing expansion ofthe region
of contaminated groundwater in the rest ofthe Study Area however because contaminated
groundwater is further below ground surface in these regions and phytoremediation is limited by
the depth ofthe roots ofthe selected plant If monitoring data indicates that the southwestern
portion ofthe region of VOC-contaminated groundwater is expanding then Alternative 4 could
be supplemented with extraction wells or a PRB for hydraulic containment
62 MONITORING PROGRAM
In its guidance document Use of Monitored Natural Attenuation at Superfund RCRA
Corrective Action and Underground Storage Tank Sites (EPA 1999) EPA states that long-term
performance monitoring will be a fundamental component of any remedy which relies on
monitored natural attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000 A1XINOFS9-00 I0030929 WPO 6-2 HSI GSOTrSDS IMC
MITEC 104e 02421
The SIR (HSI GeoTrans 2000) concluded that there were not sufficient temporal data to
determine whether the region of VOC-contaminated groundwater was stable in size or
expanding Continued monitoring for the compounds of concern will be necessary to confirm
that the region of VOC-contaminated groundwater is not expanding Table 6-1 identifies
locations which are proposed to be monitored annually to evaluate spatial and temporal trends in
VOC concentration These locations are shown in Figure 6-1
There are several mechanisms by which natural attenuation occurs These include
dilution of contaminant concentrations sorption ofthe contaminant onto the soil matrix and
biodegradation ofthe contaminant to a less toxic form Further study is necessary to determine
the contribution of each of these mechanisms to overall attenuation ofthe area of VOC
contamination
Evidence of biodegradation can be obtained by collecting three types of data of increasing
complexity (National Research Council 1993)
bull documentation of contaminant loss or transformation in the field
bull the presence of electron donors and acceptors andor alteration of groundwater
chemistry consistent with intrinsic biodegradation processes and
microcosm studies which provide direct microbiological evidence that indigenous
bacteria are capable of mediating the contaminant transformations observed
Microcosm studies are typically not employed unless the contaminant is unique or the
transformation which is being observed is not well documented in the literature For the
transformations anticipated in the Study Area numerous laboratory and field studies have
established that naturally-occurring bacteria are capable of mediating the contaminant
transformations of contaminants of concern For that reason microcosm studies will not be
performed as part of this study
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^)OM0030929 WPO 6-3 HSI GSOTrSHS jflC
MITEC 104e 02422
Of particular concern to the determination of biodegradation is the delineation of aerobic
and anaerobic zones within the contaminant area because these zones dictate the types of
biological degradation that would be expected to occur Oxygen is the primary electron acceptor
during aerobic oxidation Anaerobic processes including denitrification iron-reduction sulfate-
reduction and methanogenesis occur in the absence of oxygen and use nitrate iron (III) sulfate
and carbon dioxide respectively as primary electron acceptors Reductive dehalogenation of
TCE has been observed under iron-reducing sulfate-reducing and methanogenic conditions
although very low redox (ie methanogenic) conditions may be necessary for production of
ethene and ethane
Further sampling and analysis of selected parameters in groundwater will be conducted to
assess the potential for biodegradation in accordance with EPAs Technical Protocol for
Evaluating Natural Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) The
twelve sampling locations shown in Table 6-1 used to monitor ofthe area of VOC contamination
will also be sampled for parameters used to evaluate biodegradation The parameters include
compounds of concern and compounds which are degradation products ofthe compounds of
concern shown in Table 6-2 Table 6-3 lists parameters chosen to evaluate the presence of
electron donors and a groundwater chemical environment conducive to biologic reductive
dechlorination These parameters will be sampled once unless evaluation ofthe data indicates
that further sampling would be beneficial to calculate a rate of attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000ALUNCFS9JraquoM0030929 WPD 6-4 HSI GSOTfaHS IDC
MITEC 104e 02423
Table 6-1 Sampling locations
LOCATION
ID
ASI-32D2
RB-1
ASI-26D2
ASI-I6D2
ASI-13D2
ASI-23D2
ASI-18D2
ASI-12D2
ASI-01D2
ASI-09D2
U-TRIB-5
SW-I
Notes BGS =
SCREENED
INTERVAL
DEPTH BGS
35-40
35-40
35-40
30-35
31-36
25-30
32-37
35-40
31-36
31-36
surface
surface
Below Ground Surface
RATIONALE
Upgradient of region of highest VOC concentrations
Closest to lot 19-11 former lagoon and septic leach field source areas
Within area of highest concentrations
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient ofthe region of VOC concentrations in the southwest direction
Downgradient of source area within region of VOC concentrations in southeast direction
Downgradient of source area within region of VOC concentrations in southeast direction
At downgradient edge of region of VOC concentrations in southeast direction
Stream upgradient of VOC discharge from groundwater
Stream at location of VOC discharge from groundwater
(
FOR ALLING INDUSTRIAL PARK MWP DOCSN7532000ALUNCFS9^X)VI0030929WPO 6-5 HSI GeoTrans inc
MITEC 104e 02424
Table 6-2 VOC analytes
PARAMETER
TCE
PCE
11-DCE
cis 12-DCE
trans 12-DCE
Vinyl Chloride
Benzene
Toluene
Ethylbenzene
Xylenes
ANALYTICAL METHOD
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
8260A
8260A
8260A
8260A
RATIONALE |
Contaminant of Concern
Contaminant of Concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
Notes SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical
Methods SW-846 US EPA 3ri edition 1986
TCE = Trichloroethene
PCE = Tetrachloroethene
11-DCE = 11-Dichloroethene
cis 12-DCE = cis 12-Dichloroethene
trans 12-DCE = trans 1 2-Dichloroethene
FOR ALLING INDUSTRIAL PARK MAWP DOCSN75320laquoMLUNOFS9^XM0030929WPO 6-6 HSI GeoTrans inc
MITEC 104e 02425
Table 6-3 Parameters to evaluate biodegradation
PARAMETER ANALYTICAL METHOD RATIONALE
Field Parameters
Alkalinity as CaCO Hach Alkalinity Test Kit Model ALP Positive correlation between microbial activity and
MG-L alkalinity Measures the buffering capability of
groundwater
Total Ferrous Iron Hach Method 8146 May indicate anerobic degradation
Dissolved Hydrogen Reducing Gas Detector Predicts possibility for reductive dechlorination
Dissolved Oxygen Direct Meter Reading Indicates probability of aerobic vs aerobic
degradation
PH Direct Meter Reading Aerobic and anaerobic biological processes are pH
sensitive
Redox potential (Eh) A2580B An indicator ofthe relative tendency of a solution
to accept or transfer electrons
Specific Conductivity Direct Meter Reading Used to determine when purging of a well for
sampling is complete
Temperature Direct Meter Reading Affects the metabolic activity of bacteria and the
solubility of dissolved gasses
Laboratory Analyses
Dissolved Organic Carbon SW 9060 Carbon and energy source which can drive
dechlorination
Nitrate-N IC Method E300 At higher concentrations may compete with
reductive pathway
Total Manganese EPA 2007 or 2009 To determine if anaerobic biological activity is
solubilizing Mn for the aquifer matrix
Chloride SW 9250 Can be used as a conservative tracer to estimate
biodegredation rates
Sulfate IC Method E300 May be used as an electron acceptor for
biodegradation after dissolved oxygen and nitrate
are depleted
Sulfide IC Method E300 Indicates if reductive pathway is possible
Ethane SW 3810 Modified Daughter product of Ethene
Ethene SW 3810 Modified Daughter product of Vinyl Chloride
Methane SW 3810 Modified Ultimate reductive daughter product
Notes Rationales taken from USEPA 1998
Hach refers to Hach Company Catalogue
A refers to Standard Methods for the Examination of Water and (fostewater 18 edition 1992
E refers to Methods for Chemical Analysis of Water and Wastes US EPA 1983
SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical Methods SW-846 US EPA 31 edition
1986
FOR ALLING INDUSTRIAL PARK | C I nr A^Twmrmr bullbullltlaquo MWP DOCSN7532000ALLINCFS9-0Ol0030929wro 6-7
MITEC 104e 02426
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REFERENCES
Brinkerd 1996 Site Investigation Ailing Industrial Park Williston Vermont April to
September 1996 October 1996
Fitts C R 1997 TWODAN documentation prepared by Dr Charles Fitts Scarborough Maine
Griffin 1995 Monitor Well Log (MW-4) and Analytical Data Bove-Fagan Ice Cream
Distribution Investigation Williston VT Griffin International Inc
HSI GeoTrans Inc 2000 Site Investigation Report June 15 2000
Johnson 1999 Limited Groundwater Investigation N753 July 6 1999
Menzie Cura 2000a Screening Level Risk Characterization April 2000
Menzie Cura 2000b Addendum to Screening Level Risk Characterization June 1 2000
NRC 1993 National Research Council Committee on Bioremediation In Situ Bioremediation
When Does it Work Washington DC National Academy Press 1993
TRC 1993 Site Inspection-Ailing Industrial Park Williston Vermont VTD982748477 Final
Report
US EPA 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies
Under CERCLA OSWER Directive 93553-01
U S EPA 1992 Estimating Potential for Occurrence of DNAPL at Superfund Sites OSWER
Number 93554-07FS 9p
FOR ALLING INDUSTRIAL PARK MWP_DOCSW75JV20(XKALUNOFS9-0(AI0030929WPD 7 - 1 HSI GeOTTSHS irtC
MITEC 104e 02428
US EPA 1993 Guidance for Evaluating the Technical Impractibility of Groundwater
Restoration EPA540-R-93-080
US EPA 1998 Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents
in Ground Water EPA600R-9812~8
US EPA 1999 Use of Monitored Natural Attenuation at Superfund RCRA Corrective Action
and Underground Storage Tank Sites EPA Directive 92004-17P
US EPA 2000 Introduction to Phytoremediation EPA600R-99107
VTDEC 1996 Site Investigation Guidance August 1996
VTDEC 1997 Chapter 12 Groundwater Protection Rule and Strategy October 1997
VTDEC 2000 Vermont Water Quality Standards March 2000
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(AAUJNGFS9^)OM0030929WPD 7-2 HSI GSOTfanS tC
MITEC I04e 02429
APPENDIX A
TWODAN INPUT FILES
FOR ALUNG INDUSTRIAL PARK MWP_DOCSVN7S3200(AALUNOFS9-0(AI0030929WPO HSi GfiOTfanS WC
MITEC 104e 02430
i - i i a a o U 0 t A X H i d t l Z 018J UaiUEAJJLKATia Htj v j pound
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MITEC 104e 02431
15
6 Lancaster County Road HSI Harvard Massachusetts
GEOTRANS 01451 A TETRA TECH COMPANY 97^772-7557 FAX 978-772-6183
R E C E i ^ D PNN753-001
CUTLER A8TANPIELD Campltf December 11997
Mr Michael Smith Vermont Department of Environmental Conservation Waste Management Division 103 South Main Street Waterbury VT 05671-0404
Subject Proposed Surface Water Sampling MITEC Site Williston VT
Dear Michael
This letter describes the proposed surface water sampling at the MITEC site that we discussed during our meeting of November 201997 Our intention is to complete this work as soon as possible to avoid the complications of colder weather and possible freezing ofthe stream My understanding is that you are prepared to review and approve this plan fairly quickly and also to assist us with obtaining property access and appropriate maps to locate these sampling sites We appreciate this help In future we anticipate that the constraints of weather will not require such an expedited field mobilization process and that we will all have more time to prepare
Purpose and Extent of Sampling
The purpose ofthe surface water sampling is to further assess impacts to the unnamed tributary and to make preliminary inferences regarding the extent ofthe TCE plume currently migrating to the southeast across the Ailing Industrial Park by measuring the effects of its discharge to the stream To this end sampling locations have been chosen to 1) provide better spatial resolution in the area east of Commerce Street toward its southern end (SW-1 SW-2 SW-3 and S W-5) 2) assess the quality of surface water contributed by other tributaries (SW-4 SW-6) and 3) make preliminary estimates ofthe downgradient extent of impacts (SW-7 and SW-8) Samples from previously established sampling locations UTrib-6 7 8 1014 and 18 will also be obtained A total of 14 samples will be collected The proposed sampling locations
L-W7jni20iiooonl
MITEC 104e 02432
Michael Smith 2 December 11997
are indicated on the attached maps which depict the site at two different scales The first is a site map taken from the Binkerd report and shows the previous sampling locations east of Commerce Street as well as proposed new locations SW-1 SW-2 and SW-3 The second map shows the site and the surrounding area including the more downstream locations
Methods
At each proposed location a number of water quality indicators will be measured including temperature pH redox potential dissolved oxygen and conductivity Samples for volatile organic compound (VOC) analysis will be obtained in triplicate using a stainless steel sampling container samples will be transferred immediately to 40 mL glass vials with teflon septa and preserved with hydrochloric acid Each sample will be submitted to a local analytical laboratory for a screening level analysis of VOCs Three selected samples will also be analyzed using EPA Method 8260 The appropriate level of documentation will be generated for these samples such that laboratory analytical results can be validated to EPA Region 1 level Tier II This will require the collection and analysis of a duplicate sample a trip blank a field blank and matrix spikematrix spike duplicate samples
Sincerely
f i t mdash Peter ZeebPhD Senior Hydrogeologist
cc Sandy Feldman Sheila Jones
PZmm
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HSI GEOTRANS
LEGEND O Honrtorog Veil
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Figure 11 Station location map O Surface Water
Qfor monitoring wells borings and surface water MITEC 104e
02434
HD BINKERD ENVIRONMENTAL
HSI bull bull
GEOTRANS if prsTAOC
6 Cancaster County Road
A TETRA TECH COMPANY
Harvard Massachusetts 01451 faL32 HMETER 3 4 r t
Sheila Jones Esq Cutler and Stanfield 700 Fourteenth Street NW Washington DC 200052010
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Harvard Massachusetts 01451 GEOTRANS
A T E T R A T E C H C O M P A N Y 978-772-7557 FAX 978-772-6183
PN N753-002
May 111999 RECEIVED
MAY t 3 1999 Mr Michael Smith
CUTLER ampSTANrlc-uAgency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Dear Mike
Based on the site walkover and well inventory ofthe existing monitoring well network completed on April 201999 HSI GeoTrans determined that several monitoring wells proposed for sampling and monitoring in the Work Plan are not accessible or are damaged or missing Outlined below are the actions we will undertake to resolve the outstanding issues with the monitoring well network
As ofthe date of this letter access to the Bates well network has not been obtained The Work Plan identified eleven off property well clusters installed by the Bates and two wells installed by the State on the Bates property to be included in the sampling and monitoring activities for the Site Investigation (BW-2 BW-5 BW-7 BW-8 BW-9 BW-11 BW-12 BWshy13 BW-17 BW-18 BW-19) Ten ofthe off property clusters were included in the sampling plan and all eleven were included in the site water level round The wells installed by the State on the Bates property were included in the both sampling and water level rounds Replacement of eight ofthe well clusters slated for groundwater sampling is recommended (BW-5 BW-8 BW-9 BWshy12 BW-13 BW-17 BW-18 BW-19) The remaining Bates wells do not require replacement in order to achieve the goals ofthe Site Investigation Note that two ofthe original well clusters in the Work Plan BW-17 and BW-18 have been destroyed and would require replacement even if access is granted by Bates In addition HSI GeoTrans well clusters had already been proposed adjacent to BW-2 BW-7 and BW-11 and will provide the required data at these locations
It is our understanding that the two monitoring wells installed by the State on the Bates property JB-1 and JB-2 are accessible to the State for sampling and water level monitoring and that the State will sample and monitor these wells to fulfill the goals ofthe Site Investigation IF this is not the case please let me know at your earliest convenience
M WP DOCS NT^VWMiSimbW wpd
MITEC 104e 02438
Mr Michael Smith 2 May 11 1999
Several ofthe remaining wells (BF-1 BF-3 NO-2 and OE-1) were observed to be damaged during the inspection We propose to repair the wells which have been damaged The repairs will involve installation of protective casing or road boxes re-development and reshysurveying of the new measuring points The other wells are missing and presumed destroyed (ARC-2 ARC-3 BF-2 BM-2 MB-1 PO-SOUTH and RB-1) We believe that only monitoring wells MB-1 and MB-1 A require replacement The remaining wells that could not be located during the site inspection do not require replacement in order to achieve the goals ofthe Site Investigation
Based on our telephone conference on May 10 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MWgt_DOCSN753l9Wlaquo310l600raquopd M l 1 XA ~r
02439
HSI GEOTRANS
Mr Michael Smith 3 May 11 1999
bcc Sheila Jones
snwp_DocjN7sni9wcmoi6i)iraquoplti TVflTEC 1046
02440
HSI GEOTRANS
X_l ^ T 6 Lancaster Countv Road
Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-11 i 5
PN N753-002
June 25 1999
Mr Michael Smith Agency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Work Plan Modifications Ailing Industrial Park Site Williston VT
Dear Mike
This letter documents changes to the work plan for the Ailing Industrial Park Site in accordance with a telephone conference between you myself and Peter Zeeb On the results of the Site Investigation to date as well as additional data collection by the DEC we agreed that several revisions to the work plan are warranted The revisions for the work plan include the location and method of installation for the bedrock monitoring wells and the sampling of shallow monitoring wells recently installed Outlined below are the revisions to the specific tasks that we will undertake
Re-location of Bedrock Monitoring Weil BR-1
The DECs Source Area investigative work in the original location of BR-1 identified high levels (100 mgL) of VOCs present at or near the silt clay interface DEC believes that drilling through the clay layer in this location creates an unacceptable risk ofthe migration of contaminants into the underlying units HSI GeoTrans will relocate the bedrock well BR-1 adjacent to ASI-16 as located on the attached site plan
Bedrock Well Installation Method
Geophysical work at the site has refined our estimation of the depth to bedrock Depth to bedrock was initially anticipated to be greater than 150 feet below ground surface We currently anticipate bedrock at 100 to 140 feet below ground surface The shallower depth to Bedrock will
M AWPDOCStfnSIMnWUJIIW mft
MITEC 104e 02441
Mr Michael Smith 2 June 25 1999
enable us to reduce the size ofthe pilot hole needed for the well installation At locations BR-1 and BR-2 drillers will advance and set 4 in casing several feet into the clay unit and chop and wash the annulus ofthe casing All cuttings and wash water will be contained for proper disposal The casing will be refilled with potable water and the hole will be advanced with a 3 in roller bit When telescoping becomes necessary to prevent caving 3 in casing will be installed The 3 in casing will be advanced to the bedrock surface and seated The coring of bedrock will follow the original work plan specifications
Shallow Monitoring Well Sampling
The field GC water quality data obtained during small diameter installation at the site has demonstrated that contaminant concentrations in the upper portion ofthe aquifer to be low (lt 10 MgL) or non-detect in most locations This has led to the revision of our sampling plan Select shallow wells will be sampled to confirm the field GC data If these data are confirmed the low level and none detect shallow wells will not be sampled The shallow wells to be used for confirmation sampling are listed below
ASI-01 ASI-02 ASI-03 ASI-05 ASI-08 ASI-10 ASM 2 ASI-08
Based on our telephone conference on June 24 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MXTECl04e 02442
HSI GEOTRANS
Mr Michael Smith 3 June 25 1999
bcc Sheila Jones
MITEC I04e
02443
HSI GEOTRANS
1 0 T 2 shyCylty
T-TCT 6 Lancaster County Road _ _ _ Harvard Massachusetts
GEOTRANS OH 5 1
A TETRA TECH COMPANY 978-772-7557 FAX 978-772-6183
PN 753-010
July 9 1999
Mr Michael Smith Agency of Natural Resources Vermont Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Bedrock Monitoring Well Installation Ailing Industrial Park Site Williston VT
Dear Michael
On July 8 we became aware that a drill casing was advanced through the sand clay and till strata at the Ailing Industrial Park (site) without being sealed at the sandclay interface Although for the reasons described below we do not believe any vertical migration of contaminates occurred this method of drilling is contrary to the work plan for the site Therefore we are notifying you of this incident
On June 4 shallow direct push monitoring wells were installed at location ASI-06 where a deeper bedrock monitoring well is planned Groundwater quality profiling data from this location is provided on the attached boring log TCE is present in groundwater here at concentrations as high as 2270 ugl at 31 - 36 ft below ground surface (bgs) decreasing to 262 ugL at 41 - 44 ft bgs A soil boring (D-2) was advanced at this location on June 22 Field screening data from soil samples obtained in this boring are also provided on the attached log As apparent from the log fine to medium sand occurs to a depth of approximately 15 ft at this location grading to silt at depth A clay layer is encountered at 40 ft bgs Glacial till is present from 57 to 100 ft bgs where the bedrock surface is located Prior to drilling through the clay and glacial till a direct push well screen was advanced through the clay and into the till to a depth of 58 bgs and no groundwater recharge to the well screen occurred at any of five sampling depths
MWP_DOCSN753 199M7M1600 wpd
MITEC 104e 02444
Mr Michael Smith 2 July 9 1999
Drilling of bedrock monitoring well BR-2 began on June 29 Four inch casing was advanced to a depth of 44 ft and sealed within the clay layer Three inch casing was then advanced through the till layer to the bedrock surface During seating ofthe casing in the bedrock the casing was damaged and was subsequently withdrawn from the borehole
On July 7 a different drill rig was used to continue drilling the same location In accordance with both the drillers proposal to HSI GeoTrans and the work plan for the site investigation the driller was to seat a casing in the clay establish a seal and drill through the clay and till with smaller casing prior to coring bedrock Instead the drilling contractor withdrew the previously installed four inch casing without grouting it changed the drive shoe on the casing to a spin shoe and advanced the four inch casing directly to the bedrock surface Upon arrival at the site to log the coring of bedrock on July 8 HSI GeoTrans ascertained that the borehole had not been sealed at the clay surface prior to drilling deeper as was specified HSI GeoTrans then instructed the drilling contractor to immediately remove the casing and to seal the borehole with grout in the process
It is our intention to have a new drilling contractor complete the installation of BR-2 at an adjacent location in a manner that limits the potential for introducing contaminated unconsolidated deposits groundwater to the bedrock as specified in the work plan for this site investigation Within one week of completing the installation of BR-2 groundwater quality data collected from BR-2 will be evaluated with respect to the potential for contaminant migration along the unsealed borehole that existed at this location for approximately 24 hours As the casing was advanced by spinning providing a relatively good seal between the casing wall and the formation we do not anticipate that vertical migration along the casing was significant
If you have any questions regarding this letter please contact me at (978) 772-7557
Sincerely yours
Peter Zeeb PhD Senior Hydrogeologist
PZcas
MWP OOCSVN7S3M999070ll600wpri
MITEC 104e 02445
HSI GEOTRANS
1 HSI | 9pound9TPpoundSpound SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
LOCATION Williston VT CASING TYPEDIAMETER None
DRILUNG METHOD Drive and Wash Direct Push SCREEN TYPESLOT None
SAMPLING METHOD ss shelbv GRAVEL PACK TYPE None
GROUND ELEVATION GROUT TYPEQUANTITY Bentonite Portland Slurry
TOP OF CASING DEPTH TO WATER
LOGGED BY NSB GROUND WATER ELEVATION
REMARKS This log compiles the results o the all methods used to comolete the borehole over its entire depth
gtshyci IT UJ t o UJ E t shygt z L oi lti LITHOLOGIC DESCRIPTION 3Q O bdquo a UJ lt a ca sect 1a UJ
o amp UJ _ a 1 Oi i ai o UJ a E 03 5 1 - X X X
cc -S
Moderate olive Brown - Olive Grey m-f SAND w trace fines wet poorty graded
bull bull bull
- 5 shy
J
bull bull
- 1 0 shyD2-SS01 21 13 NO 7 NO 13
A12 7
bull bull
Light olive Brown SILT w trace fine sand wet poorly - 1 5 shy graded
O2-SS02 4 7 11 8
A7
6 7
- 2 0 shy Dark greenish Grey SILT wet poorly graded
O2-SS03 2 0 41 1
WOR WOR l
D2-SS04 2 4 2 X - 2 5 shy4
D2 13 1159
3
1 D2-SS05 2 5 39 v
WOR AWOR WOR - 3 0 shyD2-SS06 4 921 WOR
XWOR WOR
02-SS07 8 2270 1
X1 2 3
Continued Next Page 1 OF 3 02446
HSI GEOTRANS SOIL BORING LOG BR-02 A T E T R A T E C H C O M P A N Y
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
9 gtshyOC
UJ - j a
UJ gt o ^ r-6 LITHOLOGIC DESCRIPTION
ui
CD U UJ S oc =
o o
uj _ Q pound iT O
o
Medium Grey dayey SILT wet poorly graded
D2-SS09 4 S
28 1572
3 6
D2-SS10 WOR 1 18 13
4 6
D2-SS11 3 3 20 NO Medium Grey CLAY wet poorly graded 262
4 5
BR2-SS01 1 2 20 ND Soft Olive Grey CLAY moist laminated coheisive 2 4
BR2-SS02 20 NO
- 5 0 -
BR2-SS03 20 NO - 5 5 -
Dense Light olive Grey sandy GRAVEL w few fines
BR2-SS04 16 19 24
ND
bull60
moist poorly graded
21
Very dense Light olive Grey gravelly SAND w little fines moist well graded angular
BR2-SS05 40 51
13 ND 6 5 shy
60 66
I-7 0 shySO BR2-SS06 11 ND 50 100
5000
MITEC 104e 02447
Continued Next Page PAGE 2 OF 3
HSI GEOTRANS A T E T R A T E C H C O M P A N Y SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
a UJ
Q
05
i i m u
gt ac ui gtO bdquo UJ 3 oc S
o o
0 CO UJ _ Q pound LL C5
LITH0L0GIC DESCRIPTION 9 LU O
BR2-SS07 81 1004
10 NO E 8 0 shy
BR2-SS08 30 59 68
16 ND w8 5 shy
BR2-SS09 1005 NO 9 0 shy
BR2-SS10 89 1944
ND E bull95shy
- 1 0 0 shyND
Limestone
MITEC 104e 02448
PAGE 3 OF 3
Mr Michael Smith 3 July 9 1999
bcc Sheila Jones bcc Jerry Amman
MWPJXXSN753M9MW70J160Owpd
MITEC 104e 02449
6 Lancaster Countv Road HSI Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6 I i 5
PN N753-014
Septembers 1999
Mr Michael Smith Agency of Natural Resource Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in die Site Investigation Ailing Industrial Park Williston IT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and die Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation ore outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste waler lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot IV-11 using small-diameter wells and afield GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
bull perform one day ofwellpoint permeability testing at selected monitoring wells
mwFDocwsiMwwwnoootd MITEC 104e 02450
Mr Michael Smith September 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
M l T ECl04e 02451
U laquo OOCTN791Mtm01IOOOraquofrl
HSI GEOTRANS
HSI GEOTRANS
6 Lancaster County Road Harvard Massachusetts
01451
A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6183
PNN753-014
Septembers 1999 amp y gt
Mr Michael Smith D oJ Agency of Natural Resource Km Jt Department of Environmental Conservation i j f i l Waste Management Division ft y^y( 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park ft Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and the Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation are outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
bull perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste water lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot 19-11 using small-diameter wells and a field GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
MITEC 104e perform one day ofwellpoint permeability testing at selected monitoring wells 02452
000060 MlWP_OOCSN73Iirmraquo01|rngtlaquo|gtl
Mr Michael Smith Septembers 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
MITEC 104e 02453
000061 Mwr_cocS4miinmogtmoltsri
HSI GEOTRANS
T T Q T 6 Lancaster County Road ^ Harvard Massachusetts
GEOTRANS laquolaquo A TETRA TECH-COMPANY 978-772-7557 FAX 978-772-6183
PNN753-014
October 151999
Mr Michael Smith vZ Agency of Natural Resource J Department of Environmental Conservation Waste Management Division I 103 South Main StreetWest Building j Waterbury VT 05671-0404
Re Ailing Industrial Park Source Area Investigation
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants Evaluation of field data has determined the extent ofthe dissolved phase contamination migrating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) HSI GeoTrans will begin a Source Area Investigation on October 181999 to determine the nature and areal extent ofthe suspected contaminant source The investigation will be undertaken to gather the data necessary to complete the Site Investigation Report and the Feasibility Study which was set forth by the Agreement Between Mitec Telecom INC and Vermont Concerning the Ailing Industrial Park (1999) The Source Investigation will focus on the property owned by Beatrice Ailing and former MITEC lease hold (Lot 19-11 Williston plat map) and the area ofthe Ailing Industrial Park which has exhibited elevated contaminant concentrations during Site Investigation activities We are submitting this letter to The Vermont Department of Conservation(VTDEC) as an addendum to the approved Site Investigation Work Plan The addendum Source Investigation Work Plan will outline the tasks and methodologies to be utilized during the investigative work
Jack Guswa and I met with you on September 101999 to present the plans to investigate the suspected source area in the Ailing Industrial Park You agreed with the additional work as presented with the addition of two upgradient wells to be located to the west ofthe suspected source area (Figurel-1 ASI-30 and ASI-31) The VTDEC also agreed during the meeting to arrange access to the property for the Source Area Investigation The VTDEC and HSI GeoTrans were subsequently granted access to the property on September 111999 In addition to the work presented at the meeting it is necessary to preform a 72 hour pump test to characterize the
000054 MwrDOCSW79JimMOUIIOOpd
MITEC 104e 02454
Mr Michael Smith 2 October 151999
hydrologic conditions at the site The additional Source Area Investigation activities to be undertaken are presented below
Site Reconnaissance Ground Penetrating Radar (GPR) Survey Monitoring Well and Soil Boring Installation Low Flow Groundwater Sampling Hydraulic Characterization
The additional field work attributed to the Source Area Investigation will follow the standard operating procedures presented in the approved Site Investigation Work Plan (HSI GeoTrans 1999) The locations ofthe proposed well cluster installations and GPR survey are presented on Figure 1-1 The well cluster locations presented in Figure 1-1 were finalized during the September meeting between HSI GeoTrans and the VTDEC The GPR survey and hydraulic characterization tasks are presented below The Source Area Investigation field work will be completed within two week after its initiation The task specific outlines are presented below
Site Reconnaissance
The monitoring wells to be included in the site reconnaissance are monitoring wells MI-1 MI-2 MI-6 and RB-2 The monitoring wells on Lot 19-11 will be surveyed to a common datum with the existing site wide survey data Well integrity testing consisting of depth to bottom water level and visual inspection ofthe wells will be preformed Groundwater samples will be collected from selected monitoring wells based on the integrity testing Samples will be collected by the Low Flow Protocol set forth in the Site Investigation Work Plan (HSI GeoTrans 1999)
GPR Survey
A GPR survey will be preformed to identify on-site leach field septic tank or cesspool location remnants of waste water lagoon and any other subsurface anomalies We propose to use a 5 foot by 5 foot orthogonal grid survey to detect any near surface anomalies which exist on Lot 19-11 Geophysics GPR International will be performing the survey and will be utilizing a GSSI SR10 ground penetrating radar system with a high resolution 500 MHz antenna and a deep-penetration 100 MHZ antenna Any GPR response which indicate buried metal objects will be investigated with a Fisher TW6 pipe locator to augment the radar data All data will be analyzed in the field by GPR personnel and presented to HSI GeoTrans field personnel to determine the optimal location for well cluster ASI-28 If several anomalies are detected the VTDEC and HSI GeoTrans will evaluate the anomalies and modify the work plan accordingly
Well Installation and Soil Boring Advancement MITEC 104e 02455
The well clustes will consist of a small diameter shallow monitoring well and a deeper conventional well screened across the zone of highest concentration Well cluster installation will be performed in accordance with the Site Investigation Work Plan (HSI GeoTrans 1999) yjth 0 0 5 5
MWP_DOCSK731IW9M OOSIIOOprl
HSI GEOTRANS
Mr Michael Smith 3 October 151999
the exception ofthe deep wells The site conditions observed during previous field work prohibit the use of standard commercially available screen slot sizes The deep wells will be advanced by a large diameter Geoprobereg rod and installed using an outer filter sock to prohibit the infiltration offine sediments in to the well The well cluster installations will be performed jointly by Checkpoint Environmental and Twin State Environmental HSI GeoTrans will be provide oversite ofthe contractors and analysis of groundwater samples using afield Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999) The rationale for the selected well cluster locations is presented below
Monitoring well clusters ASI-25 through ASI-27 are located down gradient ofthe suspected source area The well clusters will be installed to more adequately define the areal extent ofthe concentrated portion ofthe contaminant plume A single soil boring will be advanced at location ASI-26 The soil boring will be screened as it is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-28 will be located after the GPR survey has been completed shyThe cluster will help define the suspected source area and the vertical migration of contaminants in the area The location will be determined in thefield after review ofthe GPR survey is completed The location will be based on any anomalies observed in the GPR data A single soil boring will be advanced at location ASI-28 The soil will be screened with a Flame Ionization Detector as the soil boring is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-29 will be located upgradient ofthe suspected source area The cluster will define the upgradient boundary andor any additional upgradient source areas The ASI-29 well will be paired with the existing shallow monitoring well AL-14
Monitoring well clusters ASI-30 and ASI-31 will be installed to the west cross gradient from the suspected source area to document the areal distribution of dissolved phase contamination emanatingfrom the Ailing Industrial Park The locations selected for these wells should define the northwestern and western extent of contamination
Low Flow Sampling
The additional monitoring well clusters will be sampled in accordance with the approved Site Investigation Work Plan (HSI GeoTrans 1999) Lowflow sampling procedures will be used to sample the newly installed deep wells in their respective clusters ASI-25 through ASI-31
MITEC 104e 02456
000056 MWP_DOCSgtK15JlWMOWllltraquoraquoprl
HSI GEOTRANS
Mr Michael Smith 4 October 151999
Hydraulic Characterization
HSI GeoTrans will conduct a 72 hour pumping test on the deep well at cluster ASM 2 The test is being undertaken to more adequately characterize hydraulic conditions at the site The data from this test will be used in the evaluation of remedial alternatives in the Feasibility Study The pump test will be performed as a step-drawdown test The pumping rates will ultimately be determined in the field from observed conditions Preliminary calculations indicate that pumping rates of 2 5 and 10 gallons per minute will be necessary to achieve the desired drawdown at observation wells The water level data will be recorded at observation wells ASI-06 ASI-13 ASI-25 ASI-26 NO-1 NO-2 and NO-3 The water level data will be recorded using pressure transducers and dataloggers
The effluent water from the pumping test will be treated by liquid phase granular activated carbon filters provided by Carbtrol Inc Two 175 pound carbon filters will be connected in series to treat the pump test effluent The effluent will be discharged to the unnamed brook upon approval from Randy Bean ofthe VTDEC The effluent will be periodically sampled between the carbon units and at the discharge point to detect break through ofthe carbon units The effluent samples will be analyzed utilizing a field Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999)) If the effluent sample between the carbon canisters exceeds 1000 ugL Trichloroethene (TCE) the discharge point sample will be analyzed If concentration of TCE in the discharge point sample exceed 300 ugl the test will be discontinued
We hope that this letter addendum to the Site Investigation Work Plan for the Source Investigation is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJmm MITEC I04e
02457
000057 MWFDOCSN731imu00SI 100 bullpd
HSI GEOTRANS
JHSTUART March 1 1985
Agency of Environmental Conservation D e partment of Water Resources und
E nvironmental Engineering H a z a r d o u s Materials Management Program A t t n John A m i d o n H y d r o g e o l o g i s t M o n t p e l i e r Vermont 05602
R e M I T E C Systems Corp W i l liston
Dear J o h n
During our meeting at MITEC on February 20th you noted that some additional information was needed to c omplete the initial phase of testing as well as the d o c umentation of the activities under takentodate Outline d~ beTow-Ts ~t h e~1 n f o r m a ti o n t h a t y o u r e q u e s t shyed
1 Attac hed here to is the plan used to install the grou ndwat er moni t o r s collection and analysis of the grou ndwa t er samp les for metals and organics and the extr actio n of and testing of soils from the area of the dispo sal site 2 A rev ised sit e pla n has been incl uded refl ecting the new well posi tions and the e leva t ions of t he top of t he mo ni to r s and th e groundwa ter 1e vels as of F e shybr ua ry 0th As note d in our m ost r ecent tel ephone conv i on th e lat ter have r isen 14-15 inc hes as er sa t the It o f th e rec ent thaw Two copie s of the resu plan be f orw ar ded to Winslo w Lad ue as req uested will and pla ns t 0 sur vey all ho uses on Br owne 11 Rd MITEC _tp tain if there are ajiy shallo w wel I sources ltis ce r with e dr aina ge ar ea a f fecte d by the 1agoo n in th 3 ngla nd Ma r ine C o m r a c t o r has been con tacted New E for remo va 1 of th e lagoon soil a nd co ntra c tural the ar ra nts wil 1 be concluded du r ing t he comi ng ngeme week if ic at io n of work comme nceme nt wi II be proshy Not vide your off ice i n advance d to t m Resul t s of th e met als and or genies are expected shor tiy
f rom IEA and will be fo rwarded to your ofshyf ice oon as a va i la ble as s 5 R esul t
s fr om t he pr e vious soi 1 and water sampling have inc 1 ude d bee n
CIVIL 4 EfViROUMEI-L pound l j i t fcHpound P ) OGA lt i f r l h r l h w i l l n-- i i U - iO l i l ) bU i l I
MITEC 104e 02458
s
MITEC Page 2 March 1 1985
If you have any questions please do not hesitate to contact me
Stuart PE
JHSocc
MITEC 104e 02459
MITEC Systems Corporation Williston Vermont
Soil and Water Sampling Program
1 Install groundwater monitors at nine (9) locashytions consisting of two (2) inch inside diameter PJpound with ten (10) feet of factory slotted pipe extending into the groundwater and terminating with a minimum of two (2) feet above ground level and capped
2 Establish elevations of the groundwater monitors for the top of each pipe and the groundwater elevashytion for each for a specific date Due to the shalshylow depth to groundwater from 51-112 inches the level is established by graduated tape and a light Each measurement will be performed a minimum of three times to assure accuracy to within one-eighth inch The location of each well and the established elevations will be represented on a general site plan showing the MITEC property
3 Groundwater samples are to be collected from each well on the same date by pump or baling Prior to - k ~ -~-|1bdquo--bdquobdquo f bdquo k bdquobdquobdquobdquobullbdquo ltv~ 11 1 1 v bdquo bdquo bdquo
acidification for metals preservation to assure ac curacy of the test results All samples are to be analyzed for copper cadmium nickel cyanide pH conductivity total chromium and hexavalent chrome
U Soil samples are to be collected as follows
GWM09 Saturated zone (aaprox 5) Overburden East side lagoon Composite from
two holes 5 apart-at-1 bullbull2 bullbull A below the-sur=mdash face and one in the saturated zone
North wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface 1 into the saturated zone
South wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface I1 into the saturated zone
Bottom of lagoon Composite offour test holes 8 apart one in the unsaturated zone
MITEC 104e 02460
MITEC Sampling Program
All samples are to be analyzed for the same constituents as required of the water testing
5 Collect separate samples of the groundwater after the above referenced purging process for storage in air-tight vials The samples which are to be colshylected from wells A-9 with only 5 and 7 analyzed initially by the GCMS- EPA method 62A If organics are detected in the first samples testing must be performed on 4 and 8 as well
6 All sampling will be performed with a State repshyresentative on-site and results of the testing to be forwarded to the State as soon as available
7 The contaminated soil within the lagoon will be removed by a Vermont certified contractor for disposhysal in an approved wastedepository The top one (1) foot of soil from the flood level and below will be extracted during the process
MITEC 104e 02461
i
o H
ON f J
o
bull I I bull
HA
OOO
x x z
bull
MITEC 104e 02463
WK miui w ci ivnui II i ici ILUI ujiyitb inc iii PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5108
ANALYSIS REPORT
Customer j H S c u a r t Associates Date 26 February 1985
Address P gt 0 gt B o x 3 6 7 Date Samples Received
Ci ty S t a t e Zip Essex Center VT 05A15 20 February^1985
Customer Order Nomber
Attent ion J o h n S t u a r t
Station 9
J
2
3
A
5
6
7
8
9
poundH
5A
58
52
5A
A5
53
53
55
59
j MITEC
Conductivity U mbos ( 25degC)
206
A18
21A
176__
208
230
205
16A
265
GROUNDWATER ANALYSIS
O01 0 OS bull
Cadmium Total Chromium (mRl) (mRl)
0A1 lt0025
006- 270
00A 012
bull005 189
005 023
001 lt0025
lt0C Hexavalent Chromium (mKI)
bull
lt0025
239
005
183
lt0025
lt0025
ampo
Zinc (mKl)
005
0A0
032
015
OU
003
Note Organic analyses to follow in two weeks
cc John Amadon
Signature jJfcrryyS 7lrifrylC
Offices ond loborotones located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02464
if jsznoi U hnvironmentol jiolysts Inc PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5138
ANALYSIS REPORT
Customer J H Stuart Associates Date 21 December 1984
Address PO Box 367 Date Samples Received 14 December 1984
City State Zip Essex Center VT 05451 Customer Order Number
Attention John Stuart
WATER ANALYSIS
PH 52 57 50 53 45 34
Conductivity (pmhos 25degC) 213 420 152 167 202 bull 225
O l Cadmium (mgl) lt001 lt001 001 v 028 bull 005 003
o pound Chromium Total (ng1) lt0025 lt0025 lt0025 lt0025 2-35 v 014 - -bullbull - bull - -bull V 013 bull^Chromium Hexavalent (mgl)1 0 11
gt1p Copper (mgl) lt002 lt002 lt002 lt002 bull 084 004
Q Cyanide (mgl) lt0005 lt0005 lt0005 lt0005 bull -lt0005 lt000E
Z Nickel (mgl) lt0025 lt0025 lt0025 lt0025 bull 010 003
fO 2inc (mgl) 0J1 UU1 0U3 001 038 030
Hexavalent chromium was only analyzed when total chromium was present
Signature fmnigt Mji fnt f VncL 7
Offices and laboratories located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02465
bull i
ANALYSIS REPORT
Customer J H Stuart Associates Date 22 January 1985
Address PO Box 367 Date Samples Received 14 December 1984
Ci ty State Zip Essex Center VT 05415 Customer Order Number
Attent ion John Stuart
bull shy
bull bull mdash bull bull bull bull bull - bull bull bull bull shy SOIL ANALYSIS1
Hexavalent Cyanide Chromium Chromium Cadmium Copper Nickel Zinc
poundH bull (mgl) (mgl) (mq1) bull (mq1) (mq1) (mgl) (bullmgl) -
2 442 lt0005 lt0025 lt0025 lt 001 lt 002 015 006
4 402 lt0005 lt0025 lt0025 lt 001 lt 002 lt002 001
7 504 lt0005 lt0025 lt0025 lt001 lt002 lt002 001
8 486 lt0005 lt0025 lt0025 lt001 lt002 lt002 bull 008
9 441 lt0005 lt0025 lt0025 lt001 lt602 lt002 004
10 444 0005 lt0025 lt0025 lt001 lt002 lt002 006
11 498 lt0005 lt0025 lt0025 lt001 003 lt002 009
30 532 lt0005 lt0025 008 lt001 005 lt002 010
31 544 lt0005 lt0025 lt0025 lt001 002 056 003
32 472 lt0005 lt0025 lt0025 lt001 lt002 024 003
36 536 0008 lt0025 011 lt001 005 lt002 011
37 490 lt0005 lt0025 lt0025 lt001 021 lt002 009
38 391 lt0005 0276 032 lt001 050 lt002 011
41 416 lt0005 0108 018 001 229 lt002 o5i
42 395 lt0005 0399 041 lt001 039 lt002 014
i
Signature Ltrf(7( ni W0 6M Analysis of EP toxicity extract
Offices ond loborotoriei locoted in Essex Junction Vermont Reseorch Triongle Pork North Corolino
MITEC 104e 02466
JHSTUART
A p r i l 2 9 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Hazardous Waste Materials Program Attn Cedric Sanborn Environmental Engineer Montpelier Vermont 05602
Re Mitec Systems Williston
Dear Cedric
I was phoned by David Gee today and informed that a truckload of the contaminated material was removed from the lagoon area as the result of a previous commitment entered into by Mitec Due to conflicting information about Mitecs responsibilities at this juncture I am recommending that any further work cease until a realistic program be agreed to by both parties I base that on the following
1 Following the trial pre-hearing the State was inshystructed to contact Mitec to develop a schedule for further dialogue and actions connected with the reshyhabilitation of the lagoon site To my knowledge there has not been any such attempt made on the part of the State to resolve issues that need clarificashytion
2 On April 18th I forwarded a letter to you outlinshying some new information with recommendations That correspondence has not been addressed yet Mitec has been ordered to continue with the soil removal
3 A letter from John Amadon on April 23rd notes the organic sampling to be invalid due to the time lapse and the method of storing the samples We do not take issue with this position however there is apshyparently some question about the validity of the GCMS method of analysis We have been instructed to re-sample but now there is a question about whether we should employ GC or GCMS
A On numerous occasions we have expressed the deshysire to tailor the soil removal process to a minimum
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 3C7 ESSEX CTR VERMONT 05451 TELEPHONE 802 876 bull 5171
MITEC 104e 02467
L
Mitec Page 2 April 29 1985
2- bull number of truckloads as they are projected to cost about $4000 for each load Mitec being in a startshyup phase of their operation cannot approach this operation with a blank check Chris Stone who was on hand today to represent the State indicated that many more loads may be necessary to effectively rid the site of contamination
Too many questions surround this project for my clishyent to understand his responsibilities and ultimate costs The requirements issued by your office either in writing or verbally on-site have changed repeatshyedly and unless we can mutually agree to a reasonshyable program that is connrifpH rnmdashyr r i ng Mitec has no other option but to let the court decide the isshysue
Again keep in mind there are questions that we feel must be resolved in order to reach a satisfactory conclusion
1 Provided that all Browneil Road houses are connected to the CWD system and thereby reshymoved from any threat of groundwater conshy
- p tamination what level of soil contamination is permissible From this limitation provishyded we concur as to its reasonableness an approximation can be developed as to how many loads of soil must be removed
2 If the soil is to be removed why is it neshyy cessary to conduct organics sampling unless
i t~ i s tne ulterior motive ot the State to direct renovation of the groundwater as well If that is the case the process will now be more expensive than at the outset due to the mobilization of the contaminants
3 If the contaminated soil is to be removed whv is additional groundwater monitoring
pound bull necessary Documentation of the degree of dilution is not considered acceptable
A If organic testing is to be performed y_hich -- method of analysis is to be used
As soon as we can receive a response to the quest-
MITEC 104e 02468
I um laquoi i laquo m mdash n r r j mdash i mdash
Mitec Page 3 April 29 1985
ions at hand then further discussion with the State will dnsue Also please be advised that at the dishyrection of Mitec all future correspondence communishycations requests for information or notification of site vists are to be forwarded to my office We also request that one person in your office be designated to process such information
tuart PE
JHSocc cc Mitec
Robert Cronin Esq
MITEC 104e 02469
jmfMraquoi w i f u m i
A u u raquo laquo F pound raquo laquobull= -
B C f U S t B C INC ENVIRONv i bullbullbull bullbull
5 GREEN MOUNTAIN DRIVE SOUTH BURLINGTON VERMONT 05401 TELEPHONE (802) 658-1074
February 17 1984
I I Mr Cedric Sanborn i
of Environmental Conservationi AgencAgencyy ox ampnvifoiuneniai Lonservdciun I i Dept of Water Resources and
Environmental Engineering Montpelier VT 05602
Dear Mr Sanborn j i
RE Mitec Clean-Up 84011 j
I am writing this letter to inform you of the work that has been completed thus far at Mitec Systems Corp The discharge of i rinsewater into the lagoon has stopped and the rinsewater is being batched and treated at Aquatec as I described in my letter to Stan Corneille dated February 3 1984
Although the chemical reduction and precipatation process works bull bull
very well we have found that the cost for design installation j septic design and installation and permit reviews is far above | Mitecs budget Aquatec has looked at a second alternative for bull the treatment and reduction of rinsewater that being ion exchange J The ion exchange system will be purchased from a vendor and will bull be installed by Aquatec to accomodate Mitecs rinsewater volumes i The rinsewater will be recirculated and will not require any discharge hence there will be no need for subsurface disposal [ permits I will send you specifications on the system and resins j that will be used I
The proposal for the out-door clean up work is enclosed Mr Kucer is currently discussing the cost estimate with his Montreal office I see no reason to intiate this work as soon as I get formal approval from your office and from Mitec
Please feel free to call me if you should have any questions
Sincerely
liytrl Zi [U$) John R Deigo Project Engineer
Enclosure cc Mr Steven Kucer
Hydrographic Studies and Analyses bull Water Quality Studies raquo Analytical Laboratories Ecological Studies bull Aquatic Nuisance Control - Industrial Waste Surveys
MITEC 104e 02472
Recommended Treatment of Rinsewater
Mitec System Corporation
Prepared By
Aquatec Inc
South Burlington Vermont
January 23 1984
MITEC 104e 02473
RE Mitec Groundwater Cleanup - 84011
The treatment of rinsewater will consist of a three stage rinse system with a batch chemical reduction treatment process Parts submersed in chromic acid solutions will be rinsed in a primary rinse bath The primary rinse bath will be a closed system and considered a rough rinse
The secondary rinse bath will also be a closed rinse system The third and final rinse will be a continuous overflow system Effluent from the tertiary system will flow directly into the septic system Tertiary effluent limits must be less than 005 mgl (ppm) before entering an underground septic system
The primary rinse bath will eventually become saturated with chromic acid solutions and require periodic batch treatment When the primary rinse water becomes spent it will be transferred into a 250 gal polyethylene plating tank The rinse water from the secondary rinse bath will be transferred into the primary rinse bath and the secondary bath will be refilled with fresh rinse water
When the tank reaches 80 of its capacity treatment will be initiated The treatment will consist of reducing hexavalent chromium to trivalent chromium by the addition of anhydrous sodium sulfite to a pH of lt2 The amount of sodium sulfite added will depend on the concentration and volume of rinsewater to be treated A portable electric mixer will be attached to the tank to ensure proper mixing The rinsewater in the reduced form will be gravity fed into a second 250 gallon polypropylene plating tank where lime will be added precipatlng out trivalent chromium as well as other heavy metals The mixer should be used to agitate the solution when the lime is added The mixer should be removed and the solids allowed to settle Once the solids have completely settled the treated water will be pumped into the tertiary effluent to allow for further dilution before it is discharged into a septic system
Periodic sampling of effluent waters should be incorporated to ensure that rinsewater discharged does not exceed 005 mgl (ppm)
Sludge will be properly stored and eventually disposed of by a certified hazardous waste carrier
MITEC 104e 02474
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Wildlife and Department of Forests Parks and Recreation Environmental Engineering Department of Water Resources amp Environmental Engineering Natural Resources Conservation Council State Geologist
January 4 1984
3 2ampov~ loo Mr J H Stuart
f i 2 Sm ^
P O Box 3 67 - - l ^ J ^ S M J Essec Center Vt 05451
SUBJECT Mitec Z 0~npJ^
1 o
Dear J o h n
I appreciate your sending me a copy of the recent Mitec water quality results It appears that there remains a detrimenshytal affect of the lagoon on the downgradient groundwater quality This is best demonstrated with the pH and chrome data While it appears that the downgradient well 5 has higher metalic concenshytration then well 6 in the middle of the lagoon I believe the Well 5 results are anamously high due to the turbidity or solids that we saw in the sample In talking with Cathy Cutting of IEA sample 5 was not filtered prior to acid digestion for the AAS analysis ^^
I would suggest that well s 4 5 and 6be resampled and analyzed along with the wells installed on CecT 17 amp 18 We would like to have a representative of our office on site when the sampling is performed so please contact me when a purging and sampling date is set in the near future The groundwater sample from test well 6 that you helped me obtain on December 17 with the teflon bailer was confirmed by our laboratory to contain volatile organics Therefore you must include the volatile orshyganics assay done by JGCMSjas a part of your analysis plan Adshyditionally I would suggest that you review the appropriate protocol for groundwater sampling and obtain the necessary equipshyment A sampling and analysis plan must be submitted for our apshyproval prior to commencing this second round of sampling The plan should be submitted by January 18 1985 with the sampling done within one month of our approval Please feel free to conshytact me with any comments or questions you may have
R f n r mdash i 1 Off ices - BarreEssex J c t P i t t s f o r d N Spr ing f ie ld S t Johnsbury
MITEC 104e 02844
J H Stuart Page 2
I do look forward to reviewing the results of the soils asshysays along with your report outlining the sampling protocol sampling locations data interpretations and projected course of action based on the results
Very truly yours
John F Amadon Hydrogeologist Hazardous Materials Management Program
JFAkp
cc Meredith Wright AG
MITEC 104e 02845
b v
HSTUART ASSOCIATES September 10 1984
Agency of Environmental Conservation Department of Water Resources and Environmental Engineering Air and Solid Waste Programs Attn Cedric Sanborn Air Pollution Control Engineer Montpelier Vermont 05602
Re M I T E C Corporation Williston Vermont
Dear Cedric
As Che result of our conversation on September 7th I am forwarding the information Chat we discussed
The CesCing program format was prepared prior Co our disshycussion and will be altered slightly based on some inforshymation that was collected
A boring was established in the cencer of Che disposal pic and Che wacer Cable as well as che Impeding layer were found to be located at 29 Inches below the surface The shallow depth will allow us co place addicional wells in che area co accuracely depicc Che groundwacer copography
The plan submiCCed herewith provides general information abouc che locaclon of che plane propercy lines and sugshygested positions for Che monitors The final location of che laccer will be decermined in che field once we collect more data on water table elevations
As we are most anxious to proceed with the program your expeditious review and responsewill be most appreciated
SCuart PE
JHSadt
cc David Gee MITEC
CIVIL ENVIRONMENTAL ENGINEERS 120 LAKE STREET BURLINGTON VERMONT 0S401 TELEPHONE 802-8640094
MITEC 104e 02846
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Game and Department of Forests Parks and Recreation
Department of Water Resources amp Environmental Engineering Environmental Engineering Natural Resources Conservation Council
September 19 1984
Mr John H Stuart PE JH Stuart Associates 120 Lake Street Burlington Vermont 05401
RE MITEC Project
Dear Mr Stuart
Chris Stone and I have reviewed the proposed soil sampling and groundwater monitoring plan for Mitec A summary of comments follows
1) The site plan did not show the location of the soil sampling sites Also we felt that additional boringmonitoring sites should be made closer to the facility The map has been re-marked to reflect these additional sites
2) It was not clear as to why the monitoring wells are to be installed 5 feet into the impeding layer However at least one boring should be made into the impeding layer to detershymine its thickness
3) Permeability tests should be performed on at least four of the test holes to determine aquifer characteristics
4) Since the water table is apparently close to the surface we feel that factory slotted pipe would be appropriate for the final monitoring wells
5) All soil1 ft 5 ft
samples 10 ft or
shouldto imp
be eding
takenlayer
at whic
depthshever
of comes
first
MITEC 104e 02847
Mr JH Stuart -2- September 19 1984
6) In addition to the soil sample in the center of the former lagoon four other locations within 2 feet of the edge of the lagoon must be sampled These locations are marked on the enclosed map
7) The State regulations do not address a level below which the metals are no longer hazardous as is done by EPA Toxicity Levels The level of contamination that is acceptable to the State is determined on a case by case basis
8) The analysis for chromium should include both hexavalent and total chromium
If you have any questions regarding our comments do not hesitate to contact us at 828-3395shy
Sincere
Sanborn C h r i s t o p h e r T Stone Environmental Engineer Hydrogeo log i s t Hazardous M a t e r i a l s Hazardous M a t e r i a l s Management Program Management Program
c r s - c t s a d e n c l o s u r e
MITEC 104e 02848
JHSTUART November 9 1984
Agency of Environmencal Conservation Deparcmenc of Wacer Resources and
Environmencal Engineering Hazardous MaCerials Management Program Attn Cedric Sanborn Environmental Engineer Mnotpelier Vermont 05602
Re M I T E C Corporation Williston Vermonc
Dear Cedric
There has been an apparent misunderstanding regarding your letter of September 19 1984 as soil and wacer sampling has been commenced ac che above location A call was placed Co your office on October 30th or 31sc and a message lefc for you indicating that we would begin on November 6ch at 8 AM
In the afternoon of November 6th I telephoned Chris Scone co inform him of our progress On che following morning you notishyfied MITEC that approval to begin had not been granced and chac work musC cease AC chac point we had completed che installashytion of five monitors and had extracted Cwo soil samples from the botcom of che wasce pic
On November 8ch I met with you and Chris to oucline che reshysulCs from our effores I was informed Chat we may have to inshystall one or Cwo additional monitors and Chac all future work muse be performed wich an Agency represenCacive in accendance
LaCe that afternoon Gerry Adams phoned Co notify me chat on short notice he was leaving to begin a large contract in rUasashychusetts and that it was unlikely that he would be back in the area for an extended period Had we been permitted to continue ttith our work on the 7th his portion of the project vould have been concluded
Enclosed you will find an updated version of the site plan orishyginally submitced wich my leCCer of Sepcember lOch A new plan will be developed buc Chis drawing will serve the purpose of locating existing and proposed wells
Whereas I am now withouc a drilling concracCor I would like chu
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05461 TELEPHONE 802 878 5171
MITEC 104e 02849
M I T E C Page 2 November 9 1984
authorization to determine groundwater elevations by auger and then establish one more monitor in a location agreed to by all che parcles I feel chac we have developed sufficient information co date to proceed in this manner
Furcher since Adams will noc be available I would also like Co extract che remaining soil samples wich a bucket auger IC can demonstrated chac che sample collected in chls manner will provide a good represencacion of che soil ac che level desired in Che profile
We are prepared co conclude chls phase of che sice evaluacion Samples from Che groundwacer monitors can be secured in a few days and I would like co follow wich che soil samples using che method described above
Please contact me at 878-5171 if you need additional informashytion
H Stuart PE
JHSadt
cc David Gee MITEC
MITEC 104e 02850
JHSTUART December 19 1984
M I T E C Corporation AtCn David Gee Manager IS Commerce Way Wllliscon Vermonc 05495
Dear David
Under Che Cerms of our agreemenc daced 10584 I wish Co proshyvide you wish an up-daCe of the project status
At the completion of 1219 we will have completed Items 1-4 as specified in the agreement specifically the soils sampling and initial set of water samples will have been collected and submitted for analysis As of chls momenC we still do not know the extent of the problem but will have a better indication once the test results are available in about a week My feelshying Is chac the problem is noc severe
We have compleCed all wells as prescribed however Che State is opting for an additional well Although the contract provides for only six the costs to date are below my target and it does not appear Chac any exCra will be necessary provided ChaC che driller concludes his work coday
The only work remaining afCer chls dace will be che collecCion of che second baCch of waCer samples and discussions wich Che State about any remedial action if necessary
Feel free to contacC me if you have any quescions
Regards
John H Stuart PE
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 878 bull 5171
MITEC 104e 02851
JHSTUART
M I T E C Corporation December 20 1984 ACCn David Gee Manager 15 Commerce Way Willaton VT 05495
Dear David
During our investigations yesterday Che work was completed on the additional monitor well as invoiced as well as drilling to the impeding layer The State decided however that two addishytional wells are required both of which will be Installed toshyday west of the Industrial park boundary line
A major change developed In Che method of testing the soils in the vicinity of the disposal pit that is not covered by our contract Instead of the four peripheral borings and one in Che center of che pic which would have produced flfceen soil samshyples che StaCe representatives decided Co require a different CesC paCCern Chac produced thirty seven samples I have collectshyed all of the samples but have Instructed the Cest lab to hold until authorization Is received Co proceed on Chls change as it Is a subsCanClal cost and will cause Che contract limit to be exceeded
Included is an invoice reflecting the additional wells the cost Co sample the groundwater for those monitors and the additional funds needed to run the soil tests I do not believe that any further surprises are in order
Regards
John H Stuart PE
JHSadt
CIVIL ft ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 06451 TELEPHONE 802 878 5171
MITEC 104e 02852
JHSTUART
December 28 1984
M I T E C Corporation Attn David Gee Manager 15 Commerce Way Williston VT 05495
Dear David
Enclosed are the results from the water quality analyses of the samples submitted to our lab I have noted in the left hand column the allowable limits for each element A copy of this information has been forwarded to John Ami-don per his request
There are several readings that are suspicious according to John The cadmium level in 4 may be an error and Che chromium found in 5 mosc likely Includes che CurbldlCy measured only in ChaC well Both should be resampled to confirm The cadmium and chromium levels in 06 exceed che allowable llmlCs but not excessively so The soil tesCs which have begun will reveal more about the ultimate disshyposition of these elemenCs
On the sewer Issue I spoke wich Frank Ailing again and his plans are Co now develop Che design and receive approval chis wincer for consCrucCion of the required Improvements this spring
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 5171
MITEC 104e 02853
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MITEC 104e 02855
JHSTUART January 28 1985
M I T E C Corporation Attn David Gee Manager 15 Commerce Drive WillistonVermont 05495
Dear David
On January 25th I met with John Amadon and Cedric Sanborn to discuss the contents of my 12385 letshyter The following resulted subject to confirmation by more senior members of the AEC staff
1 The water samples to be collected from wells 45 and 6 are to be checked for cadmium both chromiums and conductivity Wells 1 2 and 3 will be tested for conductivity and pH only
2 Samples will be collected from wells 4-9 for orshyganics but only wells 56 and 9 are to be checked at this time to determine the scope of contaminatshyion
3 The material to be removed from the pit is conshysidered as a hazardous waste and there are not any disposal sites located within Vermont certified to receive it I did obtain a listing of contractors that are approved for handling the material and I will provide this during our next meeting
4 Attached is a copy of the State lab results that address the organics problem
5 Based on the above we will have to amend our ashygreement to include the $1150 additional costs for the testing connected with Items 1 and 2
Call me if you have any questions
John H Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 raquo 878 bull 5171
MITEC 104e 02856
JHSTUART January 30 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Attn John Amadon Hydrogeologist Montpelier Vermont 05602
Re M I T E C
Dear John
I have had several discussions with MITEC relative to our meeting of last Friday In essence they have agreed to the program that you defined but with several provisos
They would like a letter from your office detailing the additional measures to be implemented together wich specific instructions as to what steps must be taken in the process of removing the contaminated soil
Further their acceptance to collect and sample for volatile organics is limited Perchloroethylene as I had indicated is not and has not been used by MITEC The materials stored on the premises as well as the list of suppliers for paints and solvents are available for inspection co corroborate that position MITEC will provide a complete analysis of all organics for the specified wells however fushyture testing for TCE will not be at the expense of MITEC unless its presence can be attributed to their operation
We are prepared to proceed as soon as we receive the requested notification
Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 bull 5171
MITEC 104e 02857
TABLE OF CONTENTS (CONTINUED)
PAGE
5 COMPARATIVE EVALUATION OF ALTERNATIVES 5-1 51 SHORT-TERM EFFECTIVENESS 5-1
52 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT 5 - 3 53 LONG-TERM EFFECTIVENESS 5-4
54 COMPLIANCE WITH ARARS 5-4
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 5-4
56 IMPLEMENTABILITY 5-5
57 COSTS 5-5
6 PREFERRED REMEDY 6-1 61 PREFERRED REMEDY 6-1
62 MONITORING PROGRAM 6-2
REFERENCES 7-1
APPENDIX A TWODAN INPUT FILES
FOR ALLING INDUSTRIAL PARK MWgt_DOCSW7532000WJJNGfS9^)0M00J(raquo9wpo I V H S I G S O T r a H S I n C
MITEC 104e 02356
LIST OF TABLES
PAGE
TABLE 3-1 REMEDIAL ACTION OBJECTIVES 3-7
TABLE 3-2 DESCRIPTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES 3-8
TABLE 3-3 SELECTION OF POTENTIALLY VIABLE REMEDIATION TECHNOLOGIES
FOR DETAILED ANALYSIS 3-11
TABLE 41 COST ESTIMATES FOR REMEDIAL ALTERNATIVES 4-31
TABLE 6-1 SAMPLING LOCATIONS 6-5
TABLE 6-2 VOC ANALYTES 6-6
TABLE 6-3 PARAMETERS TO EVALUATE BIODEGRADATION 6-7
FOR ALLING INDUSTRIAL PARK MWP DOCSN7S32000AUJNOFS9-00I0030929 wro HSI GeoTrans inc
MITEC 104e 02357
LIST OF FIGURES
PAGE
FIGURE 1-1 STUDY AREA LOCATION MAP 1-2
FIGURE 1 -2 LATERAL BOUNDARIES OF REGION OF TCE-CONTAMINATED GROUNDWATER 1 -3
FIGURE 4-1 MODELED SITE-EXISTING CONDITIONS 4-33
FIGURE 4-2 MODELED SITE WITH THREE RECOVERY WELLS PUMPING AT 5 GPM 4-34
FIGURE 4-3 MODELED SITE WITH TEN RECOVERY WELLS PUMPING AT 5 GPM 4-35
FIGURE 4-4 ALTERNATIVE 3 PERMEABLE REACTIVE BARRIER 4-36
FIGURE 6-1 PROPOSED MONITORING LOCATIONS 6-8
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUUNOFS9-OOV 10030929 w r o VI HSI GeoTrans inc
MITEC 104e 02358
1 INTRODUCTION
This Corrective Action Feasibility Investigation is submitted on behalf of Mitec Telecom
Inc (Mitec) by HSI GeoTrans The investigation was done to evaluate potential remedial
alternatives for groundwater contaminated by trichloroethylene (TCE) and to a lesser extent
tetrachloroethylene (PCE) and petroleum related compounds (BTEX) at the Ailing Industrial
Park (the Study Area) A recently prepared Site Investigation Report (SIR) (HSI GeoTrans
2000) identified the nature and extent of contaminated groundwater within the Study Area
Figure 1-1 is a map ofthe Study Area and Figure 1-2 is a map that outlines the region of
contaminated groundwater for which potential remedial alternatives were evaluated
The SIR concluded that the TCE contamination was widespread across the Study Area
that residual TCE dense non-aqueous phase liquid (DNAPL) resulting from one or more releases
was a continuing source of contamination to groundwater and that under current conditions the
groundwater contamination does not pose an unacceptable risk to human health and the
environment Current conditions include the continued effective mitigation of indoor air vapors
at the residence at Lot 3-30 no other residences with basements below the water table and no
use of groundwater within the Study Area as a potable supply The SIR also concluded that if
groundwater were to be used as a potable supply a significant health risk would exist as a result
of exposure to groundwater through ingestion dermal contact and inhalation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^X)M0030929WPD 1 - 1 HSI GCOTrdnS ITC
MITEC 104e 02359
I - N -
Former Mitec Hold y
Meters
Explanation
Study Area TITLE
MITEC 104e 02360
Study Area Location Map
LOCATION
Williston Vermont CHECKED MS FIGURE HSI OfVFTED RMK
GEOTRANS RLE f s ~ Expa nd~S(tsdirq 1-1 A T I T M TICK C011irraquoraquoT DATE- 10600 ~
2 STUDY AREA CONCEPTUAL MODEL
The following discussion ofthe Study Area conceptual model is summarized from
information contained in the previously submitted SIR (HSI GeoTrans 2000)
21 STUDY AREA LOCATION AND DESCRIPTION
The Study Area is located at the Ailing Industrial Park and adjacent areas in Chittienden
County Williston VT The VT state plane coordinates for the Study Area are Northing
71210837 (44 27 T north latitude) and Easting 147576375 (73 7 50 west longitude) The
Study area is within the Winooski River watershed and has an elevation ranging from 330 to 350
feet above mean sea level (MSL) The ground surface has little relief and slopes gently to the
southwest A small unnamed brook flows in a southerly direction along the eastern edge of an
industrial park located within the Study Area There is unlimited public pedestrian access to the
Study Area
22 S T U D Y A R E A L A N D U S E
The land in the Study Area is currently zoned for mixed residential commercial and
industrial use The eastern portion ofthe Study area is primarily zoned for commercial use and
the western portion ofthe Study Area is predominantly residential The Study Area includes an
industrial park where there has been light industrial and commercial use since 1946 Three lots
in the industrial park have been previously identified as locations of former manufacturing andor
fabrication operations that resulted in release of contaminants to groundwater (Brinkerd 1996
TRC 1993 Griffin 1995)
23 HYDROGEOLOGIC SETTING
The unconsolidated geologic deposits beneath the Study Area consist of sand silt and
clay which were deposited in the former Champlain Sea overlying till The unconsolidated
deposits occur in four distinct layers The surficial deposits are medium to fine sand which
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000VALUNoFS9^X)10030929wro 2 - 1 H S I G e O T r a f l S J n C
MITEC 104e 02362
generally becomes finer-grained with depth and extend to approximately 20 feet below ground
surface (bgs) Interbedded silts and fine sands are present from approximately 20 to 40 feet bgs
An areally-extensive clay layer underlies the interbedded silt and fine sands at a depth of
approximately 32 to 60 feet bgs Beneath the clay layer is a dense till which extends from about
60 to 100 feet bgs The underlying bedrock is comprised of massive gray limestone gray
dolomite and white marble ofthe Beckman formation This bedrock is of lower Ordovician age
and is part ofthe Hinesburg Synclinorium structure
The aquifer in the Study Area and surrounding regions is primarily the surficial medium
and fine sands although some water is capable of being extracted from the lower silt and fine
sand The residences and businesses within the Study Area are currently serviced by a public
water supply and the aquifer is not used for potable water supply within the Study Area The
hydraulic conductivity ofthe medium to fine sands was determined from a slug test to be about
20 feetday (Johnson 1999) The hydraulic conductivity ofthe interbedded silt and fine sand as
determined from rising and falling head slug tests (HSI GeoTrans 2000) ranged from 1 to 20
ftday with a geometric mean of 38 ftday A pumping test of well NO-1 yielded a hydraulic
conductivity estimate of about 2 to 30 ftday for the combined medium to fine sands and
underlying silt and fine sand There are no hydraulic conductivity data for the underlying clay
and till layers It is believed that the clay and till act as a lower confining layers restricting the
vertical flow of water between the overlying sand and the underlying bedrock
Beneath the Study Area the depth to water generally ranges from 3 to 11 feet below
ground surface In general groundwater flow beneath the Study Area is from the north to the
southeast and southwest There is a groundwater divide in the water table that runs generally
parallel to Commerce Street East ofthe divide groundwater flows toward and discharges to the
unnamed brook West ofthe divide groundwater flows toward Muddy Brook which is located
about 300 meters or 1000 feet west ofthe Study Area Groundwater recharge within the Study
FOR ALLING INDUSTRIAL PARK MAWPJgtOCSN753UOOOWXINOFS9-O0l0030929wro 2-2 HSI GCOTrdnS IDC
MITEC 104e 02363
Area is primarily from infiltration of precipitation Prior to 1986 when a sewer line was
installed groundwater recharge also resulted from discharge to numerous on-site disposal
systems
24 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION
Figure 1-2 illustrates the 1999 distribution of TCE-contaminated groundwater within the
Study Area The lateral boundaries ofthe region of TCE-contaminated groundwater
approximately represent the lateral boundaries ofthe region of volatile organic compound
(VOC)-contaminated groundwater As discussed in the SIR (HSI GeoTrans 2000) VOCs
present in groundwater include TCE PCE and BTEX The compound detected at the highest
concentrations and over the largest portion ofthe Study Area is TCE PCE is generally detected
in the same area as TCE but at significantly lower concentrations BTEX compounds have been
detected in groundwater primarily in the eastern portion ofthe Study Area and are commingled
with but not coincident with TCE-contaminated groundwater The lateral boundaries shown in
Figure 1-2 approximately represent the lateral extent of groundwater contamination and are not
intended to indicate that all groundwater within those boundaries is contaminated This figure
includes data collected on behalf of Mitec as part ofthe SIR (HSI GeoTrans 2000) and data
collected in 1999 by the Johnson Company (Johnson 1999) Figure 4-2 A ofthe SIR (HSI
GeoTrans 2000) shows all TCE concentration data collected in 1999 as well as some data
collected in 1997 The SIR (HSI GeoTrans 2000) summarized previous investigations that
indicated that at least three properties have contributed to the region of VOC-contaminated
groundwater On Lot 19-11 there were a disposal lagoon and a leach field that resulted in the
release ofthe VOCs TCE and PCE (perhaps as an impurity in the TCE) Lot 19-12 once had
underground storage tanks from which a previous release of BTEX was discovered when the
tanks were removed Lot 19-2 contained a disposal pit and outfall pipe from which TCE was
reportedly released
Figure 1-2 of this report shows in plan view the areal distribution of TCE-contaminated
groundwater Where there were multiple 1999 data values for the same location preference was
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AL1JNOFS9-OOM0030929WPD 2-3 HSI GSOTraHS JHC
MITEC 104e 02364
given to samples collected by low-flow sampling done subsequent to well installation In
addition for those locations which had samples from different depths the sample with the
highest concentration was used Figure 1-2 illustrates that TCE-contaminated groundwater is
widespread beneath the Study Area and that the highest TCE concentrations are detected in
groundwater beneath the eastern portion ofthe Study Area The figure illustrates that TCE-
contaminated groundwater in the eastern portion ofthe Study Area discharges to the unnamed
brook No VOCs including TCE have been detected in groundwater samples collected from
wells on the eastern side of the unnamed brook Based on surface water and groundwater data
that have been collected the unnamed brook appears to limit the southeasterly extent ofthe
region of VOC-contaminated groundwater In the western portion ofthe Study Area the lateral
boundaries of contaminated groundwater were identified through vertical profile sampling at
several locations Figure 1-2 shows the location ofthe vertical profiling borings that define the
lateral extent of TCE-contaminated groundwater The SIR (HSI GeoTrans 2000) recommended
periodic sampling and analysis of wells in the western portion ofthe Study Area for the purpose
of determining whether this region of VOC-contaminated groundwater was stable or expanding
in size
While not evident from Figure 1-2 it was determined that throughout the Study Area the
highest TCE concentrations were detected in samples collected from the interbedded siltclay
layer As shown on Figure 4-2A ofthe SIR the higher TCE concentrations were generally
detected at a depth of about 35 feet below ground surface in the eastern portion ofthe Study
Area and at a depth of about 30 feet below ground surface in the western portion ofthe Study
Area It is believed that the current distribution of TCE contamination resulted from DNAPL
releases at one or more locations within the Study Area One such release area was at Lot 19-11
DNAPL migrated downward through the upper medium to coarse sands under the primary
influence of gravitational forces There would have been some lateral displacement along
preferential pathways provided by sloping unconsolidated deposits but the primary flow would
have been downward Upon encountering the more resistive capillary pressure forces associated
with the water-saturated finer-grained geologic units such as the interbedded silts and sands
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which exist beneath the upper medium to coarse sands the DNAPL downward migration would
have stopped The DNAPL would have accumulated on top ofthe capillary pressure barrier layer
and then would have spread laterally following preferential flow paths within the coarser-grained
geologic units above the interbedded silts and sands The amount of lateral spreading of
DNAPL from any release area would have been dependent upon the volume and frequency ofthe
releases As the DNAPL migrated it would have created a region of residual DNAPL This
region of residual DNAPL consists of isolated DNAPL droplets trapped within pore spaces ofthe
unconsolidated deposits The lateral migration ofthe DNAPL would have been affected by the
slope ofthe surface ofthe finer-grained units that halted downward migration ofthe DNAPL
and it would not necessarily have been coincident with the direction of hydraulic gradient or
groundwater flow The region of residual DNAPL is now a continuing source of contamination
to the groundwater which flows past and gradually dissolves the DNAPL The locations ofthe
residual DNAPL zones are not known
There were no direct observations of DNAPL during drilling and well installation but it
is expected that residual DNAPL generally exists within regions of higher concentration detected
in the eastern portion of the Study Area The residual DNAPL is not necessarily continuously
connected within that region Based on the vertical distribution of TCE concentrations it is also
expected that the residual DNAPL exists in a relatively thin zone within the interbedded silt and
clay Limited hydrodynamic dispersion within the interbedded silt and clay has resulted in a
relatively thin zone of relatively high TCE concentrations in groundwater The southeastward
and southwestward divergence of groundwater flow has resulted in a laterally extensive region of
TCE-contaminated groundwater
There has been no indication in any ofthe investigations done within the Study Area
including the SIR (HSI GeoTrans 2000) that there are locations within the Study Area where
DNAPL is present in sufficient volume to be recoverable in the DNAPL phase
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3 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES
31 IDENTIFICATION OF ARARS
Two Applicable or Relevant and Appropriate Requirements (ARARs) were identified in
consultation with Mr Mike Smith ofthe Vermont Department of Environmental Conservation
(VTDEC) The first are the Groundwater Enforcement Standards as outlined in Appendix one of
the Chapter 12 Groundwater Protection Rule (VTDEC 1997) These standards apply to
concentrations of contaminants in groundwater in the Study Area (TCE PCE and BTEX) The
second are the Vermont Water Quality Criteria dated March 142000 (VTDEC 2000) which
specify surface water quality criteria and policy
32 REMEDIAL ACTION OBJECTIVES
The remedial action objectives (RAOs) for the Study Area are summarized in Table 3-1
and further described below
321 REMOVAL OR CONTROL OF CONTAMINANT SOURCES
One ofthe RAOs for the Study Area is the remediation of source areas Soil excavation
and removal has already occurred at the known release areas Not withstanding the fact that
previous DNAPL releases are suspected no areas of recoverable DNAPL have been detected in
the Study Area Concentrations of TCE in groundwater indicate it is present in some areas as
residual phase below the water table One purpose of this Corrective Action Feasibility
Investigation is to evaluate options for remediating residual DNAPL in the Study Area
322 GROUNDWATER
Attain VT Groundwater Enforcement Standards The ultimate goal of remediation is to
attain Groundwater Enforcement Standards for VOCs in groundwater This is in accordance
with the VT Groundwater Protection Rule and Strategy (VTDEC 1997) which states that If an
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(MUJNOFS9^)OM0030929WPD 3 - 1 HSI GCOTranS IttC
MITEC 104e 02367
enforcement standard has been reached or exceeded at a compliance point the goal is to take
appropriate action to retum the groundwater quality to below the enforcement standard if
possible
Prevent Expansion ofthe Dissolved Plume A risk assessment (Menzie Cura 2000a and
2000b) was included as part ofthe SIR (HSI GeoTrans 2000) The risk assessment concluded
that under current conditions concentrations of VOCs dissolved in groundwater in the Study Area
do not pose a risk to human health andor the environment The SIR (HSI GeoTrans 2000) also
indicated that the available monitoring data were not sufficient to determine whether the region
of VOC-contaminated groundwater in the southwestern portion ofthe Study Area was stable in
size or expanding This Corrective Action Feasibility Investigation explores options for
monitoring groundwater quality and preventing the region of VOC-contaminated groundwater
from expanding in size
Prevent Potable Use of Groundwater Within the Dissolved Plume Menzie Cura prepared
a June 1 2000 addendum (Menzie Cura 2000b) to the April 2000 risk assessment (Menzie Cura
2000a) The addendum evaluated risk posed by potable use of groundwater at the site The
addendum found there to be a human health risk associated with the use of groundwater at the
site for potable purposes One RAO of this Corrective Action Feasibility Investigation is to
propose institutional controls so that groundwater within the region of contaminated
groundwater would not be used as a potable supply until concentrations are suitable for such use
323 SURFACE WATER
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
under current conditions VOCs dissolved in surface water in the Study Area do not pose arisk to
human health or the environment Currently however surface water concentrations in the
unnamed brook exceed VT Water Quality Criteria (VTDEC 2000) One ofthe RAOs for the
site will be to meet these surface water quality standards in the unnamed brook
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324 INDOOR AIR
The VTDEC has conducted air sampling at several residences along Kirby Lane and
South Browneil Road The results have indicated the presence of TCE and PCE in indoor air at
some ofthe South Browneil Road residences (Brinkerd 1996) and unacceptable VOC
concentrations in the basement ofthe residence at Lot 3-30 on South Browneil Road The
presence of VOC vapors in the residence on Lot 3-30 is believed to have resulted from
volatilization of groundwater which infiltrated the basement through a continuously operating
sump pump The sump was vented to the exterior ofthe house as part of a state-sponsored
action and the indoor air concentration ofthe contaminants reduced to an acceptable
concentration Therefore one institutional control for the site will be to maintain the sump
venting as long as necessary to prevent health risks due to inhalation of VOC concentrations in
indoor air Also an institutional control in the form of a zoning restriction should be
implemented to prohibit the construction of new buildings with basements below the water table
in the region of contaminated groundwater The restriction should specify that in cases where it
is unavoidable to place the basement below the water table proper containment and venting of
the sump drainage system is required
33 INITIAL SCREENING
Four general categories of remedial technologies were evaluated The first monitoring
may be used alone or in conjunction with other remedies The second category includes
institutional controls to prevent exposure to contamination in groundwater and indoor air
Institutional controls could also be used alone or in conjunction with other remedies The third
category includes source removal technologies
The fourth category includes contaminated groundwater containment technologies such
as a hydraulic barrier or permeable reactive barrier Containment technologies can be applied in
two different ways Thefirst source control application would entail installing the containment
technology directly downgradient ofthe highest dissolved concentrations in an attempt to contain
the contaminated groundwater nearest the source Over time if new contamination is not
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MITEC 104e 02369
allowed to migrate beyond the source VOC concentrations in the downgradient region of
contaminated groundwater should attenuate
The second application would entail installing the containment technology at the
downgradient edge ofthe region of Contaminated groundwater The containment would protect
downgradient receptors from impacts by the region of contaminated groundwater
Both containment technology approaches were considered for use in the event additional
monitoring data shows that the region of VOC-contaminated groundwater is expanding in size
or if VOC concentrations in groundwater discharging to the unnamed brook are increasing
Table 3-2 identifies the remedial technologies considered and summarizes the results ofthe
initial screening for applicability to addressing the ARARs
34 SELECTION OF POTENTIALLY VIABLE TECHNOLOGIES
The list of potentially viable technologies shown in Table 3-2 was subjected to an initial
screening process The purpose ofthe initial screening was to identify those technologies that are
potentially feasible in the Study Area prior to performing a more detailed technology screening
Many ofthe source removal technologies were removed from further consideration because of
the impracticability of remediating residual DNAPL at the site
As described in the SIR (HSI GeoTrans 2000) DNAPL is likely present in the Study
Area Although present DNAPL has not been directly observed in any location and there has
been no indication that there is recoverable DNAPL present The failure to detect DNAPL
directly is not an uncommon situation at DNAPL sites and commonly results from its
heterogeneous distribution or its presence only at residual saturation (US EPA 1992)
Groundwater extraction and treatment is not an effective technology for remediation of residual
DNAPL due to limitations resulting from the limited solubility of most DNAPL compounds and
the heterogeneous distribution ofthe DNAPL (US EPA 1993) Designing remedial strategies
for DNAPL is made difficult by the inability to accurately locate the DNAPL sources This
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inability to locate the DNAPL renders the use of targeted source remedies that might be cost
effective for a small readily definable source area ineffective These targeted source remedies
include excavation air sparging chemical oxidation in-situ thermal desorption and chemical
flushing technologies
Subsurface deposits in the Study Area are heterogeneous due to the interbedded nature of
the sands and silts overlying an areally extensive clay The presence of such heterogeneity
creates extremely variable and unpredictable groundwater flow velocities as well as flow paths
for DNAPL migration The contrast in permeability and porosity between different lithologies
results in the development of preferential flow pathways While preferential flow through coarse
sand and gravel zones provides higher than average groundwater flow rates and contaminant
flushing less preferential flow pathways such as silty sands silts and clays remain poorly
flushed even under forced hydraulic gradients created by extraction wells Contaminants
however may have migrated to these areas of less preferential flow as DNAPLs under
gravitational influence or by diffusion over long periods of time The low permeability zones
even if addressed by localized extraction of groundwater will transmit only small quantities of
water and hence contaminant flushing is slow This is compounded by the low solubility of
DNAPL constituents and the tendency for them to become trapped in soils by capillary pressure
forces
Specific source removal technologies which have been screened out as ineffective at this
stage include air sparging groundwater amendments excavation and in-situ thermal desorption
Low permeability zones prevent the migration of soil vapors or sparged air to the near-surface for
recovery due to the preferential flow caused by heterogenieties it is not possible to determine if
amendments which can be added to the groundwater or chemical flushing compounds which
displace the groundwater and help liberate residual DNAPL such as oxidants alcohol polymers
andor surfactant would reach the DNAPL Excavation which has already been used to remove
impacted surface soils in known release areas is not practical for removing residual DNAPL
deep below the water table The in-situ thermal desorption can be useful in some environments
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MITEC 104e 02371
but can also induce downward DNAPL migration if hydraulic control ofthe system is not
complete Because the location of residual DNAPL is not known and because hydraulic control
ofthe underlying silt clay and till into which the DNAPL may migrate cannot be assured in-situ
thermal desorption is not feasible for this site
Monitoring and institutional controls are included in each option evaluated except for the
no-action alternative These are required to rule out possible future health risks due to expansion
ofthe region of VOC-contaminated groundwater or the creation of new contaminant exposure
pathways
The technologies remaining after the initial screening are presented in Table 3-3
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Table 3-1 Remedial action objectives
MEDIA REMEDIAL ACTION OBJECTIVE
Groundwater -Remove or control contaminant sources
bullAttain VT Groundwater Enforcement Standards
-Prevent expansion ofthe region of contaminated groundwater
-Prevent use of groundwater within the region of contaminated groundwater as a
potable water supply where contaminant concentrations exceed federal drinking
water standards
Surface Water -Attain VT Water Quality Criteria
Air -Prevent inhalation of concentrations in indoor air derived from groundwater
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MITEC 104e 02373
-n Table 3-2 Description of potentially viable remediation technologies o w o
i mi m rshym
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I W O mOH
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R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Basement Sump Venting
Restriction on new buildings with basements set below the water table
Restrict Potable Use of Groundwater
Excavation
Natural Gradient Flushing
Air Sparging
RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
PROCESS DESCRIPTION OPTIONS
No Action No Action
Monitor groundwater concentrations to confirm that region of VOC-contaminated groundwater is not expanding in size
Monitor surface water concentrations in unnamed brook to ensure concentrations remain below risk levels
Continue to vent the sumps at Lot 3-30 on South Browneil Road
Restrict construction of any new buildings with basements set below the water table within the area of dissolved VOC contamination and require basement sump venting in those where a below water table basement is unavoidable
Place restrictions on potable use of groundwater at properties overlying the region of VOCshy contaminated groundwater
Excavation and removal of soils containing residual DNAPL
Continued dissolution and natural attenuation of residual DNAPL
Injection of air beneath the water table to volatilize residual DNAPL and dissolved concentrations in groundwater
INITIAL SCREENING C O M M E N T
Used as a baseline for comparison No cost Long remediation time
Can be used in conjunction with other response actions Will be required in the southwest portion ofthe region of contaminated groundwater since existing data are inconclusive regarding this issue
Can be used in conjunction with other response actions
Will be required until data show there is no longer a risk to indoor air from groundwater in the basement
Will be required until data show there is no risk of migration of VOCs to indoor air from groundwater
Will be required at all properties in the area of VOC-contaminated groundwater to prevent a risk to human health
Has been used at the site to remove residual DNAPL in soils in the release areas Impractical to recover residual DNAPL at depth The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Intermediate cost Short time frame to cleanup if all residual source can be removed
Higher permeability zones are preferentially remediated On-going monitoring required No installation or on-going maintenance costs Long time frame to cleanup
Small-scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Intermediate installation and high on-going maintenance costs
MITEC 104e 02374
5 T l O Description of potentially viable remediation technologies (continued) PO
Table 3-2 O
RESPONSE REMEDIAL PROCESS g 5 ACTION TECHNOLOGY OPTIONS 5 m
r-m Source Chemical Ozone m Removal Oxidation Sparging q JO o n o
o
Potassium Permanganate Injection
Fentonss Reagent Injection
i co
Source In-Situ Steam Removal Thermal Stripping
Desorption
Electrical Resistance Heating
I Radio (pound Frequency
O m Heating OH 3) gt Z 0)
DESCRIPTION
Injection of air and encapsulated ozone beneath the water table to oxidize dissolved DNAPL constituents such as TCE
KMn04 is injected below the water table to oxidize dissolved DNAPL constituents
Fentons Reagent is injected below the water table to oxidize dissolved DNAPL constituents
Stream injected below the water table As the groundwater and soil are heated residual DNAPL is mobilized and collected by groundwater and soil vapor extraciion techniques
Low frequency alternating current is applied below the water table to cause resistive heating ofthe soil and groundwater As the groundwater and soil heat residual DNAPL is mobilized Groundwater and soil vapor extraction techniques are used to collect dissolved and vaporized DNAPL constituents
Electromagnetic radiation is applied below the water table As the groundwater and soil heat residual DNAPL is mobilized
INITIAL SCREENING COMMENT
Presence of DNAPL will potentially require large quantities of ozone The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Small scale heterogenieties can result in channeling during air injection and reduce the recovery efficiency Soil vapor extraction must be used to recover stripped contaminants from the unsaturated zone Ozone is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of KMn04 The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Presence of DNAPL will potentially require large quantities of Fentons Reagent The exact location of the residual DNAPL is unknown and will be hard to target for treatment Higher permeability zones are preferentially remediated Fentons Reagent is highly reactive Intermediate time frame to cleanup unless heterogenieties prevent full residual DNAPL removal High installation and operation cost
Small scale heterogenieties can result in channeling during steam injection and reduce the recovery efficiency Shallow depth of application may preclude effective steam control The exact location ofthe residual DNAPL is unknown and will be hard to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeneity has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
Formation heterogeniety has little effect on treatment uniformity The exact location ofthe residual DNAPL is unknown and will be difficult so target for treatment Must be used in conjunction with vapor and groundwater extraction to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent full residual DNAPL removal Very high installation and operation cost
_ mdash_ mdash _ _
MITEC I04e 02375
bulln Table 3-2 Description of potentially viable remediation technologies (continued) o
R E S P O N S E
A C T I O N
tn Source Removal
Source Containment Plume Management
co bull
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REMEDIAL
TECHNOLOGY
Chemical Flushing
Hydraulic Containment
Impermeable Barrier
Permeable Reactive Barrier
Phytoshyremediation
PROCESS
OPTIONS
bull
DESCRIPTION
Injection and recovery of alcohol polymers andor surfactant below the water table to enhance dissolution of residual DNAPL
Pump groundwater in downgradient portion of VOC-contaminated region groundwater to intercept contamination before it reaches a receptor or downgradient ofthe highest concentrations as source containment
Impermeable barrier is installed in the subsurface to contain groundwater and reduce the pumping rate needed for containment Can be installed upgradient of a receptor to prevent exposure or downgradient of the highest concentrations as source containment
Reactive material such as zero valent iron placed in flow path of contaminated groundwater Contaminants are treated as the natural gradient causes groundwater to flow through the barrier
Extracting of contaminated groundwater by evaporation from high water use trees Organic contaminants may also be biodegraded by the root system or may adsorb to living or dead root tissue and become immobilized
INITIAL SCREENING C O M M E N T
Higher permeability zones are preferentially remediated The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Groundwater extraction is required to control mobilized contaminants May mobilize and spread DNAPL Short time frame to cleanup unless heterogenieties prevent fulfresidual DNAPL removal Very high installation and operation cost
Effective in containing dissolved concentrations Relatively low installation cost moderate on-going maintenance costs
Effective in containing dissolved concentrations Requires groundwater extraction and treatment Moderate installation cost moderate on-going maintenance costs
Moderate installation costs Lifetime of reactive material difficult to predict and reinstallation may become necessary No on-going maintenance costs prior to replacement
Still experimental Hard to confirm water usage rates and prove containment Trees may require ongoing monitoring and replacement Low installation and maintenance costs Only operates during the growing season
MITEC 104e 02376
1 T l Table 3-3 Selection of potentially viable remediation technologies for detailed analysis 1
rt g g g
5
i 8 5
3
CO
o m O H JO gtZW
o3 O tn
spound r m rshymO
M nn o
gt zbulllt
RESPONSE
ACTION
No Action
Monitoring
Institutional Controls
Source Removal
R E M E D I A L
T E C H N O L O G Y
No Action
Groundwater Monitoring
Surface Water Monitoring
Indoor Air Monitoring
Basement Sump Venting
Potable Use of Groundwater
Restrict Basements Below Water Table
Excavation
Natural Gradient Flushing
Air Sparging
Chemical Oxidation
In-Situ Thermal Desorption
Chemical Flushing
PROCESS
OPTIONS
No Action
Ozone Sparging
Potassium Permanganate Injection
Fentonss Reagent Injection
Steam Stripping
Electrical Resistance Heating
Radio Frequency Heating
RETAINED
DISCARDED
Retained
Retained
Retained
Retained
Retained
Retained
Retained
Discarded
Retained
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
Discarded
RATIONALE
Used as a baseline for comparison
Necessary to evaluate if the region of VOC-contaminated groundwater is expanding in size and if the VOC concentrations in groundwater discharging to the unnamed brook are increasing
Necessary to monitor that concentrations remain below health risk levels
May be required al new residences with basements below the water table built in Browneil Road area
The existing sump vents at Lot 3-30 on South Browneil Road will be required to mitigate indoor air risks
Restriction of potable use of groundwater at properties overlying the region of VOC-contaminated groundwater will be required to prevent dermal ingestion and inhalation exposure
Restriction of construction of new basements below the water table in the area of VOC-contamination will be required to prevent future inhalation risks
Residual DNAPL located too far below ground surface to make excavation feasible The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment Excavation of known release areas has occurred
Longer time frame to clean up not a drawback at this site Lower cost is a benefit
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location of the residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL Steam control difficult
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
The exact location ofthe residual DNAPL is unknown and will be difficult to target for treatment May mobilize and spread DNAPL
MITEC 104e 02377
2 Table 3-3 Selection of potentially viable of remediation technologies for detailed analysis (continued) a m RESPONS E R E M E D I A L PROCES S RETAINED RATIONALE
ACTION T E C H N O L O G Y OPTION S DISCARDED
Source Containment Hydraulic Containment Retained Proven effective at containing expansion ofthe region of contaminated groundwater Region of Contaminated
iisect
n n o
Groundwater Management
Impermeable Barrier Retained Proven effective at region of contaminated groundwater containment
Permeable Reactive Retained Proven effective at region of contaminated groundwater containment Barrier
Phyto-remediation Retained Experimental however there are no potential negative consequences in using the technology Low cost is a benefit
co i
IO
I (A O m OH 73 gtZ
MITEC 104e 02378
4 DETAILED ANALYSIS OF ALTERNATIVES
41 ALTERNATIVE 1 NO ACTION
The no-action alternative is included in accordance with EPAs Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA (EPA 1988) The no-action
alternative provides a baseline for comparison and involves taking no additional actions at the
Study Area This remedy assumes no continuing monitoring of dissolved concentrations in
groundwater surface water or concentrations in indoor air This remedy assumes no institutional
controls on basement sump venting at Lot 3-30 on South Browneil Road property no restrictions
on new buildings with basements set below the water table constructed within the area of VOC
concentrations in groundwater and no restrictions groundwater use for potable purposes within
the region of VOC-contaminated groundwater
411 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community The risk assessment completed for the SIR
(HSI GeoTrans 2000) concluded that current conditions at the Study Area do not pose a risk to
human health Current conditions include venting ofthe sump at Lot 3-30 on South Browneil
Road no buildings other than at Lot 3-30 with basements below the water table in VOC-
contaminated areas and no potable-use wells within the region of VOC-contaminated
groundwater Without institutional controls to ensure this there may be future risk The risk
evaluation indicated that concentrations in the unnamed brook resulting from contaminated
groundwater discharge while not above risk-based thresholds were close to levels that could
pose a risk to human health Therefore monitoring is advised to confirm that VOC
concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
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MITEC 104e 02379
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of VOC-contaminated groundwater could result in health risks not
evaluated in the risk assessment
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative
Time to Achieve Remedial Action Objectives It is estimated that the time frame required
for natural attenuation of contaminants to meet the groundwater cleanup concentrations will
significantly exceed the two-year time frame used to evaluate short-term effectiveness
412 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment There is no treatment of contaminants under this option
Reduction in Toxicity Mobility or Volume Some reduction of residual DNAPL and
accompanying dissolved concentrations is expected through natural attenuation over time if no
action were pursued at the Study Area However no monitoring data would be available to
confirm the progress
Amount of Material Contained or Treated Natural attenuation may serve to contain the
entirety of the region of groundwater contaminated with dissolved VOCs
413 LONG-TERM EFFECTIVENESS
Residual Risk Therisk assessment completed for the SIR (HSI GeoTrans 2000)
concluded that current conditions at the Study Area do not pose a risk to human health
However the risk evaluation indicated that concentrations in the unnamed brook resulting from
contaminated groundwater discharge while not above risk-based thresholds were close to levels
that could pose a risk to human health Therefore monitoring is advised to confirm that VOC
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concentrations in groundwater discharging to the brook do not increase Without monitoring
such an evaluation cannot be made In addition there are not sufficient temporal data to verify
that the southwest portion of VOC-contaminated groundwater is not expanding in size Further
expansion ofthe region of contaminated groundwater could result in health risks not evaluated in
the risk assessment Without institutional controls to ensure basement sump venting at Lot 3-30
on South Browneil Road restrictions on new buildings with basements set below the water table
within the region of VOC-contaminated groundwater and prevention ofthe installation of wells
for potable supplies within the region of VOC concentrations in groundwater a residualrisk to
human health remains
Adequacy and Reliability of Controls This remedy does not assume the sump in the
basement ofthe residence at Lot 3-30 on South Browneil Road remains sealed and vented to the
outside and that the pump is maintained in operable condition to continue to keep groundwater
out ofthe basement Previous air sampling conducted by the VTDEC has confirmed that this is
necessary to control indoor air impacts to this residence This remedy relies on natural
attenuation to control the region of VOC-contaminated groundwater however there is no
continuing monitoring of dissolved VOC concentrations in groundwater Since monitoring to
date has not confirmed that the region of VOC-contaminated groundwater is not expanding in
size a remedy which has a natural attenuation component but does not include monitoring does
not provide adequate control
Permanence of Remedy In the very long-term natural gradient flushing should reduce
VOC concentrations in groundwater to acceptable levels
414 COMPLIANCE WITH ARARs
Groundwater Protection Rule and Strategy It is expected that natural attenuation would
over time reduce groundwater concentrations to below VT Groundwater Enforcement Standards
However a no-action response would not comply with VT Groundwater Protection Rule and
Strategy (VTDEC 1997) which allows for remediation of sites by natural attenuation if sufficient
monitoring is perfonned to document that expansion ofthe region of contaminated groundwater
is not occurring and that natural attenuation is occurring The no-action alternative would not
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AU1NGFS90010030929wro 4-3 HSI GSOTraFIS IflC
MITEC 104e 02381
allow for continued monitoring and would not meet this requirement
Surface Water Quality Standards It is expected that natural attenuation would over
time reduce surface water concentrations to below VT Water Quality Criteria for the protection
of human health and aquatic organisms (VTDEC 2000)
415 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The risk evaluation conducted as a part ofthe SIR (HSI GeoTrans 2000) concluded that
concentrations of VOCs adsorbed to soil and dissolved in groundwater in the Study Area do not
pose a risk to human health andor the environment under current uses There would be arisk if
groundwater within the region of VOC-contamination were used as a potable supply Therefore
if dissolved concentrations were not migrating beyond the limits ofthe region identified in the
SIR (HSI GeoTrans 2000) and groundwater were not used for potable purposes the no action
alternative would be protective of human health and the environment However there are not
sufficient data to determine whether the region of VOC-contaminated groundwater is stable or
decreasing in size If the region of contaminated groundwater were expanding beyond the limits
upon which the risk assessment was based there may be a future risk to human health and the
environment Also restrictions should be placed on properties overlying the region of VOC-
contaminated groundwater to prohibit construction of basements below the water table and the
use of groundwater as a potable supply and the venting ofthe sump at Lot 3-30 should continue
416 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000AlXINGFS900U0030929wro 4-4 HSI GGOTrdRS IflC
MITEC 104e 02382
Technical Feasibility The no-action alternative is technically feasible
bull Ability to Construct the Alternative The no-action alternative requires no
construction
bull Reliability ofthe Technology No technology would be applied under the no-
action alternative
bull Ease of Undertaking Additional Remedial Actions The no-action alternative
would not prevent future remedial actions
Administrative Feasibility The no-action alternative is administratively feasible
Availability of Services and Materials No services or materials are required to carry out
the no-action alternative
417 COSTS
There are no costs associated with the no-action alternative The no-action alternative is
shown on Table 41 for purposes of comparison
4 2 A L T E R N A T I V E 2 M O N I T O R I N G INSTITUTIONAL C O N T R O L S AND
H Y D R A U L I C C O N T A I N M E N T
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull institutional controls would be implemented to restrict construction of any
buildings with basements within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull groundwater extraction and treatment would be done to contain the region of
VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753laquo000WJJNoFS9JXI10030929wro 4 - 5 HSI GSOTraDS JllC
MITEC 104e 02383
Groundwater pumping is an effective technology for hydraulic containment of
contaminated groundwater Hydraulic containment can be used if the region of VOC-
contaminated groundwater is impacting a sensitive receptor or is expanding is size The risk
assessment (Menzie Cura 2000a and 2000b) showed that groundwater was not impacting any
receptors to a degree that would represent a human health risk or risk to the environment There
is not sufficient temporal data however to confirm that the region of VOC-contaminated
groundwater is not expanding is size Therefore an analysis of hydraulic containment has been
included in this Corrective Action Feasibility Investigation in the event that future monitoring
shows the region of VOC-contaminated groundwater is expanding and that containment is
necessary
If monitoring indicates that natural attenuation is not causing the region of VOC-
contaminated groundwater to be stable in size or to shrink then an active containment remedy
may be required Under this scenario a groundwater pump-and-treat system would be installed
and operated in the Study Area to hydraulically contain contaminated groundwater and prevent
expansion ofthe region of VOC-contaminated groundwater Pumping wells would be installed
in the overburden silts and sands to the clay layer Wells would be installed in the downgradient
portions of contaminated groundwater to the southeast and southwest Extracted groundwater
would be treated before discharge to surface water The primary treatment operation will be air
stripping with a low-profile stripper for the removal of VOCs primarily TCE Depending on
treatment efficiencies secondary treatment with granular activated carbon may be required In
addition a particulate filter may be added to remove iron prior to treatment and reduce iron
fouling ofthe air stripper and carbon Extracted and treated groundwater would be discharged to
surface water via an outfall Compliance sampling can be conducted at the outfall or at a
sampling point within the treatment building The outfall should be constructed to minimize
hydraulic impacts on the receiving water body
The number and location of pumping wells that may be required to capture and contain
the region of TCE-contaminated groundwater has been investigated using the two-dimensional
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9JXA10030929WO 4-6 HSI GSOTfanS IdC
MITEC 104e 02384
analytical element simulation code TWODAN (Fitts 1997) TWODAN is a commercially
available copyrighted program The input parameters to the model are based on the values
reported in the SIR (HSI GeoTrans 2000) Input data sets for the analyses contained in this
report are included in Appendix A The bottom elevation ofthe model is 306 ft which is
representative ofthe top ofthe continuous clay layer beneath the site The model represents the
interbedded silts and fine sand layer and the overlying medium to fine sand surficial unit as one
layer The hydraulic conductivity ofthe modeled layer is 184 ftday The estimated areal
recharge for the model is 10 inyr The basement sump at Lot 3-30 on South Browneil Road
pumps groundwater year round The resulting depression ofthe water table is represented by a
constant head of 33128 ft which is approximately 8ft below ground surface at that location
Groundwater elevations used in the model were based on an average ofthe July 1999 and
December 1999 potentiometric surface in wells with screened intervals intersecting the water
table The model representation of current hydrologic conditions at the Study Area is shown in
Figure 4-1 Groundwater elevations are shown in meters on this figure
Two containment scenarios were evaluated The first was a source control application in
which the TWODAN model was used to determine the number of wells and pumping rates
required to contain the 10000 to 20000+ ugL TCE concentration zone as shown in Figure 1-2
In this scenario pumping would contain the contaminated groundwater nearest the source(s)
Over time if new contamination is not allowed to migrate from the source(s) the VOC
concentrations in the rest ofthe region of contaminated groundwater would attenuate The
second scenario was a containment application in which the TWODAN model was used to
determine the number of wells and pumping rate required to contain the 1000 to 10000 (igL
TCE concentration zone as displayed in Figure 1-2 In this scenario pumping occurs in the
downgradient portions ofthe contaminated groundwater
Each recovery well was assumed to be 4 inches in diameter fully screened and have a
pumping rate of 5 gpm The pumping rate was based on the aquifer testing results reported in the
SIR (HSI GeoTrans 2000) applied to a fully screened extraction well The results ofthe model
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000A1XINOFS9JX)10030929WPD 4-7 HSI GSOTraDS IflC
MITEC 104e 02385
analyses indicate that a minimum of three 4-inch diameter recovery wells pumping at 5 gpm are
required to contain the 10000 to 20000+ ugL TCE concentration zone The results of this
model simulation are shown on Figure 4-2 The model analyses also indicated that a minimum
often 4-inch diameter recovery wells pumping at 5 gpm are required to contain the 1000 to
10000 ugL TCE concentration zone Figure 4-3 shows the results of this model simulation
Figures 4-2 and 4-3 also show that groundwater extraction for hydraulic containment may induce
infiltration of surface water in response to pumping thereby reducing the amount of water
flowing in the brook
421 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 2 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with extraction well construction and treatment plant construction Access by
unauthorized personnel would be restricted by fencing temporary barriers andor warning signs
The groundwater treatment building would be locked and secured A health and safety plan
(HASP) would be prepared for the remedial activities In conformance with Occupational Safety
and Health Administration (OSHA) regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative Suitable dust control measures would be implemented during
construction ofthe groundwater treatment system Additionally the treatment process is
expected to be relatively simple with a low potential for exceedance of discharge limitations
Monitoring ofthe treatment process would be performed
Time to Achieve Remedial Action Objectives The time estimated for well installation
system debugging and establishing hydraulic gradient control is three to six months The RAOs
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^XM0030929wro 4-8 HSI GSOTraOS IIIC
MITEC 104e 02386
for groundwater would be achieved when monitoring results indicated that VOC concentrations
had attenuated and groundwater standards had been met It is estimated that attenuation of VOC
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
422 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of recovered groundwater would remove some ofthe VOCs from
the aquifer This treatment would generate residuals such as used filters and spent carbon This
process is irreversible
Reduction in Toxicity Mobility or Volume Treatment ofthe extracted groundwater
would reduce its toxicity prior to surface water discharge Contaminants adsorbed to any
secondary carbon would ultimately be destroyed during the process of regenerating the carbon
Contaminants adsorbed to any particulate filters would be landfilled or incinerated along with the
filters The toxicity and volume of contamination in groundwater are nominally reduced by
extraction and treatment but effectiveness is limited as discussed in Section 421 above
Modeling shows that groundwater extraction would be effective in reducing the mobility ofthe
dissolved phase contamination
Amount of Material Contained or Treated The volume of contaminated groundwater
that would be treated on a long-term basis is estimated at about 8 million gallons per year for the
source containment option and about 26 million gallons per year for containment of all dissolved
TCE concentrations greater than 1000 ugl
423 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
FOR ALLING INDUSTRIAL PARK MWPJXXTSN75320(XAAUJNOFS9-OCM0030929WKgt 4-9 HSI GSOTrSDS IDC
MITEC 104e 02387
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Groundwater pumping would control any risks caused by expansion ofthe
region of contaminated groundwater Residual risk to human health would be controlled through
institutional controls
Adequacy and Reliability of Controls Extracted groundwater would be treated on-site to
standards required for discharge to surface water The extraction well pumps and groundwater
treatment equipment would require maintenance on a long-term basis Groundwater monitoring
to ensure that the contamination was being adequately contained by the groundwater extraction
would be necessary on a long-term basis
Permanence of Remedy The groundwater treatment plant would be enclosed and
designed as a modular system and its equipment would be readily replaceable if required The
extraction wells may need to be rehabilitated andor replaced during the life ofthe remedy
424 COMPLIANCE WITH A R A R S
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to return the
remaining groundwater to below Groundwater Enforcement Standards Groundwater extraction
would also eventually return the areas of highest groundwater contamination to below
Groundwater Enforcement Standards
Surface Water Quality Standards Hydraulic control of the groundwater migration would
interrupt and remove contaminates from groundwater thereby preventing discharge to the
unnamed brook resulting in achievement of Water Quality Criteria for the protection of human
health and aquatic organisms (VTDEC 2000)
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200OALUNoFS9^Kgtl0030929wro 4-10 HSI GOOTrSDS IDC
laquoTEC I04e 02388
425 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
The hydraulic containment alternative would offer protection to both human health and
the environment if expansion ofthe region of contaminated groundwater were identified Since
the risk assessment (Menzie Cura 2000a) found that under current conditions groundwater and
surface water concentrations are below levels which constitute a risk to human health and since
hydraulic containment would ensure the region of VOC-contaminated groundwater remained in
the current configuration hydraulic containment would be protective of human health and the
environment This alternative assumes institutional controls will be in place to continue sump
venting in the basement at Lot 3-30 on South Browneil Road restrict the installation of
basements below the water table within the region of VOC-contaminated groundwater and
prevent potable use of groundwater within the region of VOC-contaminated groundwater
Protection would be achieved at the end ofthe construction period of three to six months The
residual risks posed by contaminated material remaining within the groundwater would not be
significant because all potential exposure routes would be addressed
426 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction which would present no special problems
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000AUB4CFS9^10l0030929wro 4 - 1 1 HSI GGOTrdDS IDC
MITEC 104e 02389
bull Reliability ofthe Technology Hydraulic gradient control is a frequently used
alternative that has proven effective in preventing further expansion of areas with
- contamination in groundwater Filtration air stripping and carbon absorption
have frequently been used and proven effective in treating groundwater in other
applications
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the
gradient control system was inadequate to restrict the expansion ofthe region of
contaminated groundwater implementation of additional resources would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
operate maintain and monitor the well head portions ofthe treatment system Institutional
controls would also be needed to implement institutional controls to continue sump venting in
the basement at Lot 3-30 on South Browneil Road The town must pass zoning restriction which
would prevent construction of basements below the water table and potable use of groundwater
within the region of contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor the groundwater treatment system associated with the hydraulic containment option
are available
427 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 2 The
capital costs would be $207000 for the source control application and $732000 for the
containment option OampM costs include groundwater monitoring and maintenance ofthe
groundwater extraction and treatment system These are $77000 per year for the source control
application and $139000 per year for the containment option The present worth analysis
(calculated at a 7 discount rate interest for 30 years) yields a total of $1085403 for the source
control application and $2287474 for the plume containment option
FOR ALLING INDUSTRIAL PARK MWPJXXSN753U0OOALUNGFS9-tfW0030929wro 4-12 HSI GSOTrailS IRC
MITEC 104e 02390
43 ALTERNATIVE 3 MONITORING INSTITUTIONAL CONTROLS AND
PERMEABLE REACTIVE BARRIER
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
bull and a permeable reactive barrier would be installed and maintained at a
downgradient location to reduce concentrations of TCE dissolved in groundwater
as it flows under natural gradient flow conditions if groundwater monitoring
shows the region of VOC-contaminated groundwater is expanding in size
PRBs consist of a permeable region of chemically reactive materials constructed to
intercept the path of a dissolved groundwater contaminants Reactive materials may include
bull zero-valent iron for reductive dehalogenation
precipitation agents such as gypsum to create insoluble metal salts
bull sorptive agents such as granular activated carbon to capture and immobilize organics
bull reducing agents such as dithionite and hydrogen sulfide to reduce and insolubilize metals
and
bull biologic electron acceptors such as lactic acid or nitrate to enhance aerobic
biodegradation
FOR ALLING INDUSTRIAL PARK MAWPJX)CSVN7532000AmNOFS9-OOU0030929wpo 4-13 HSI GSOTrSDS IDC
MITEC 104e 02391
Zero-valent iron and granular activated carbon are both applicable for use in the treatment
of TCE in a PRB Granular zero-valent iron has been widely applied in PRB installations and
promotes reductive dehalogenation of TCE to chloride ion ethane and ethene Activated carbon
has been used in a limited number of field and lab studies to simply adsorb dissolved organic
constituents as they pass through thePRB
Because ofthe costs ofthe reactive or adsorptive material PRBs are generally
constructed as a funnel and gate system The funnel portion ofthe PRB is a typical vertical
barrier wall constructed of sheet piles bentonite or other impermeable material which is
designed to direct groundwater flow to the gate portion ofthe PRB containing the reactive or
adsorptive material Funnel and gate sections ofthe PRB are keyed together and generally to a
low permeablility zone located at depth
The use of permeable reactive barriers is not directly applicable to treatment of DNAPL
The mechanism for groundwater remediation using a PRB would include
bull dissolution ofthe DNAPL into groundwater by natural processes
bull downgradient transport ofthe dissolved contaminants to the PRB location
artificial channeling ofthe contaminated groundwater to the reactive material located in
the gate by the barrier funnel and
bull reductive dehalogenation or adsorption of a portion ofthe VOC as is passes through the
gate
A variety of methods are available for emplacement ofthe PRB The most conventional
method includes excavation of a trench and backfill will a soilbentonite slurry for the funnel
portion and granular iron or carbon in the gate section Other methods such as sheet-piling jet
grouting continuous trenching fracturing and others are available For the subject site because
ofthe presence of sand in the formation it is likely that a continuous trenching method would be
the most applicable and cost effective
FOR ALLING INDUSTRIAL PARK MWPJX)CSN7S320O0ALUNGFSraquo-O0U0030929wro 4-14 HSI GGOTfaDS IOC
MITEC 104e 02392
Operation maintenance and monitoring ofthe PRB is relatively simple Groundwater
samples would be periodically collected from locations upgradient and downgradient ofthe gate
section(s) ofthe PRB to monitor its effectiveness Media installed in the gate (iron or carbon)
would require periodic replacement probably on a annual basis for carbon and every 5 to 10
years for iron
The placement depth width and length ofthe PRB would depend on the region of
VOC-contaminated groundwater that was desired to be intercepted the depth to the underlying
low permeability layer and the desired TCE concentration reduction (which determines resident
time required in the gate) As wilh hydraulic containment two scenarios were investigated The
first a source control option would intercept VOC-contaminated groundwater with TCE
concentrations greater than 10000 ugL A PRB of approximately 1200 feet in length would be
required The second a region of contaminated groundwater containment option would
intercept VOC-contaminated groundwater with TCE concentrations in excess of 1000 ugL A
PRB of approximately 2200 feet in length would be required The depth ofthe PRB in both
cases would likely extend from ground surface to about 40 feet below ground surface The PRB
would be installed into the underlying areally-extensive clay layer Figure 4-4 shows the
placement ofthe PRB under each opinion
431 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 3 are as follows
Protection of Workers and the Community Normal construction hazards would be
associated with PRB construction since either conventional or continuous trenching methods
would be employed during its construction However exposure hazards during construction
would be considerable since the emplacement requires excavation and handling of a large
volume of potentially contaminated soils During construction access by unauthorized personnel
would be restricted by fencing temporary barriers andor warning signs Following
FOR ALLING INDUSTRIAL PARK
MWP_DOCSN753 2000 AUJNCFS9^10 10030929 WPD 4-15 HSI GSOTrSPS IDC
MITEC 104e 02393
construction little to no hazards should be expected from the long-term operation ofthe PRB A
HASP would be prepared for the construction activities In conformance with OSHA
regulations site workers would be trained required to wear appropriate protective equipment
and as applicable would be enrolled in a medical monitoring program Groundwater monitoring
wells would be sampled to determine changes in VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative with proper controls Suitable dust control vapor monitoring and
stormwater runoff measures would be implemented during construction ofthe PRB
Time to Achieve Remedial Action Objectives The time estimated for PRB emplacement
is four to six months The RAOs for groundwater would be achieved when monitoring results
indicated that the VOC concentrations have attenuated and groundwater standards have been
met It is estimated that attenuation of contaminant concentrations to ARARS will significantly
exceed the two-year time frame for short-term effectiveness This is because the application of a
PRB at the site would not significantly alter groundwater flow or TCE dissolution from within
the source area Therefore it would not increase the rate at which concentrations of residual
DNAPL or dissolved constituents of DNAPL (TCE) were removed from the source area It
would however limit the size ofthe region of VOC-contaminated groundwater
432 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment Treatment of groundwater flowing through the permeable sections ofthe PRB
would remove the dissolved TCE as is flows under natural gradient conditions from the source
area
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNGFS9^X)10030929WPO 4-16 HSI G G O T T S O S jflC
MITEC 104e 02394
Reduction in Toxicity Mobility or Volume Treatment ofthe groundwater would reduce
its toxicity Contaminants adsorbed to carbon (if used as the treatment media in the gate sections
ofthe PRB) would be excavated on a periodic basis and ultimately be destroyed during the
process of regenerating the carbon
Amount of Material Contained or Treated The volumetric flux of contaminated
groundwater through the PRB is estimated to be approximately two million gallons per year for
the 10000 (igL source containment option and approximately four million gallons per year for
containment of all dissolved TCE concentrations greater than 1000 ugL
433 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Treatment of groundwater intersecting the PRB would control any risks
caused by expansion ofthe region of contaminated groundwater to the southeast Residual risk
to human health would be controlled through institutional controls
Adequacy and Reliability of Controls Performance of PRBs in reducing concentrations
of chlorinated organics such as TCE using zero-valent iron has been mixed Most ofthe PRB
performance demonstrations indicate that a concentration reduction of 60 to 90 percent can be
expected Some applications however have been much less successful at reducing VOC
concentrations Although little experience is available for PRBs using activated carbon the
removal efficiency should be expected to be greater and more reliable than zero-valent iron but
far more costly Groundwater monitoring would ensure that the contamination was being
adequately contained by the PRB and would be necessary on a long-term basis
Permanence of Remedy Installation of a PRB would be considered a permanent remedy
although periodic maintenance and replacement of reactive material in the gate would be
required for both carbon and iron-based systems
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UOOOALUNOFS9^X)l0030929wro 4-17 HSI GGOTfSnS IDC
MITEC 104e 02395
434 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy Under this scenario the areas of highest
groundwater contamination would be contained allowing natural attenuation to reduce VOC
concentrations in the remaining groundwater to below Groundwater Enforcement Standards
Natural gradient flushing would also eventually reduce the areas of highest groundwater
contamination to below Groundwater Enforcement Standards
Surface Water Quality Standards VOC concentrations in groundwater discharging to the
unnamed brook would be reduced significantly Thus operation ofthe PRB would result in
achievement of Water Quality Criteria for the protection of human health and aquatic organisms
(VTDEC 2000)
435 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This downgradient containment alternative would offer protection to both human health
and the environment if VOC concentrations in groundwater discharging to the unnamed brook
were to increase or if the region of contaminated groundwater were to expand in size This
alternative assumes institutional controls will be in place to continue sump venting in the
basement at Lot 3-30 on South Browneil Road restrict installation of new basements below the
water table within the region of VOC-contaminated groundwater and prevent potable use of
groundwater within the contaminated region Protection relative to the risks posed by expansion
ofthe region of contaminated groundwater to the unnamed brook would be achieved at the end
ofthe construction period of four to six months The residual risks posed by contaminated
material remaining within the groundwater would not be significant because all potential
exposure routes would be addressed
FOR ALLING INDUSTRIAL PARK MWP JX3CSN753V2000AIXINOFS90Crl0O30929wPD 4-18 HSI GCOTtSHS IRC
MITEC 104e 02396
436 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility The technical feasibility is evaluated on the basis of three
parameters ability to construct the alternative the reliability ofthe technologies used and ease
of undertaking additional remedial actions
bull Ability to Construct the Alternative The construction of this alternative would
involve basic heavy construction Removal and handling of contaminated soils
presents potential risks to construction workers during construction which could
be minimized through health and safety controls
bull Reliability of the Technology Although many full-scale applications of this
approach have been conducted they have been relatively recent Long-term
reliability and effectiveness of PRBs has not been established
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that the PRB
was inadequate to prevent expansion ofthe region of VOC-contaminated
groundwater implementation of additional resources would not be hampered by
this alternative
Administrative Feasibility Installing and maintaining the PRB will require access to
properties overlying the region of VOC-contaminated groundwater Additionally property
owner cooperation would be needed to operate maintain and monitor wells located upstream
and downstream ofthe gate sections ofthe PRB system Restrictions would also be needed to
implement institutional controls to continue sump venting in the basement at Lot 3-30 on South
Browneil Road restrict the construction of basements below the water table within the region of
VOC-contaminated groundwater and prevent potable use of groundwater within the region of
VOC contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753UO(XAAUJNOFS9-O0 10030929 WPO 4-19 HSI GGOTrSMS IDC
MITEC 104e 02397
Availability of Services and Materials The materials equipment and personnel required
to design install and maintain the PRB are readily available
437 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 3 The
capital costs would be $572000 for the source control application and $1022000 for the
containment option OampM costs include groundwater monitoring and periodic replacement of
the permeable barrier These average $64000 per year for the source control application and
$112000 per year for the containment option The present worth analysis calculated at a 7
discount rate over a 30-year duration yields a total of $1277356 for the source control option
and $2248691 for the containment option
4 4 A L T E R N A T I V E 4 M O N I T O R I N G I N S T I T U T I O N A L C O N T R O L S AND
N A T U R A L A T T E N U A T I O N
Implementation of this alternative would include the following elements
monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water
The chief mechanisms contributing to reduction of contaminant concentrations in
groundwater by natural attenuation include biotransformation dilution dispersion and discharge
through advective flow and volatilization (EPA 1998) Volatilization is not likely a major
mechanism at the Study Area since contaminated groundwater is located at depth below the
FOR ALLING INDUSTRIAL PARK
MWP_DOCSW7S3U000WXINoFS9-001003O929wro 4-20 HSI GGOTfaDS IDC
MITEC 104e 02398
water table A natural attenuation evaluation will be conducted to better identify the mechanisms
contributing to concentration reduction through natural attenuation Monitoring to be completed
for this evaluation is included in Section 62 EPAs Technical Protocol for Evaluating Natural
Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) was used as the basis for the
design ofthe natural attenuation evaluation
441 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 1 are as follows
Protection of Workers and the Community A HASP would be prepared for the remedial
activities In conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Groundwater monitoring wells would be sampled to determine changes in
VOC concentration
Environmental Impacts No significant environmental impacts would be expected during
construction of this alternative
Time to Achieve Remedial Action Objectives The RAOs for groundwater would be
achieved when monitoring results indicated that the region of contaminated groundwater had
naturally attenuated and groundwater standards had been met It is estimated that natural
attenuation of contaminants to ARARS will exceed the two-year time frame for short-term
effectiveness
442 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0ALUNOFS9^X)M0030929wro 4-21 HSI GGOTfaflS jflC
MITEC 104e 02399
Treatment This alternative involves only natural in-situ processes No remediation
wastes would be generated
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area
Amount of Material Contained or Treated Natural attenuation may serve to contain the
region of VOC-contaminated groundwater at the Study Area Treatment may be accomplished
through biotransformation ofthe contaminants to environmentally acceptable compounds
443 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation of VOC-contaminated groundwater at the Study Area
would eventually achieve the ARARs Residual risk to human health would be controlled
through institutional controls Implementing institutional controls to maintain the sump venting
at Lot 3-30 on South Browneil Road restrict the construction of basements below the water table
within the region of VOC-contaminated groundwater and to control the use of groundwater
within the region of VOC-contaminated groundwater for potable purposes would provide
protection against the potential for exposure
Adequacy and Reliability of Controls Monitoring for VOC concentration reductions in
groundwater and institutional controls would be the main controls of this alternative Sump
venting at Lot 3-30 on South Browneil Road would prevent indoor air impacts at this location
and restrictions on construction of basements below the water table would prevent future indoor
air impacts Control ofthe use of groundwater within the region of VOC-contaminated
groundwater for potable purposes would minimize potential use of groundwater with VOCs
above federal and state drinking water standards Groundwater monitoring would ensure that
attenuation of VOC concentrations was proceeding and provide for periodic assessment ofthe
region of VOC-contaminated groundwater in the Study Area
FOR ALLING INDUSTRIAL PARK bull MWPJXXSN7532000AUINOFS9-00I0O30929WPD 4 - 2 2 HSI GGOTPaMS IRC
MITEC 104e 02400
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time
444 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
445 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
446 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
FOR ALLING INDUSTRIAL PARK _
M W P _ D O C S N 7 5 3 U O O O A L U N O F S 9 - O O U 0 0 3 0 9 2 9 W P O 4-23 HSI GGOT 13118 IflC
MITEC 104e 02401
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
bull Ability to Construct the Alternative No major construction is included in this
alternative
bull Reliability ofthe Technology Ongoing monitoring and evaluation on would
ensure that natural attenuation was controlling and remediating the contaminated
groundwater
Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation was not restricting the size ofthe region of VOC-contaminated
groundwater implementation of additional remedial actions would not be
hampered by this alternative
Administrative Feasibility Installing and monitoring additional wells if needed might
require access to private property Additionally property owner cooperation would be needed to
sample and maintain monitoring wells Restrictions would also be needed to implement
institutional controls to continue sump venting in the basement at Lot 3-30 on South Browneil
Road restrict construction of basements below the water table in VOC-contaminated
groundwater and prevent potable use of groundwater within the region of VOC-contaminated
groundwater
Availability of Services and Materials The materials equipment and personnel required
to monitor natural attenuation are also available
447 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 4 The
capital costs would be $55000 and include the initial natural attenuation evaluation and the
implementation of institutional controls OampM costs include groundwater monitoring These are
$9000 per year The present worth analysis yields a total of $163083 for this 30-year
alternative
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320O0AUJNOFS9^X)10030929wro 4-24 HSI GGOTraDS 1110
MTECl04e 02402
45 ALTERNATIVE 5 MONITORING INSTITUTIONAL CONTROLS NATURAL
ATTENUATION AND PHYTOREMEDIATION
Implementation of this alternative would include the following elements
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater and
bull natural attenuation would be utilized to reduce VOC concentrations in
groundwater and surface water and
phytoremediation would be used to intercept TCE-contaminated groundwater
where it discharges to the unnamed brook
In this alternative all components of Alternative 4 would be implemented and
phytoremediation would be implemented in the area where TCE- contaminated groundwater
intersects the unnamed brook to intercept the contaminated groundwater and reduce the amount
of VOCs reaching the brook Phytoremediation of VOCs is still an experimental technology
Several field studies have used hybrid poplars (EPA 2000) to extract TCE- contaminated
groundwater It has been shown that TCE is removed along with groundwater by the trees and
metabolized as well as transpired from the leaves The rate of TCE contaminant removal from
the groundwater and its discharge to air by transpiration varies based on site specific conditions
and season Therefore contaminant or groundwater removal rates are impossible to predict at
this time without field studies Trees may be subject to destruction by natural disasters and pests
Their condition must be monitored and they may require replacement
F O R ALLING INDUSTRIAL PARK MWPJXXSN7532OOOWXINGFS9JraquoIOO30929WPO 4 - 2 5 H S I G G O T r S D S IOC
MITEC 104e 02403
In order for interception ofthe region of contaminated groundwater to be effective the
trees must be planted so that the root zone intercepts the contaminated groundwater Due to the
depth ofthe higher VOC concentrations in most areas ofthe site phytoremediation would be
ineffective in containing expansion ofthe region of contaminated groundwater An exception to
this is the area near the unnamed brook According to the SIR (HSI GeoTrans 2000) VOC-
contaminated groundwater appears to be discharging upward in groundwater into the unnamed
brook Trees planted along the border ofthe brook may help to intercept this contaminated
groundwater before it discharges into the brook
451 SHORT-TERM EFFECTIVENESS
This criterion refers to the protectiveness a remedial alternative offers to workers and the
community during the remediation period as well as the environmental impacts and the time
required to meet the RAOs The short-term effectiveness factors for Alternative 5 are as follows
Protection of Workers and the Community Normal landscaping hazards would be
associated with installation ofthe trees A HASP would be prepared for the remedial activities
In conformance with OSHA regulations site workers would be trained required to wear
appropriate protective equipment and as applicable would be enrolled in a medical monitoring
program Groundwater monitoring wells would be sampled to determine changes in the VOC
concentration
Environmental Impacts No significant environmental impacts would be expected during
implementation of this alternative Suitable dust control measures would be implemented during
planting of trees
Time to Achieve Remedial Action Objectives The time required for maximum
interception ofthe contaminated groundwater by the trees would depend on site specific
conditions such as root growth rate and tree survival rate The RAOs for groundwater would be
achieved when monitoring results indicated that VOC concentrations had attenuated and
groundwater standards had been met It is estimated that natural attenuation of contaminant
concentrations to ARARS will exceed the two-year time frame for short-term effectiveness
FOR ALLING INDUSTRIAL PARK MWP J X 3 C S N 7 5 3 2 0 0 0 A U J N O F S 9 ^ ) 0 1 0 0 3 0 9 2 9 W P D 4-26 HSI G G O T H S I I S IDC
MITEC 104e 02404
452 REDUCTION OF TOXICITY MOBILITY OR VOLUME THROUGH TREATMENT
This criterion reflects the statutory preference for treatment alternatives over non-
treatment alternatives The factors addressed include the treatment itself (process irreversibility
the amount ofhazardous materials to be treated the quantity of treatment residuals) and the
reduction in toxicity mobility or volume ofthe contaminants These factors are discussed
below
Treatment This alternative involves only in-situ treatment ofthe groundwater Plant
tissue would be analyzed for the presence of VOCs Plant materials can bio-accumulate metals
present in soil and groundwater If concentrations are high enough dead plant matter may have
to be disposed in an appropriate manner
Reduction in Toxicity Mobility or Volume Natural attenuation will reduce the toxicity
mobility and volume of VOC-impacted groundwater at the Study Area Phytoremediation may
metabolize some ofthe VOCs
Amount of Material Contained or Treated Natural attenuation and phytoremediation
may serve to prevent expansion ofthe region of VOC-contaminated groundwater at the Study
Area Treatment is accomplished with biotransformation ofthe contaminants to environmentally
acceptable compounds
453 LONG-TERM EFFECTIVENESS
The long-term effectiveness of a remedial alternative pertains to the risks remaining
following the remedial action Three factors to be considered are the magnitude of any residual
risk the adequacy and reliability ofthe controls and the permanence ofthe remedy The longshy
term effectiveness factors are described below
Residual Risk Natural attenuation ofthe region of VOC-contaminated groundwater and
phytoremediation at the Study Area would eventually achieve the ARARs Implementing
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil Road
restrictions on construction of basements below the water table in regions of VOC-contaminated
groundwater and to control the use of groundwater for potable purposes within the region of
VOC-contaminated groundwater would provide protection against the potential for exposure
FOR ALLING INDUSTRIAL PARK MWP_IXXSW532000ALL1NOFS9^)0I0030929WTO 4-27 HSI GCOTraDS IflC
M l T E C l 0 4 e 0240S
Therefore despite the fact that an extended time period may be required to reduce VOC
concentrations to an acceptable level the residual risk associated with this alternative would be
minimal Trees planted near the unnamed brook may serve to intercept contaminated
groundwater before it discharges to this receptor
Adequacy and Reliability of Controls Groundwater monitoring for natural attenuation
institutional controls and interception of contaminated groundwater before it reaches the
unnamed brook would be the main controls of this alternative Sump venting at Lot 3-30 on
South Browneil Road would prevent indoor air impacts at this location and restriction on the
construction of new basements below the water table within the region of VOC-contaminated
groundwater would prevent future indoor air impacts at other locations Control ofthe use of
groundwater for potable purposes within the region of VOC-contaminated groundwater would
minimize potential use of groundwater with VOCs above federal and state drinking water
standards Groundwater monitoring would ensure that natural attenuation of contaminants was
proceeding and provide for periodic assessment ofthe region of VOC-contaminated groundwater
in the Study Area Groundwater and surface water monitoring would also be conducted to
monitor success ofthe phytoremediation in intercepting contaminated groundwater before it
reaches the unnamed brook
Permanence of Remedy It is expected that the monitoring wells may have to be
redeveloped andor replaced from time to time Trees must be monitored and will be replaced in
the event of destruction by severe weather pests or other reasons
454 COMPLIANCE WITH ARARs
This criterion examines the alternative to determine if compliance will be achieved for
the two types of ARARs
Groundwater Protection Rule and Strategy If the natural attenuation processes are
effective at preventing the region of VOC-contaminated groundwater from expanding then they
will also cause VOC concentrations in groundwater to eventually decrease below VT
Groundwater Enforcement Standards
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000AUINOFS9-00I0030929WPD 4-28 HSI GGOTraflS IllC
MITEC 104e 02406
Surface Water Quality Standards If the natural attenuation processes are effective at
reducing the VOC concentrations in groundwater that discharges to the unnamed brook then
VOC concentrations in surface water would eventually decrease to concentrations below the VT
Water Quality Criteria for the protection of human health and aquatic organisms
Phytoremediation at the edge ofthe unnamed brook would further reduce the VOC
concentrations in groundwater discharging to the brook
455 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the overall protectiveness offered by an alternative The
evaluation considers the adequacy of protection minimization of risk and achievement ofthe
four previous evaluation criteria
This alternative would offer protection to both human health and the environment by
minimizing potential contact with contaminated groundwater and preventing expansion ofthe
region of VOC-contaminated groundwater The residual risks caused by groundwater would not
be significant because potential exposure routes would be addressed
456 IMPLEMENTABILITY
This criterion assesses the implementability of an alternative The evaluation considers
technical feasibility administrative feasibility and the availability ofthe required services and
materials
Technical Feasibility Technical feasibility is evaluated on the basis of three parameters
ability to construct the alternative the reliability ofthe technologies used and the ease of
undertaking additional remedial actions
Ability to Construct the Alternative Installation of this alternative requires
landscaping skills which are readily available
bull Reliability ofthe Technology Ongoing monitoring and evaluation would ensure
that natural attenuation was controlling and remediating the contaminated
groundwater Ongoing monitoring ofthe condition ofthe trees would also be
required to ensure they are continuing to grow and do not need replacement
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7S32000ALUNOFS9^)OM0030929WPD 4-29 HSI GGOTfaDS jflC
MITEC 104e 02407
bull Ease of Undertaking Additional Remedial Actions It is not anticipated that any
future remedial actions would be necessary If monitoring indicated that natural
attenuation and phytoremediation were not restricting the size ofthe region of
VOC-contaminated groundwater implementation of additional resources would
not be hampered by this alternative
Administrative Feasibility Planting trees and if necessary installing and monitoring
additional wells might require access to private property Additionally property owner
cooperation would be needed to sample and maintain monitoring wells Restrictions would also
be needed to implement institutional controls to continue sump venting in the basement at Lot 3shy
30 on South Browneil Road restrict construction of new basements below the water table in
regions of VOC-contaminated groundwater and prevent potable use of groundwater within the
region of VOC-contaminated groundwater
Availability of Services and Materials The materials equipment and personnel required
to plant the trees and monitor natural attenuation are also available
457 COSTS
Table 41 provides a summary ofthe capital and OampM costs for Alternative 5 The
capital costs would be $80000 and include the initial natural attenuation evaluation the
implementation of institutional controls and installation of a phytoremedial barrier of poplars
OampM costs include groundwater monitoring and maintenance ofthe phytoremedial barrier
These are $11000 per year The present worth analysis yields a total of $209397 for this 30shy
year alternative
FOR ALLING INDUSTRIAL PARK MAWP_DOCSN7532000ALLINOFS9^)0I0030929WPD 4-30 HSI GGOTfaDS IPC
MITEC 104e 02408
r TI Table 41 Cost estimates for remedial alternatives i deg 5 70
8 P
QUANTITY UNITS UNIT C O S T CAPITA L C O S T ANNUAL
OampM C O S T
5 n Alternative I No Action 8 O a Q
na na $0 $0 $0 a sect
Total $0 $0
Alternative 2 Monitoring Institutional Controls and Hydraulic Containment
1) Implement Institutional Controls 32 properties $10000 $32000
2) Groundwater Monitoring $9000
3) Pumping System
Option 1 Source Containment
Extraction wellspiping $50000 $15000
Electrical distributioncontrol $25000 $8000
Construction oversight $25000
Groundwater treatment system $75000 $45000
Total Option 1 $207000 $77000
Option 2 region of contaminated
groundwater Containment
Extraction wellspiping $175000 $35000
w Electrical distributioncontrol $50000 $20000
O
o H mO Construction oversight $125000
o n gt Groundwater treatment system $350000 $75000
o z 0) Tolal Option 2 $732000 $139000
i deg QUANTITY UNITS UNI T C O S T
5 so
Alternative 3 Monitoring Institutional Controls and Permeable Barrier
m t - 1) Implement Institutional Controls 32 properties $10000
9 O 2) Groundwater Monitoring
| o 3) Permeable Harrier
Option I Source Containment
Barrier installation 1200 feel $450
Total Option 1
Option 2 region of contaminated
groundwater Containment
Barrier Installation 2200 feet $450
w Total Option 2 NJ
Alternative 4 Monitoring Institutional Controls and Natural Gradient Flushing
1) Implement Institutional Controls 32 properties $10000
2) Groundwater Monitoring
3) Natural Attenuation Evaluation
Total
Alternative 5 Monitoring Institutional Controls Natural Gradient Flushing and Phytoremediation
1) Implement Institutional Controls 32 properties $10000 X (A 2) Groundwater Monitoring
reg 3
o m O H
3) Natural Attenuation Evaluation
4) Phytoremediation
gt z Total (A
Notes na = not applicable
CAPITAL C O S T
$32000
$540000
$572000
$990000
$1022000
$32000
$23000
$55000
$32000
$23000
$25000
$80000
ANNUAL
OampM C O S T
$9000
$55000
$64000 1
$103000
$112000
$9000
$9000
$9000
$2000
$11000
MODEL CALCULATED GROUNDWATER CONTOUR IN FEET ABOVE MEAN SEA LEVEL
APPROXIMATE PROPERTY BOUNDARY
M6-2 raquo EXISTING MONITORING WELL
CP-6 bull EXISTING SOIL BORING
M 8 - 2 raquo MONITORING WELL (RESAMPLED)
bull SMALL DIAMETER BORING - BELOW CLAY
bull BEDROCK MONITORING WELL
A S I - 2 I H S I GEOTRANS WELL CLUSTER LOCATION
U-TRIB-8a SURFACE WATER SAMPLING LOCATION R S - U
a PASSIVE SAMPLER LOCATION
T2-2 PROFILE SAMPLE LOCA1ION (JOHNSON COMPANY 1999)
WELL DESTROYED
TEF Concentrat ions ( u g A l
1000 - 10000
iry IOOOO - 20000
bull 20000 + NOTES AREA WHERE TCE CONCENTRATION IS
M l LOCATIONS APPROXIMATE INTERPOLATED THERE IS NO TCE
BASE PUN DEVELOPED FROM DATA FROM THESE AREAS
1 TOWN OF WUUSION PARCEL BOUNOART MAP (SHIPPED 121597) PROVIDED ST (VS (BURUNCTON VT) IN DXF FORMAT
2 PLAN DEVELOPED BT HEINDEL AND NOTES (BURUNCTON VT) FOR THE BATES PROPER1Y 1NVESIBAT10N AND PROVIDED TO THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION HASTE MANAGEMENT DIVISION 1997
3 ORTHOPHOTO SHEET 100216 VERMONT STATE MAPPING PROJECT 1988
4 TORN OF WIUJSTON ASSESSORS MAP 1997
5 VARIOUS SITE PUVQ CN RLE WITH THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION WASTE HMUGElENr OOVBON
6 DM FROM JOHNSON DD REPORT UNTIED GROUNDWXIER IHVESI1CAH0M ALLWC INDUSTRIAL PARK DATED 7 W FDR THE VT DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Modeled Site - Existing Conditions copy H
pound n Williston Vermont o CHECKED MS HSI
DRAFTED RMK GEOTRANS FU fa-Site-mod-ECdwg 4 - 1 A TITIA T t n HBVAIT
DATE 10600
5 COMPARATIVE EVALUATION OF ALTERNATIVES
The purpose of this section is to compare the remedial alternatives on the basis ofthe
evaluation criteria developed and discussed in Section 4 and provide a recommended alternative
These criteria include overall protection of human health and the environment short-term
effectiveness reduction of toxicity mobility or volume long-term effectiveness and
permanence compliance with ARARs implementability and cost
The comparative analysis is conducted to highlight significant differences between
identified alternatives All alternatives for the Study Area groundwater except the no-action
alternative include the following
bull monitoring would be done at selected locations to evaluate spatial and temporal
trends in groundwater quality
bull institutional controls would be implemented to maintain the sump venting at Lot
3-30 on South Browneil Road
bull restrictions would be placed on any new buildings with basements constructed
within the region of VOC-contaminated groundwater and
bull institutional controls would be implemented to prevent the installation of wells for
potable supplies within the region of VOC-contaminated groundwater
The no-action alternative is not included in the comparison provided in the following
sections since it would not meet the RAOs All four ofthe remaining alternatives would meet
the RAOs stated in Section 32
51 SHORT-TERM EFFECTIVENESS
Protection of Workers and the Community Groundwater would be monitored under all
scenarios to look for any changes in VOC concentration which might result in increased risk
The containment options in Alternatives 2 3 and 5 would be more protective ofthe community
FOR ALLING INDUSTRIAL PARK MWP_DOCSN75320MAUINOFSWWI0030929WPD 5 - 1 HSI GSOTrSflS IflC
MITEC 104e 02415
if the region of VOC-contaminated groundwater were shown to be expanding and presenting
increased risk However in the event that the region of VOC-contaminated groundwater is not
expanding Alternative 4 would be equally protective Under all options a HASP would be
prepared and in conformance with OSHA regulations site workers would be trained required to
wear appropriate protective equipment and as applicable would be enrolled in a medical
monitoring program Alternatives 2 3 and 5 would involve normal construction hazards during
installation of pumping wells piping trenches treatment enclosures permeable reactive barrier
trenches or planting of trees In addition under Alternative 5 release of VOCs to air through
transpiration may need to be measured to prevent creation of a new exposure pathway and health
risk through air
Environmental Impacts Minor additional impacts may occur during installation of
Alternatives 2 3 and 5 due to dust and sediment production Groundwater would need to be
treated to regulatory discharge limits before discharge under Alternative 2 and treatment may be
temporarily hampered in the event of treatment system mechanical failure Because ofthe
experimental nature of phytoremediation greater uncertainty exists that the trees will be effective
in acting as a barrier to expansion ofthe region of contaminated groundwater to the unnamed
brook under Alternative 5 If it is shown that expansion ofthe region of contaminated
groundwater toward the unnamed brook poses a future health risk additional measures may
become necessary to contain the contaminated groundwater
Time to Achieve Remedial Action Objectives None ofthe alternatives has an appreciably
shorter time frame than the others in reducing groundwater concentrations to VT Groundwater
Enforcement Standards and VT Water Quality Criteria This is because while Alternatives 2 3
and 5 rely on engineered remedies to contain the region of contaminated groundwater residual
TCE DNAPL and geologic heterogenieties will cause the contaminant source to persist for an
extended time As discussed in Section 34 active DNAPL removal alternatives were removed
during the preliminary screening DNAPL has never been directly observed at the Study Area
and is assumed to be present based on dissolved concentrations of TCE DNAPL distribution is
FOR ALLING INDUSTRIAL PARK MWP_DOCSW753200OALLINOFS9-00M0O30929wPD 5-2 HSI GGOTr3nS IflC
MITEC 104e 02416
expected to occur heterogeneously at residual saturation and it is infeasible to locate the DNAPL
to treat it directly Because of this each ofthe remedies is expected to exceed the two-year time
frame for short term effectiveness
52 R E D U C T I O N O F T O X I C I T Y M O B I L I T Y O R V O L U M E T H R O U G H
T R E A T M E N T
Treatment All ofthe proposed alternatives would treat the residual DNAPL source of
contamination through dissolution and natural gradient flushing While Alternatives 2 3 and 5
are intended primarily for containment and not groundwater restoration these alternatives would
actively treat some concentrations in groundwater
Reduction in Toxicity Mobility or Volume The containment Alternatives 2 3 and 5
may result in decreased mobility ofthe region of contaminated groundwater However
groundwater monitoring may show that the region of contaminated groundwater is not
expanding under existing conditions If this were the case containment would not result in any
additional decrease in size ofthe region of VOC-contaminated groundwater
Since Alternatives 2 3 and 5 treat concentrations in groundwater without treating the
residual DNAPL source and the amount of contaminants that can be removed from groundwater
by these methods would likely equal the amount added by continued dissolution ofthe DNAPL
sources alternatives 2 3 and 5 would not result in a greater reduction in the total volume of
contaminant than Alternative 4
Amount of Material Contained or Treated As described above the amount of material
contained under Alternatives 2 3 and 5 would not be any greater than under Alternative 4 unless
the size ofthe region of VOC-contaminated groundwater is not presently contained by natural
attenuation If natural attenuation is currently controlling the size ofthe region of VOC-
contaminated groundwater then the amount of contaminants being removed by natural processes
equals the amount added by dissolution of residual DNAPL In this case intercepting and
removing contaminants from the groundwater using one ofthe containment alternatives will not
result in a significant increase in the amount of contaminant treated
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000ALUNOFS9-OOUM30929WPD 5-3 HSI GGOTrdHS jflC
MITEC 104e 02417
53 LONG-TERM EFFECTIVENESS
Residual Risk Implementing institutional controls to maintain the sump venting at Lot 3shy
30 on South Browneil Road to restrict construction of buildings with basements below the water
table within the region of VOC-contaminated groundwater and to control the use of groundwater
for potable purposes within the region of VOC-contaminated groundwater would provide
protection against the potential for exposure to existing concentrations in groundwater
Therefore despite the fact that some ofthe remedial alternatives may be required to operate for
an extended time the residual risk associated with any ofthe alternatives would be minimal
Adequacy and Reliability of Controls Alternative 5 has the least reliable controls
because ofthe difficulty in predicting the effectiveness of phytoremediation The second least
reliable alternative would be Alternative 2 because of its reliance on mechanical equipment to
maintain containment and to meet discharge standards
Permanence of Remedy All ofthe proposed alternatives would rely on permanent
destruction of contaminants through natural attenuation over time If one ofthe containment
technologies are required maintenance and periodic replacement would be necessary to ensure
containment was maintained until expansion ofthe region of VOC-contaminated groundwater
was no longer a threat This maintenance would be straight-forward and easy to continue for any
of the containment alternatives
54 COMPLIANCE WITH ARARs
All ofthe alternatives would eventually reduce contaminant concentrations within the
current region of contaminated groundwater to below VT Groundwater Enforcement Standards
and VT Water Quality Criteria
55 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Each ofthe alternatives would rely on groundwater monitoring and institutional controls
on venting basement sumps at Lot 3-30 on South Browneil Road restrictions on the construction
of new basements below the water table within the region of VOC-contaminated groundwater
FOR ALLING INDUSTRIAL PARK MWPJX3CSN7S3UOOOAUJNGFS9-OOUM30929wro 5-4 HSI GOTr3nS IflC
MITEC 104e 02418
and potable use of groundwater from within the region of VOC-contaminated groundwater to
maintain conditions protective of human health and the environment If monitoring shows that
natural attenuation is not restricting the size ofthe region of VOC-contaminated groundwater
then one ofthe containment alternatives would be more protective than Alternative 4
56 IMPLEMENTABILITY
The most easily implemented alternativewould be Alternative 4 as it would not require
any installation but only groundwater monitoring to gauge the progress of natural attenuation
Alternative 5 requires all the components of Alternative 4 and adds trees along the unnamed
brook Alternatives 2 and 3 are the most difficult to implement as they require disruptive and
invasive installation techniques However the necessary equipment materials workers and
specialists required to implement all the alternatives are available
57 COSTS
The present worth costs range form a low of $163083 for Alternative 4 to a high of
$2287474 for the containment option of Alternative 3 These present worth costs were based on
a 30-year service period and an annual discount rate of seven percent
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALLINOFS9-OOM0030929WPD 5-5 HSI GGOTfaDS IflC
MITEC 104e 02419
6 PREFERRED REMEDY
61 PREFERRED REMEDY
Alternatives 2 34 and 5 are all protective of human health and the environment and rely
on the following technologies
bull groundwater monitoring to evaluate spatial and temporal trends in VOC
concentration
institutional controls to maintain the sump venting at Lot 3-30 on South Browneil
Road
restrictions on the construction of new buildings within the region of VOC-
contaminated groundwater to prevent unacceptable concentrations of volatile
compounds in indoor air and
institutional controls to restrict the use of groundwater for potable purposes within
the region of VOC-contaminated groundwater
All ofthe alternatives rely on dissolution and natural gradient flushing to treat the
residual DNAPL source of groundwater contamination Therefore none ofthe alternatives has
an appreciably shorter time frame than the others in reducing groundwater concentrations to VT
Groundwater Enforcement Standards and VT Water Quality Criteria
Alternative 4 includes remediation by natural attenuation There is no active containment
technology associated with Alternative 4 As such it is simpler less costly and easier to
implement than Alternatives 2 3 and 5 which include some form of active containment ofthe
region of VOC-contaminated groundwater Containment could become necessary under
Alternative 4 if future groundwater quality monitoring indicates the region of VOC-contaminated
groundwater is impacting a sensitive receptor or is expanding in size and not contained by natural
attenuation The SIR (HSI GeoTrans 2000) risk assessment (Menzie Cura 2000a and 2000b)
showed that under current conditions groundwater was not impacting any receptors to a degree
FOR ALLING INDUSTRIAL PARK MWPJXXrSN7532000ALUNcFS9-OOU0030929WO 6 - 1 HSI GSOTraflS jflC
MITEC 104e 02420
that would represent a human health risk or risk to the environment Therefore containment is
not necessary to protect any sensitive receptors currently being impacted by the region of
contaminated groundwater Continued groundwater monitoring is required to demonstrate
whether the region of VOC-contaminated groundwater is stable in size or expanding
Alternative 4 has been selected as the preferred remedy On-going monitoring ofthe
effectiveness of natural attenuation in containing and remediating the region of VOC-
contaminated groundwater is part ofthe remedy Further details on this proposed monitoring are
provided in Section 62 If monitoring shows that size ofthe VOC-contaminated region is not
contained by natural attenuation then one ofthe other technologies could be used to supplement
Alternative 4 based on the nature ofthe expansion ofthe region of contaminated groundwater
If monitoring data indicates that VOC concentrations in the groundwater discharging to the
unnamed brook have increased and pose an unacceptable risk to human health and the
environment then phytoremediation could be considered in this location Phytoremediation
would be less costly than installation of a permeable reactive barrier or active groundwater
extraction system Phytoremediation would be ineffective in containing expansion ofthe region
of contaminated groundwater in the rest ofthe Study Area however because contaminated
groundwater is further below ground surface in these regions and phytoremediation is limited by
the depth ofthe roots ofthe selected plant If monitoring data indicates that the southwestern
portion ofthe region of VOC-contaminated groundwater is expanding then Alternative 4 could
be supplemented with extraction wells or a PRB for hydraulic containment
62 MONITORING PROGRAM
In its guidance document Use of Monitored Natural Attenuation at Superfund RCRA
Corrective Action and Underground Storage Tank Sites (EPA 1999) EPA states that long-term
performance monitoring will be a fundamental component of any remedy which relies on
monitored natural attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSW532000 A1XINOFS9-00 I0030929 WPO 6-2 HSI GSOTrSDS IMC
MITEC 104e 02421
The SIR (HSI GeoTrans 2000) concluded that there were not sufficient temporal data to
determine whether the region of VOC-contaminated groundwater was stable in size or
expanding Continued monitoring for the compounds of concern will be necessary to confirm
that the region of VOC-contaminated groundwater is not expanding Table 6-1 identifies
locations which are proposed to be monitored annually to evaluate spatial and temporal trends in
VOC concentration These locations are shown in Figure 6-1
There are several mechanisms by which natural attenuation occurs These include
dilution of contaminant concentrations sorption ofthe contaminant onto the soil matrix and
biodegradation ofthe contaminant to a less toxic form Further study is necessary to determine
the contribution of each of these mechanisms to overall attenuation ofthe area of VOC
contamination
Evidence of biodegradation can be obtained by collecting three types of data of increasing
complexity (National Research Council 1993)
bull documentation of contaminant loss or transformation in the field
bull the presence of electron donors and acceptors andor alteration of groundwater
chemistry consistent with intrinsic biodegradation processes and
microcosm studies which provide direct microbiological evidence that indigenous
bacteria are capable of mediating the contaminant transformations observed
Microcosm studies are typically not employed unless the contaminant is unique or the
transformation which is being observed is not well documented in the literature For the
transformations anticipated in the Study Area numerous laboratory and field studies have
established that naturally-occurring bacteria are capable of mediating the contaminant
transformations of contaminants of concern For that reason microcosm studies will not be
performed as part of this study
FOR ALLING INDUSTRIAL PARK MWP_DOCSN7532000ALUNOFS9^)OM0030929 WPO 6-3 HSI GSOTrSHS jflC
MITEC 104e 02422
Of particular concern to the determination of biodegradation is the delineation of aerobic
and anaerobic zones within the contaminant area because these zones dictate the types of
biological degradation that would be expected to occur Oxygen is the primary electron acceptor
during aerobic oxidation Anaerobic processes including denitrification iron-reduction sulfate-
reduction and methanogenesis occur in the absence of oxygen and use nitrate iron (III) sulfate
and carbon dioxide respectively as primary electron acceptors Reductive dehalogenation of
TCE has been observed under iron-reducing sulfate-reducing and methanogenic conditions
although very low redox (ie methanogenic) conditions may be necessary for production of
ethene and ethane
Further sampling and analysis of selected parameters in groundwater will be conducted to
assess the potential for biodegradation in accordance with EPAs Technical Protocol for
Evaluating Natural Attenuation of Chlorinated Solvents in Ground Water (EPA 1998) The
twelve sampling locations shown in Table 6-1 used to monitor ofthe area of VOC contamination
will also be sampled for parameters used to evaluate biodegradation The parameters include
compounds of concern and compounds which are degradation products ofthe compounds of
concern shown in Table 6-2 Table 6-3 lists parameters chosen to evaluate the presence of
electron donors and a groundwater chemical environment conducive to biologic reductive
dechlorination These parameters will be sampled once unless evaluation ofthe data indicates
that further sampling would be beneficial to calculate a rate of attenuation
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753V2000ALUNCFS9JraquoM0030929 WPD 6-4 HSI GSOTfaHS IDC
MITEC 104e 02423
Table 6-1 Sampling locations
LOCATION
ID
ASI-32D2
RB-1
ASI-26D2
ASI-I6D2
ASI-13D2
ASI-23D2
ASI-18D2
ASI-12D2
ASI-01D2
ASI-09D2
U-TRIB-5
SW-I
Notes BGS =
SCREENED
INTERVAL
DEPTH BGS
35-40
35-40
35-40
30-35
31-36
25-30
32-37
35-40
31-36
31-36
surface
surface
Below Ground Surface
RATIONALE
Upgradient of region of highest VOC concentrations
Closest to lot 19-11 former lagoon and septic leach field source areas
Within area of highest concentrations
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient of source area within region of VOC concentrations in southwest direction
Downgradient ofthe region of VOC concentrations in the southwest direction
Downgradient of source area within region of VOC concentrations in southeast direction
Downgradient of source area within region of VOC concentrations in southeast direction
At downgradient edge of region of VOC concentrations in southeast direction
Stream upgradient of VOC discharge from groundwater
Stream at location of VOC discharge from groundwater
(
FOR ALLING INDUSTRIAL PARK MWP DOCSN7532000ALUNCFS9^X)VI0030929WPO 6-5 HSI GeoTrans inc
MITEC 104e 02424
Table 6-2 VOC analytes
PARAMETER
TCE
PCE
11-DCE
cis 12-DCE
trans 12-DCE
Vinyl Chloride
Benzene
Toluene
Ethylbenzene
Xylenes
ANALYTICAL METHOD
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
SW 8260A
8260A
8260A
8260A
8260A
RATIONALE |
Contaminant of Concern
Contaminant of Concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
daughter product of biodegradation of
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
contaminant of concern
Notes SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical
Methods SW-846 US EPA 3ri edition 1986
TCE = Trichloroethene
PCE = Tetrachloroethene
11-DCE = 11-Dichloroethene
cis 12-DCE = cis 12-Dichloroethene
trans 12-DCE = trans 1 2-Dichloroethene
FOR ALLING INDUSTRIAL PARK MAWP DOCSN75320laquoMLUNOFS9^XM0030929WPO 6-6 HSI GeoTrans inc
MITEC 104e 02425
Table 6-3 Parameters to evaluate biodegradation
PARAMETER ANALYTICAL METHOD RATIONALE
Field Parameters
Alkalinity as CaCO Hach Alkalinity Test Kit Model ALP Positive correlation between microbial activity and
MG-L alkalinity Measures the buffering capability of
groundwater
Total Ferrous Iron Hach Method 8146 May indicate anerobic degradation
Dissolved Hydrogen Reducing Gas Detector Predicts possibility for reductive dechlorination
Dissolved Oxygen Direct Meter Reading Indicates probability of aerobic vs aerobic
degradation
PH Direct Meter Reading Aerobic and anaerobic biological processes are pH
sensitive
Redox potential (Eh) A2580B An indicator ofthe relative tendency of a solution
to accept or transfer electrons
Specific Conductivity Direct Meter Reading Used to determine when purging of a well for
sampling is complete
Temperature Direct Meter Reading Affects the metabolic activity of bacteria and the
solubility of dissolved gasses
Laboratory Analyses
Dissolved Organic Carbon SW 9060 Carbon and energy source which can drive
dechlorination
Nitrate-N IC Method E300 At higher concentrations may compete with
reductive pathway
Total Manganese EPA 2007 or 2009 To determine if anaerobic biological activity is
solubilizing Mn for the aquifer matrix
Chloride SW 9250 Can be used as a conservative tracer to estimate
biodegredation rates
Sulfate IC Method E300 May be used as an electron acceptor for
biodegradation after dissolved oxygen and nitrate
are depleted
Sulfide IC Method E300 Indicates if reductive pathway is possible
Ethane SW 3810 Modified Daughter product of Ethene
Ethene SW 3810 Modified Daughter product of Vinyl Chloride
Methane SW 3810 Modified Ultimate reductive daughter product
Notes Rationales taken from USEPA 1998
Hach refers to Hach Company Catalogue
A refers to Standard Methods for the Examination of Water and (fostewater 18 edition 1992
E refers to Methods for Chemical Analysis of Water and Wastes US EPA 1983
SW refers to the Test Methods for Evaluating Solid Waste Physical and Chemical Methods SW-846 US EPA 31 edition
1986
FOR ALLING INDUSTRIAL PARK | C I nr A^Twmrmr bullbullltlaquo MWP DOCSN7532000ALLINCFS9-0Ol0030929wro 6-7
MITEC 104e 02426
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REFERENCES
Brinkerd 1996 Site Investigation Ailing Industrial Park Williston Vermont April to
September 1996 October 1996
Fitts C R 1997 TWODAN documentation prepared by Dr Charles Fitts Scarborough Maine
Griffin 1995 Monitor Well Log (MW-4) and Analytical Data Bove-Fagan Ice Cream
Distribution Investigation Williston VT Griffin International Inc
HSI GeoTrans Inc 2000 Site Investigation Report June 15 2000
Johnson 1999 Limited Groundwater Investigation N753 July 6 1999
Menzie Cura 2000a Screening Level Risk Characterization April 2000
Menzie Cura 2000b Addendum to Screening Level Risk Characterization June 1 2000
NRC 1993 National Research Council Committee on Bioremediation In Situ Bioremediation
When Does it Work Washington DC National Academy Press 1993
TRC 1993 Site Inspection-Ailing Industrial Park Williston Vermont VTD982748477 Final
Report
US EPA 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies
Under CERCLA OSWER Directive 93553-01
U S EPA 1992 Estimating Potential for Occurrence of DNAPL at Superfund Sites OSWER
Number 93554-07FS 9p
FOR ALLING INDUSTRIAL PARK MWP_DOCSW75JV20(XKALUNOFS9-0(AI0030929WPD 7 - 1 HSI GeOTTSHS irtC
MITEC 104e 02428
US EPA 1993 Guidance for Evaluating the Technical Impractibility of Groundwater
Restoration EPA540-R-93-080
US EPA 1998 Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents
in Ground Water EPA600R-9812~8
US EPA 1999 Use of Monitored Natural Attenuation at Superfund RCRA Corrective Action
and Underground Storage Tank Sites EPA Directive 92004-17P
US EPA 2000 Introduction to Phytoremediation EPA600R-99107
VTDEC 1996 Site Investigation Guidance August 1996
VTDEC 1997 Chapter 12 Groundwater Protection Rule and Strategy October 1997
VTDEC 2000 Vermont Water Quality Standards March 2000
FOR ALLING INDUSTRIAL PARK MWP_DOCSN753200(AAUJNGFS9^)OM0030929WPD 7-2 HSI GSOTfanS tC
MITEC I04e 02429
APPENDIX A
TWODAN INPUT FILES
FOR ALUNG INDUSTRIAL PARK MWP_DOCSVN7S3200(AALUNOFS9-0(AI0030929WPO HSi GfiOTfanS WC
MITEC 104e 02430
i - i i a a o U 0 t A X H i d t l Z 018J UaiUEAJJLKATia Htj v j pound
50-oo
4 e s y lt lt 4 A M ^ L S m m 9 m mdash t j y m
MITEC 104e 02431
15
6 Lancaster County Road HSI Harvard Massachusetts
GEOTRANS 01451 A TETRA TECH COMPANY 97^772-7557 FAX 978-772-6183
R E C E i ^ D PNN753-001
CUTLER A8TANPIELD Campltf December 11997
Mr Michael Smith Vermont Department of Environmental Conservation Waste Management Division 103 South Main Street Waterbury VT 05671-0404
Subject Proposed Surface Water Sampling MITEC Site Williston VT
Dear Michael
This letter describes the proposed surface water sampling at the MITEC site that we discussed during our meeting of November 201997 Our intention is to complete this work as soon as possible to avoid the complications of colder weather and possible freezing ofthe stream My understanding is that you are prepared to review and approve this plan fairly quickly and also to assist us with obtaining property access and appropriate maps to locate these sampling sites We appreciate this help In future we anticipate that the constraints of weather will not require such an expedited field mobilization process and that we will all have more time to prepare
Purpose and Extent of Sampling
The purpose ofthe surface water sampling is to further assess impacts to the unnamed tributary and to make preliminary inferences regarding the extent ofthe TCE plume currently migrating to the southeast across the Ailing Industrial Park by measuring the effects of its discharge to the stream To this end sampling locations have been chosen to 1) provide better spatial resolution in the area east of Commerce Street toward its southern end (SW-1 SW-2 SW-3 and S W-5) 2) assess the quality of surface water contributed by other tributaries (SW-4 SW-6) and 3) make preliminary estimates ofthe downgradient extent of impacts (SW-7 and SW-8) Samples from previously established sampling locations UTrib-6 7 8 1014 and 18 will also be obtained A total of 14 samples will be collected The proposed sampling locations
L-W7jni20iiooonl
MITEC 104e 02432
Michael Smith 2 December 11997
are indicated on the attached maps which depict the site at two different scales The first is a site map taken from the Binkerd report and shows the previous sampling locations east of Commerce Street as well as proposed new locations SW-1 SW-2 and SW-3 The second map shows the site and the surrounding area including the more downstream locations
Methods
At each proposed location a number of water quality indicators will be measured including temperature pH redox potential dissolved oxygen and conductivity Samples for volatile organic compound (VOC) analysis will be obtained in triplicate using a stainless steel sampling container samples will be transferred immediately to 40 mL glass vials with teflon septa and preserved with hydrochloric acid Each sample will be submitted to a local analytical laboratory for a screening level analysis of VOCs Three selected samples will also be analyzed using EPA Method 8260 The appropriate level of documentation will be generated for these samples such that laboratory analytical results can be validated to EPA Region 1 level Tier II This will require the collection and analysis of a duplicate sample a trip blank a field blank and matrix spikematrix spike duplicate samples
Sincerely
f i t mdash Peter ZeebPhD Senior Hydrogeologist
cc Sandy Feldman Sheila Jones
PZmm
m w MITEC 104e 02433
HSI GEOTRANS
LEGEND O Honrtorog Veil
A GeoProb Sortg
Figure 11 Station location map O Surface Water
Qfor monitoring wells borings and surface water MITEC 104e
02434
HD BINKERD ENVIRONMENTAL
HSI bull bull
GEOTRANS if prsTAOC
6 Cancaster County Road
A TETRA TECH COMPANY
Harvard Massachusetts 01451 faL32 HMETER 3 4 r t
Sheila Jones Esq Cutler and Stanfield 700 Fourteenth Street NW Washington DC 200052010
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Harvard Massachusetts 01451 GEOTRANS
A T E T R A T E C H C O M P A N Y 978-772-7557 FAX 978-772-6183
PN N753-002
May 111999 RECEIVED
MAY t 3 1999 Mr Michael Smith
CUTLER ampSTANrlc-uAgency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Dear Mike
Based on the site walkover and well inventory ofthe existing monitoring well network completed on April 201999 HSI GeoTrans determined that several monitoring wells proposed for sampling and monitoring in the Work Plan are not accessible or are damaged or missing Outlined below are the actions we will undertake to resolve the outstanding issues with the monitoring well network
As ofthe date of this letter access to the Bates well network has not been obtained The Work Plan identified eleven off property well clusters installed by the Bates and two wells installed by the State on the Bates property to be included in the sampling and monitoring activities for the Site Investigation (BW-2 BW-5 BW-7 BW-8 BW-9 BW-11 BW-12 BWshy13 BW-17 BW-18 BW-19) Ten ofthe off property clusters were included in the sampling plan and all eleven were included in the site water level round The wells installed by the State on the Bates property were included in the both sampling and water level rounds Replacement of eight ofthe well clusters slated for groundwater sampling is recommended (BW-5 BW-8 BW-9 BWshy12 BW-13 BW-17 BW-18 BW-19) The remaining Bates wells do not require replacement in order to achieve the goals ofthe Site Investigation Note that two ofthe original well clusters in the Work Plan BW-17 and BW-18 have been destroyed and would require replacement even if access is granted by Bates In addition HSI GeoTrans well clusters had already been proposed adjacent to BW-2 BW-7 and BW-11 and will provide the required data at these locations
It is our understanding that the two monitoring wells installed by the State on the Bates property JB-1 and JB-2 are accessible to the State for sampling and water level monitoring and that the State will sample and monitor these wells to fulfill the goals ofthe Site Investigation IF this is not the case please let me know at your earliest convenience
M WP DOCS NT^VWMiSimbW wpd
MITEC 104e 02438
Mr Michael Smith 2 May 11 1999
Several ofthe remaining wells (BF-1 BF-3 NO-2 and OE-1) were observed to be damaged during the inspection We propose to repair the wells which have been damaged The repairs will involve installation of protective casing or road boxes re-development and reshysurveying of the new measuring points The other wells are missing and presumed destroyed (ARC-2 ARC-3 BF-2 BM-2 MB-1 PO-SOUTH and RB-1) We believe that only monitoring wells MB-1 and MB-1 A require replacement The remaining wells that could not be located during the site inspection do not require replacement in order to achieve the goals ofthe Site Investigation
Based on our telephone conference on May 10 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MWgt_DOCSN753l9Wlaquo310l600raquopd M l 1 XA ~r
02439
HSI GEOTRANS
Mr Michael Smith 3 May 11 1999
bcc Sheila Jones
snwp_DocjN7sni9wcmoi6i)iraquoplti TVflTEC 1046
02440
HSI GEOTRANS
X_l ^ T 6 Lancaster Countv Road
Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-11 i 5
PN N753-002
June 25 1999
Mr Michael Smith Agency of Natural Resources Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Work Plan Modifications Ailing Industrial Park Site Williston VT
Dear Mike
This letter documents changes to the work plan for the Ailing Industrial Park Site in accordance with a telephone conference between you myself and Peter Zeeb On the results of the Site Investigation to date as well as additional data collection by the DEC we agreed that several revisions to the work plan are warranted The revisions for the work plan include the location and method of installation for the bedrock monitoring wells and the sampling of shallow monitoring wells recently installed Outlined below are the revisions to the specific tasks that we will undertake
Re-location of Bedrock Monitoring Weil BR-1
The DECs Source Area investigative work in the original location of BR-1 identified high levels (100 mgL) of VOCs present at or near the silt clay interface DEC believes that drilling through the clay layer in this location creates an unacceptable risk ofthe migration of contaminants into the underlying units HSI GeoTrans will relocate the bedrock well BR-1 adjacent to ASI-16 as located on the attached site plan
Bedrock Well Installation Method
Geophysical work at the site has refined our estimation of the depth to bedrock Depth to bedrock was initially anticipated to be greater than 150 feet below ground surface We currently anticipate bedrock at 100 to 140 feet below ground surface The shallower depth to Bedrock will
M AWPDOCStfnSIMnWUJIIW mft
MITEC 104e 02441
Mr Michael Smith 2 June 25 1999
enable us to reduce the size ofthe pilot hole needed for the well installation At locations BR-1 and BR-2 drillers will advance and set 4 in casing several feet into the clay unit and chop and wash the annulus ofthe casing All cuttings and wash water will be contained for proper disposal The casing will be refilled with potable water and the hole will be advanced with a 3 in roller bit When telescoping becomes necessary to prevent caving 3 in casing will be installed The 3 in casing will be advanced to the bedrock surface and seated The coring of bedrock will follow the original work plan specifications
Shallow Monitoring Well Sampling
The field GC water quality data obtained during small diameter installation at the site has demonstrated that contaminant concentrations in the upper portion ofthe aquifer to be low (lt 10 MgL) or non-detect in most locations This has led to the revision of our sampling plan Select shallow wells will be sampled to confirm the field GC data If these data are confirmed the low level and none detect shallow wells will not be sampled The shallow wells to be used for confirmation sampling are listed below
ASI-01 ASI-02 ASI-03 ASI-05 ASI-08 ASI-10 ASM 2 ASI-08
Based on our telephone conference on June 24 1999 it is my understanding that you agree with our proposed course of action described above If that is not the case please contact me immediately
Sincerely
Michael J Jordan Project Hydrogeologist
MJJcas
MXTECl04e 02442
HSI GEOTRANS
Mr Michael Smith 3 June 25 1999
bcc Sheila Jones
MITEC I04e
02443
HSI GEOTRANS
1 0 T 2 shyCylty
T-TCT 6 Lancaster County Road _ _ _ Harvard Massachusetts
GEOTRANS OH 5 1
A TETRA TECH COMPANY 978-772-7557 FAX 978-772-6183
PN 753-010
July 9 1999
Mr Michael Smith Agency of Natural Resources Vermont Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Subject Bedrock Monitoring Well Installation Ailing Industrial Park Site Williston VT
Dear Michael
On July 8 we became aware that a drill casing was advanced through the sand clay and till strata at the Ailing Industrial Park (site) without being sealed at the sandclay interface Although for the reasons described below we do not believe any vertical migration of contaminates occurred this method of drilling is contrary to the work plan for the site Therefore we are notifying you of this incident
On June 4 shallow direct push monitoring wells were installed at location ASI-06 where a deeper bedrock monitoring well is planned Groundwater quality profiling data from this location is provided on the attached boring log TCE is present in groundwater here at concentrations as high as 2270 ugl at 31 - 36 ft below ground surface (bgs) decreasing to 262 ugL at 41 - 44 ft bgs A soil boring (D-2) was advanced at this location on June 22 Field screening data from soil samples obtained in this boring are also provided on the attached log As apparent from the log fine to medium sand occurs to a depth of approximately 15 ft at this location grading to silt at depth A clay layer is encountered at 40 ft bgs Glacial till is present from 57 to 100 ft bgs where the bedrock surface is located Prior to drilling through the clay and glacial till a direct push well screen was advanced through the clay and into the till to a depth of 58 bgs and no groundwater recharge to the well screen occurred at any of five sampling depths
MWP_DOCSN753 199M7M1600 wpd
MITEC 104e 02444
Mr Michael Smith 2 July 9 1999
Drilling of bedrock monitoring well BR-2 began on June 29 Four inch casing was advanced to a depth of 44 ft and sealed within the clay layer Three inch casing was then advanced through the till layer to the bedrock surface During seating ofthe casing in the bedrock the casing was damaged and was subsequently withdrawn from the borehole
On July 7 a different drill rig was used to continue drilling the same location In accordance with both the drillers proposal to HSI GeoTrans and the work plan for the site investigation the driller was to seat a casing in the clay establish a seal and drill through the clay and till with smaller casing prior to coring bedrock Instead the drilling contractor withdrew the previously installed four inch casing without grouting it changed the drive shoe on the casing to a spin shoe and advanced the four inch casing directly to the bedrock surface Upon arrival at the site to log the coring of bedrock on July 8 HSI GeoTrans ascertained that the borehole had not been sealed at the clay surface prior to drilling deeper as was specified HSI GeoTrans then instructed the drilling contractor to immediately remove the casing and to seal the borehole with grout in the process
It is our intention to have a new drilling contractor complete the installation of BR-2 at an adjacent location in a manner that limits the potential for introducing contaminated unconsolidated deposits groundwater to the bedrock as specified in the work plan for this site investigation Within one week of completing the installation of BR-2 groundwater quality data collected from BR-2 will be evaluated with respect to the potential for contaminant migration along the unsealed borehole that existed at this location for approximately 24 hours As the casing was advanced by spinning providing a relatively good seal between the casing wall and the formation we do not anticipate that vertical migration along the casing was significant
If you have any questions regarding this letter please contact me at (978) 772-7557
Sincerely yours
Peter Zeeb PhD Senior Hydrogeologist
PZcas
MWP OOCSVN7S3M999070ll600wpri
MITEC 104e 02445
HSI GEOTRANS
1 HSI | 9pound9TPpoundSpound SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
LOCATION Williston VT CASING TYPEDIAMETER None
DRILUNG METHOD Drive and Wash Direct Push SCREEN TYPESLOT None
SAMPLING METHOD ss shelbv GRAVEL PACK TYPE None
GROUND ELEVATION GROUT TYPEQUANTITY Bentonite Portland Slurry
TOP OF CASING DEPTH TO WATER
LOGGED BY NSB GROUND WATER ELEVATION
REMARKS This log compiles the results o the all methods used to comolete the borehole over its entire depth
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O2-SS02 4 7 11 8
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O2-SS03 2 0 41 1
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WOR AWOR WOR - 3 0 shyD2-SS06 4 921 WOR
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X1 2 3
Continued Next Page 1 OF 3 02446
HSI GEOTRANS SOIL BORING LOG BR-02 A T E T R A T E C H C O M P A N Y
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
9 gtshyOC
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Medium Grey dayey SILT wet poorly graded
D2-SS09 4 S
28 1572
3 6
D2-SS10 WOR 1 18 13
4 6
D2-SS11 3 3 20 NO Medium Grey CLAY wet poorly graded 262
4 5
BR2-SS01 1 2 20 ND Soft Olive Grey CLAY moist laminated coheisive 2 4
BR2-SS02 20 NO
- 5 0 -
BR2-SS03 20 NO - 5 5 -
Dense Light olive Grey sandy GRAVEL w few fines
BR2-SS04 16 19 24
ND
bull60
moist poorly graded
21
Very dense Light olive Grey gravelly SAND w little fines moist well graded angular
BR2-SS05 40 51
13 ND 6 5 shy
60 66
I-7 0 shySO BR2-SS06 11 ND 50 100
5000
MITEC 104e 02447
Continued Next Page PAGE 2 OF 3
HSI GEOTRANS A T E T R A T E C H C O M P A N Y SOIL BORING LOG BR-02
PROJECT NUMBER N753
PROJECT NAME Ailing Industrial Park DATE DRILLED 62999 - 7999
Continued from Previous Page
a UJ
Q
05
i i m u
gt ac ui gtO bdquo UJ 3 oc S
o o
0 CO UJ _ Q pound LL C5
LITH0L0GIC DESCRIPTION 9 LU O
BR2-SS07 81 1004
10 NO E 8 0 shy
BR2-SS08 30 59 68
16 ND w8 5 shy
BR2-SS09 1005 NO 9 0 shy
BR2-SS10 89 1944
ND E bull95shy
- 1 0 0 shyND
Limestone
MITEC 104e 02448
PAGE 3 OF 3
Mr Michael Smith 3 July 9 1999
bcc Sheila Jones bcc Jerry Amman
MWPJXXSN753M9MW70J160Owpd
MITEC 104e 02449
6 Lancaster Countv Road HSI Harvard Massachusetts
GEOTRANS A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6 I i 5
PN N753-014
Septembers 1999
Mr Michael Smith Agency of Natural Resource Department of Environmental Conservation Waste Management Division 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in die Site Investigation Ailing Industrial Park Williston IT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and die Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation ore outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste waler lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot IV-11 using small-diameter wells and afield GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
bull perform one day ofwellpoint permeability testing at selected monitoring wells
mwFDocwsiMwwwnoootd MITEC 104e 02450
Mr Michael Smith September 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
M l T ECl04e 02451
U laquo OOCTN791Mtm01IOOOraquofrl
HSI GEOTRANS
HSI GEOTRANS
6 Lancaster County Road Harvard Massachusetts
01451
A TETRA TECH C O M P A N Y 978-772-7557 FAX 978-772-6183
PNN753-014
Septembers 1999 amp y gt
Mr Michael Smith D oJ Agency of Natural Resource Km Jt Department of Environmental Conservation i j f i l Waste Management Division ft y^y( 103 South Main StreetWest Building Waterbury VT 05671-0404
Re Ailing Industrial Park ft Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants The collection of field data to date has determined the extent ofthe dissolved phase contamination emanating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) At this time we believe it is necessary to investigate the suspected source area located on lot 19-11 The source investigation would require access to the property owned by Beatrice Ailing The access to the property has been denied on several attempts by HSI GeoTrans and the Vermont Department of Environmental Conservation Upon the granting of permission HSI GeoTrans would require approximately one week of onsite work to perform a limited source area investigation The activities to be included in the source area investigation are outlined below
bull perform site reconnaissance including surveying and sampling of selected existing monitoring wells
bull perform a single day GPR survey to identify leachfield septic or cesspool location remnants of waste water lagoon and any other subsurface anomalies
bull perform one day of groundwater profiling in the suspected source zone on Lot 19-11 using small-diameter wells and a field GC
bull perform two days of soil sampling and well installation within the suspected source zone on lot 19-11 using a GeoProbe sampling rig
MITEC 104e perform one day ofwellpoint permeability testing at selected monitoring wells 02452
000060 MlWP_OOCSN73Iirmraquo01|rngtlaquo|gtl
Mr Michael Smith Septembers 1999
We hope that this summary is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJcas
MITEC 104e 02453
000061 Mwr_cocS4miinmogtmoltsri
HSI GEOTRANS
T T Q T 6 Lancaster County Road ^ Harvard Massachusetts
GEOTRANS laquolaquo A TETRA TECH-COMPANY 978-772-7557 FAX 978-772-6183
PNN753-014
October 151999
Mr Michael Smith vZ Agency of Natural Resource J Department of Environmental Conservation Waste Management Division I 103 South Main StreetWest Building j Waterbury VT 05671-0404
Re Ailing Industrial Park Source Area Investigation
Dear Michael
The Site Investigation into the nature and extent ofthe contamination at the Ailing Industrial Park has focused on the areal distribution of contaminants Evaluation of field data has determined the extent ofthe dissolved phase contamination migrating from the suspected source area defined in the Site Investigation Ailing Industrial Park Williston VT (Binkerd 1996) HSI GeoTrans will begin a Source Area Investigation on October 181999 to determine the nature and areal extent ofthe suspected contaminant source The investigation will be undertaken to gather the data necessary to complete the Site Investigation Report and the Feasibility Study which was set forth by the Agreement Between Mitec Telecom INC and Vermont Concerning the Ailing Industrial Park (1999) The Source Investigation will focus on the property owned by Beatrice Ailing and former MITEC lease hold (Lot 19-11 Williston plat map) and the area ofthe Ailing Industrial Park which has exhibited elevated contaminant concentrations during Site Investigation activities We are submitting this letter to The Vermont Department of Conservation(VTDEC) as an addendum to the approved Site Investigation Work Plan The addendum Source Investigation Work Plan will outline the tasks and methodologies to be utilized during the investigative work
Jack Guswa and I met with you on September 101999 to present the plans to investigate the suspected source area in the Ailing Industrial Park You agreed with the additional work as presented with the addition of two upgradient wells to be located to the west ofthe suspected source area (Figurel-1 ASI-30 and ASI-31) The VTDEC also agreed during the meeting to arrange access to the property for the Source Area Investigation The VTDEC and HSI GeoTrans were subsequently granted access to the property on September 111999 In addition to the work presented at the meeting it is necessary to preform a 72 hour pump test to characterize the
000054 MwrDOCSW79JimMOUIIOOpd
MITEC 104e 02454
Mr Michael Smith 2 October 151999
hydrologic conditions at the site The additional Source Area Investigation activities to be undertaken are presented below
Site Reconnaissance Ground Penetrating Radar (GPR) Survey Monitoring Well and Soil Boring Installation Low Flow Groundwater Sampling Hydraulic Characterization
The additional field work attributed to the Source Area Investigation will follow the standard operating procedures presented in the approved Site Investigation Work Plan (HSI GeoTrans 1999) The locations ofthe proposed well cluster installations and GPR survey are presented on Figure 1-1 The well cluster locations presented in Figure 1-1 were finalized during the September meeting between HSI GeoTrans and the VTDEC The GPR survey and hydraulic characterization tasks are presented below The Source Area Investigation field work will be completed within two week after its initiation The task specific outlines are presented below
Site Reconnaissance
The monitoring wells to be included in the site reconnaissance are monitoring wells MI-1 MI-2 MI-6 and RB-2 The monitoring wells on Lot 19-11 will be surveyed to a common datum with the existing site wide survey data Well integrity testing consisting of depth to bottom water level and visual inspection ofthe wells will be preformed Groundwater samples will be collected from selected monitoring wells based on the integrity testing Samples will be collected by the Low Flow Protocol set forth in the Site Investigation Work Plan (HSI GeoTrans 1999)
GPR Survey
A GPR survey will be preformed to identify on-site leach field septic tank or cesspool location remnants of waste water lagoon and any other subsurface anomalies We propose to use a 5 foot by 5 foot orthogonal grid survey to detect any near surface anomalies which exist on Lot 19-11 Geophysics GPR International will be performing the survey and will be utilizing a GSSI SR10 ground penetrating radar system with a high resolution 500 MHz antenna and a deep-penetration 100 MHZ antenna Any GPR response which indicate buried metal objects will be investigated with a Fisher TW6 pipe locator to augment the radar data All data will be analyzed in the field by GPR personnel and presented to HSI GeoTrans field personnel to determine the optimal location for well cluster ASI-28 If several anomalies are detected the VTDEC and HSI GeoTrans will evaluate the anomalies and modify the work plan accordingly
Well Installation and Soil Boring Advancement MITEC 104e 02455
The well clustes will consist of a small diameter shallow monitoring well and a deeper conventional well screened across the zone of highest concentration Well cluster installation will be performed in accordance with the Site Investigation Work Plan (HSI GeoTrans 1999) yjth 0 0 5 5
MWP_DOCSK731IW9M OOSIIOOprl
HSI GEOTRANS
Mr Michael Smith 3 October 151999
the exception ofthe deep wells The site conditions observed during previous field work prohibit the use of standard commercially available screen slot sizes The deep wells will be advanced by a large diameter Geoprobereg rod and installed using an outer filter sock to prohibit the infiltration offine sediments in to the well The well cluster installations will be performed jointly by Checkpoint Environmental and Twin State Environmental HSI GeoTrans will be provide oversite ofthe contractors and analysis of groundwater samples using afield Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999) The rationale for the selected well cluster locations is presented below
Monitoring well clusters ASI-25 through ASI-27 are located down gradient ofthe suspected source area The well clusters will be installed to more adequately define the areal extent ofthe concentrated portion ofthe contaminant plume A single soil boring will be advanced at location ASI-26 The soil boring will be screened as it is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-28 will be located after the GPR survey has been completed shyThe cluster will help define the suspected source area and the vertical migration of contaminants in the area The location will be determined in thefield after review ofthe GPR survey is completed The location will be based on any anomalies observed in the GPR data A single soil boring will be advanced at location ASI-28 The soil will be screened with a Flame Ionization Detector as the soil boring is advanced The screening will follow the procedures outlined in the Site Investigation Work Plan (HSI GeoTrans 1999) including all NAPL screening safeguards to prevent the downgradient migration of any DNAPL sources
Monitoring well cluster ASI-29 will be located upgradient ofthe suspected source area The cluster will define the upgradient boundary andor any additional upgradient source areas The ASI-29 well will be paired with the existing shallow monitoring well AL-14
Monitoring well clusters ASI-30 and ASI-31 will be installed to the west cross gradient from the suspected source area to document the areal distribution of dissolved phase contamination emanatingfrom the Ailing Industrial Park The locations selected for these wells should define the northwestern and western extent of contamination
Low Flow Sampling
The additional monitoring well clusters will be sampled in accordance with the approved Site Investigation Work Plan (HSI GeoTrans 1999) Lowflow sampling procedures will be used to sample the newly installed deep wells in their respective clusters ASI-25 through ASI-31
MITEC 104e 02456
000056 MWP_DOCSgtK15JlWMOWllltraquoraquoprl
HSI GEOTRANS
Mr Michael Smith 4 October 151999
Hydraulic Characterization
HSI GeoTrans will conduct a 72 hour pumping test on the deep well at cluster ASM 2 The test is being undertaken to more adequately characterize hydraulic conditions at the site The data from this test will be used in the evaluation of remedial alternatives in the Feasibility Study The pump test will be performed as a step-drawdown test The pumping rates will ultimately be determined in the field from observed conditions Preliminary calculations indicate that pumping rates of 2 5 and 10 gallons per minute will be necessary to achieve the desired drawdown at observation wells The water level data will be recorded at observation wells ASI-06 ASI-13 ASI-25 ASI-26 NO-1 NO-2 and NO-3 The water level data will be recorded using pressure transducers and dataloggers
The effluent water from the pumping test will be treated by liquid phase granular activated carbon filters provided by Carbtrol Inc Two 175 pound carbon filters will be connected in series to treat the pump test effluent The effluent will be discharged to the unnamed brook upon approval from Randy Bean ofthe VTDEC The effluent will be periodically sampled between the carbon units and at the discharge point to detect break through ofthe carbon units The effluent samples will be analyzed utilizing a field Gas Chromatagraph (see Site Investigation Work Plan (HSI GeoTrans 1999)) If the effluent sample between the carbon canisters exceeds 1000 ugL Trichloroethene (TCE) the discharge point sample will be analyzed If concentration of TCE in the discharge point sample exceed 300 ugl the test will be discontinued
We hope that this letter addendum to the Site Investigation Work Plan for the Source Investigation is sufficient for your needs If you should have any questions please call Jack Guswa or me
Sincerely
Michael Jordan Project Hydrogeologist
Enclosure
cc Sheila Jones
MJJmm MITEC I04e
02457
000057 MWFDOCSN731imu00SI 100 bullpd
HSI GEOTRANS
JHSTUART March 1 1985
Agency of Environmental Conservation D e partment of Water Resources und
E nvironmental Engineering H a z a r d o u s Materials Management Program A t t n John A m i d o n H y d r o g e o l o g i s t M o n t p e l i e r Vermont 05602
R e M I T E C Systems Corp W i l liston
Dear J o h n
During our meeting at MITEC on February 20th you noted that some additional information was needed to c omplete the initial phase of testing as well as the d o c umentation of the activities under takentodate Outline d~ beTow-Ts ~t h e~1 n f o r m a ti o n t h a t y o u r e q u e s t shyed
1 Attac hed here to is the plan used to install the grou ndwat er moni t o r s collection and analysis of the grou ndwa t er samp les for metals and organics and the extr actio n of and testing of soils from the area of the dispo sal site 2 A rev ised sit e pla n has been incl uded refl ecting the new well posi tions and the e leva t ions of t he top of t he mo ni to r s and th e groundwa ter 1e vels as of F e shybr ua ry 0th As note d in our m ost r ecent tel ephone conv i on th e lat ter have r isen 14-15 inc hes as er sa t the It o f th e rec ent thaw Two copie s of the resu plan be f orw ar ded to Winslo w Lad ue as req uested will and pla ns t 0 sur vey all ho uses on Br owne 11 Rd MITEC _tp tain if there are ajiy shallo w wel I sources ltis ce r with e dr aina ge ar ea a f fecte d by the 1agoo n in th 3 ngla nd Ma r ine C o m r a c t o r has been con tacted New E for remo va 1 of th e lagoon soil a nd co ntra c tural the ar ra nts wil 1 be concluded du r ing t he comi ng ngeme week if ic at io n of work comme nceme nt wi II be proshy Not vide your off ice i n advance d to t m Resul t s of th e met als and or genies are expected shor tiy
f rom IEA and will be fo rwarded to your ofshyf ice oon as a va i la ble as s 5 R esul t
s fr om t he pr e vious soi 1 and water sampling have inc 1 ude d bee n
CIVIL 4 EfViROUMEI-L pound l j i t fcHpound P ) OGA lt i f r l h r l h w i l l n-- i i U - iO l i l ) bU i l I
MITEC 104e 02458
s
MITEC Page 2 March 1 1985
If you have any questions please do not hesitate to contact me
Stuart PE
JHSocc
MITEC 104e 02459
MITEC Systems Corporation Williston Vermont
Soil and Water Sampling Program
1 Install groundwater monitors at nine (9) locashytions consisting of two (2) inch inside diameter PJpound with ten (10) feet of factory slotted pipe extending into the groundwater and terminating with a minimum of two (2) feet above ground level and capped
2 Establish elevations of the groundwater monitors for the top of each pipe and the groundwater elevashytion for each for a specific date Due to the shalshylow depth to groundwater from 51-112 inches the level is established by graduated tape and a light Each measurement will be performed a minimum of three times to assure accuracy to within one-eighth inch The location of each well and the established elevations will be represented on a general site plan showing the MITEC property
3 Groundwater samples are to be collected from each well on the same date by pump or baling Prior to - k ~ -~-|1bdquo--bdquobdquo f bdquo k bdquobdquobdquobdquobullbdquo ltv~ 11 1 1 v bdquo bdquo bdquo
acidification for metals preservation to assure ac curacy of the test results All samples are to be analyzed for copper cadmium nickel cyanide pH conductivity total chromium and hexavalent chrome
U Soil samples are to be collected as follows
GWM09 Saturated zone (aaprox 5) Overburden East side lagoon Composite from
two holes 5 apart-at-1 bullbull2 bullbull A below the-sur=mdash face and one in the saturated zone
North wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface 1 into the saturated zone
South wall of lagoon at flood level Composhysite from two holes A apart at 1 and 2 below the surface I1 into the saturated zone
Bottom of lagoon Composite offour test holes 8 apart one in the unsaturated zone
MITEC 104e 02460
MITEC Sampling Program
All samples are to be analyzed for the same constituents as required of the water testing
5 Collect separate samples of the groundwater after the above referenced purging process for storage in air-tight vials The samples which are to be colshylected from wells A-9 with only 5 and 7 analyzed initially by the GCMS- EPA method 62A If organics are detected in the first samples testing must be performed on 4 and 8 as well
6 All sampling will be performed with a State repshyresentative on-site and results of the testing to be forwarded to the State as soon as available
7 The contaminated soil within the lagoon will be removed by a Vermont certified contractor for disposhysal in an approved wastedepository The top one (1) foot of soil from the flood level and below will be extracted during the process
MITEC 104e 02461
i
o H
ON f J
o
bull I I bull
HA
OOO
x x z
bull
MITEC 104e 02463
WK miui w ci ivnui II i ici ILUI ujiyitb inc iii PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5108
ANALYSIS REPORT
Customer j H S c u a r t Associates Date 26 February 1985
Address P gt 0 gt B o x 3 6 7 Date Samples Received
Ci ty S t a t e Zip Essex Center VT 05A15 20 February^1985
Customer Order Nomber
Attent ion J o h n S t u a r t
Station 9
J
2
3
A
5
6
7
8
9
poundH
5A
58
52
5A
A5
53
53
55
59
j MITEC
Conductivity U mbos ( 25degC)
206
A18
21A
176__
208
230
205
16A
265
GROUNDWATER ANALYSIS
O01 0 OS bull
Cadmium Total Chromium (mRl) (mRl)
0A1 lt0025
006- 270
00A 012
bull005 189
005 023
001 lt0025
lt0C Hexavalent Chromium (mKI)
bull
lt0025
239
005
183
lt0025
lt0025
ampo
Zinc (mKl)
005
0A0
032
015
OU
003
Note Organic analyses to follow in two weeks
cc John Amadon
Signature jJfcrryyS 7lrifrylC
Offices ond loborotones located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02464
if jsznoi U hnvironmentol jiolysts Inc PO Dox 626 bull Essex Junction Vermont 05452 bull 802-878-5138
ANALYSIS REPORT
Customer J H Stuart Associates Date 21 December 1984
Address PO Box 367 Date Samples Received 14 December 1984
City State Zip Essex Center VT 05451 Customer Order Number
Attention John Stuart
WATER ANALYSIS
PH 52 57 50 53 45 34
Conductivity (pmhos 25degC) 213 420 152 167 202 bull 225
O l Cadmium (mgl) lt001 lt001 001 v 028 bull 005 003
o pound Chromium Total (ng1) lt0025 lt0025 lt0025 lt0025 2-35 v 014 - -bullbull - bull - -bull V 013 bull^Chromium Hexavalent (mgl)1 0 11
gt1p Copper (mgl) lt002 lt002 lt002 lt002 bull 084 004
Q Cyanide (mgl) lt0005 lt0005 lt0005 lt0005 bull -lt0005 lt000E
Z Nickel (mgl) lt0025 lt0025 lt0025 lt0025 bull 010 003
fO 2inc (mgl) 0J1 UU1 0U3 001 038 030
Hexavalent chromium was only analyzed when total chromium was present
Signature fmnigt Mji fnt f VncL 7
Offices and laboratories located in Essex Junction Vermont Research Triangle Pork North Carolina
MITEC 104e 02465
bull i
ANALYSIS REPORT
Customer J H Stuart Associates Date 22 January 1985
Address PO Box 367 Date Samples Received 14 December 1984
Ci ty State Zip Essex Center VT 05415 Customer Order Number
Attent ion John Stuart
bull shy
bull bull mdash bull bull bull bull bull - bull bull bull bull shy SOIL ANALYSIS1
Hexavalent Cyanide Chromium Chromium Cadmium Copper Nickel Zinc
poundH bull (mgl) (mgl) (mq1) bull (mq1) (mq1) (mgl) (bullmgl) -
2 442 lt0005 lt0025 lt0025 lt 001 lt 002 015 006
4 402 lt0005 lt0025 lt0025 lt 001 lt 002 lt002 001
7 504 lt0005 lt0025 lt0025 lt001 lt002 lt002 001
8 486 lt0005 lt0025 lt0025 lt001 lt002 lt002 bull 008
9 441 lt0005 lt0025 lt0025 lt001 lt602 lt002 004
10 444 0005 lt0025 lt0025 lt001 lt002 lt002 006
11 498 lt0005 lt0025 lt0025 lt001 003 lt002 009
30 532 lt0005 lt0025 008 lt001 005 lt002 010
31 544 lt0005 lt0025 lt0025 lt001 002 056 003
32 472 lt0005 lt0025 lt0025 lt001 lt002 024 003
36 536 0008 lt0025 011 lt001 005 lt002 011
37 490 lt0005 lt0025 lt0025 lt001 021 lt002 009
38 391 lt0005 0276 032 lt001 050 lt002 011
41 416 lt0005 0108 018 001 229 lt002 o5i
42 395 lt0005 0399 041 lt001 039 lt002 014
i
Signature Ltrf(7( ni W0 6M Analysis of EP toxicity extract
Offices ond loborotoriei locoted in Essex Junction Vermont Reseorch Triongle Pork North Corolino
MITEC 104e 02466
JHSTUART
A p r i l 2 9 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Hazardous Waste Materials Program Attn Cedric Sanborn Environmental Engineer Montpelier Vermont 05602
Re Mitec Systems Williston
Dear Cedric
I was phoned by David Gee today and informed that a truckload of the contaminated material was removed from the lagoon area as the result of a previous commitment entered into by Mitec Due to conflicting information about Mitecs responsibilities at this juncture I am recommending that any further work cease until a realistic program be agreed to by both parties I base that on the following
1 Following the trial pre-hearing the State was inshystructed to contact Mitec to develop a schedule for further dialogue and actions connected with the reshyhabilitation of the lagoon site To my knowledge there has not been any such attempt made on the part of the State to resolve issues that need clarificashytion
2 On April 18th I forwarded a letter to you outlinshying some new information with recommendations That correspondence has not been addressed yet Mitec has been ordered to continue with the soil removal
3 A letter from John Amadon on April 23rd notes the organic sampling to be invalid due to the time lapse and the method of storing the samples We do not take issue with this position however there is apshyparently some question about the validity of the GCMS method of analysis We have been instructed to re-sample but now there is a question about whether we should employ GC or GCMS
A On numerous occasions we have expressed the deshysire to tailor the soil removal process to a minimum
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 3C7 ESSEX CTR VERMONT 05451 TELEPHONE 802 876 bull 5171
MITEC 104e 02467
L
Mitec Page 2 April 29 1985
2- bull number of truckloads as they are projected to cost about $4000 for each load Mitec being in a startshyup phase of their operation cannot approach this operation with a blank check Chris Stone who was on hand today to represent the State indicated that many more loads may be necessary to effectively rid the site of contamination
Too many questions surround this project for my clishyent to understand his responsibilities and ultimate costs The requirements issued by your office either in writing or verbally on-site have changed repeatshyedly and unless we can mutually agree to a reasonshyable program that is connrifpH rnmdashyr r i ng Mitec has no other option but to let the court decide the isshysue
Again keep in mind there are questions that we feel must be resolved in order to reach a satisfactory conclusion
1 Provided that all Browneil Road houses are connected to the CWD system and thereby reshymoved from any threat of groundwater conshy
- p tamination what level of soil contamination is permissible From this limitation provishyded we concur as to its reasonableness an approximation can be developed as to how many loads of soil must be removed
2 If the soil is to be removed why is it neshyy cessary to conduct organics sampling unless
i t~ i s tne ulterior motive ot the State to direct renovation of the groundwater as well If that is the case the process will now be more expensive than at the outset due to the mobilization of the contaminants
3 If the contaminated soil is to be removed whv is additional groundwater monitoring
pound bull necessary Documentation of the degree of dilution is not considered acceptable
A If organic testing is to be performed y_hich -- method of analysis is to be used
As soon as we can receive a response to the quest-
MITEC 104e 02468
I um laquoi i laquo m mdash n r r j mdash i mdash
Mitec Page 3 April 29 1985
ions at hand then further discussion with the State will dnsue Also please be advised that at the dishyrection of Mitec all future correspondence communishycations requests for information or notification of site vists are to be forwarded to my office We also request that one person in your office be designated to process such information
tuart PE
JHSocc cc Mitec
Robert Cronin Esq
MITEC 104e 02469
jmfMraquoi w i f u m i
A u u raquo laquo F pound raquo laquobull= -
B C f U S t B C INC ENVIRONv i bullbullbull bullbull
5 GREEN MOUNTAIN DRIVE SOUTH BURLINGTON VERMONT 05401 TELEPHONE (802) 658-1074
February 17 1984
I I Mr Cedric Sanborn i
of Environmental Conservationi AgencAgencyy ox ampnvifoiuneniai Lonservdciun I i Dept of Water Resources and
Environmental Engineering Montpelier VT 05602
Dear Mr Sanborn j i
RE Mitec Clean-Up 84011 j
I am writing this letter to inform you of the work that has been completed thus far at Mitec Systems Corp The discharge of i rinsewater into the lagoon has stopped and the rinsewater is being batched and treated at Aquatec as I described in my letter to Stan Corneille dated February 3 1984
Although the chemical reduction and precipatation process works bull bull
very well we have found that the cost for design installation j septic design and installation and permit reviews is far above | Mitecs budget Aquatec has looked at a second alternative for bull the treatment and reduction of rinsewater that being ion exchange J The ion exchange system will be purchased from a vendor and will bull be installed by Aquatec to accomodate Mitecs rinsewater volumes i The rinsewater will be recirculated and will not require any discharge hence there will be no need for subsurface disposal [ permits I will send you specifications on the system and resins j that will be used I
The proposal for the out-door clean up work is enclosed Mr Kucer is currently discussing the cost estimate with his Montreal office I see no reason to intiate this work as soon as I get formal approval from your office and from Mitec
Please feel free to call me if you should have any questions
Sincerely
liytrl Zi [U$) John R Deigo Project Engineer
Enclosure cc Mr Steven Kucer
Hydrographic Studies and Analyses bull Water Quality Studies raquo Analytical Laboratories Ecological Studies bull Aquatic Nuisance Control - Industrial Waste Surveys
MITEC 104e 02472
Recommended Treatment of Rinsewater
Mitec System Corporation
Prepared By
Aquatec Inc
South Burlington Vermont
January 23 1984
MITEC 104e 02473
RE Mitec Groundwater Cleanup - 84011
The treatment of rinsewater will consist of a three stage rinse system with a batch chemical reduction treatment process Parts submersed in chromic acid solutions will be rinsed in a primary rinse bath The primary rinse bath will be a closed system and considered a rough rinse
The secondary rinse bath will also be a closed rinse system The third and final rinse will be a continuous overflow system Effluent from the tertiary system will flow directly into the septic system Tertiary effluent limits must be less than 005 mgl (ppm) before entering an underground septic system
The primary rinse bath will eventually become saturated with chromic acid solutions and require periodic batch treatment When the primary rinse water becomes spent it will be transferred into a 250 gal polyethylene plating tank The rinse water from the secondary rinse bath will be transferred into the primary rinse bath and the secondary bath will be refilled with fresh rinse water
When the tank reaches 80 of its capacity treatment will be initiated The treatment will consist of reducing hexavalent chromium to trivalent chromium by the addition of anhydrous sodium sulfite to a pH of lt2 The amount of sodium sulfite added will depend on the concentration and volume of rinsewater to be treated A portable electric mixer will be attached to the tank to ensure proper mixing The rinsewater in the reduced form will be gravity fed into a second 250 gallon polypropylene plating tank where lime will be added precipatlng out trivalent chromium as well as other heavy metals The mixer should be used to agitate the solution when the lime is added The mixer should be removed and the solids allowed to settle Once the solids have completely settled the treated water will be pumped into the tertiary effluent to allow for further dilution before it is discharged into a septic system
Periodic sampling of effluent waters should be incorporated to ensure that rinsewater discharged does not exceed 005 mgl (ppm)
Sludge will be properly stored and eventually disposed of by a certified hazardous waste carrier
MITEC 104e 02474
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Wildlife and Department of Forests Parks and Recreation Environmental Engineering Department of Water Resources amp Environmental Engineering Natural Resources Conservation Council State Geologist
January 4 1984
3 2ampov~ loo Mr J H Stuart
f i 2 Sm ^
P O Box 3 67 - - l ^ J ^ S M J Essec Center Vt 05451
SUBJECT Mitec Z 0~npJ^
1 o
Dear J o h n
I appreciate your sending me a copy of the recent Mitec water quality results It appears that there remains a detrimenshytal affect of the lagoon on the downgradient groundwater quality This is best demonstrated with the pH and chrome data While it appears that the downgradient well 5 has higher metalic concenshytration then well 6 in the middle of the lagoon I believe the Well 5 results are anamously high due to the turbidity or solids that we saw in the sample In talking with Cathy Cutting of IEA sample 5 was not filtered prior to acid digestion for the AAS analysis ^^
I would suggest that well s 4 5 and 6be resampled and analyzed along with the wells installed on CecT 17 amp 18 We would like to have a representative of our office on site when the sampling is performed so please contact me when a purging and sampling date is set in the near future The groundwater sample from test well 6 that you helped me obtain on December 17 with the teflon bailer was confirmed by our laboratory to contain volatile organics Therefore you must include the volatile orshyganics assay done by JGCMSjas a part of your analysis plan Adshyditionally I would suggest that you review the appropriate protocol for groundwater sampling and obtain the necessary equipshyment A sampling and analysis plan must be submitted for our apshyproval prior to commencing this second round of sampling The plan should be submitted by January 18 1985 with the sampling done within one month of our approval Please feel free to conshytact me with any comments or questions you may have
R f n r mdash i 1 Off ices - BarreEssex J c t P i t t s f o r d N Spr ing f ie ld S t Johnsbury
MITEC 104e 02844
J H Stuart Page 2
I do look forward to reviewing the results of the soils asshysays along with your report outlining the sampling protocol sampling locations data interpretations and projected course of action based on the results
Very truly yours
John F Amadon Hydrogeologist Hazardous Materials Management Program
JFAkp
cc Meredith Wright AG
MITEC 104e 02845
b v
HSTUART ASSOCIATES September 10 1984
Agency of Environmental Conservation Department of Water Resources and Environmental Engineering Air and Solid Waste Programs Attn Cedric Sanborn Air Pollution Control Engineer Montpelier Vermont 05602
Re M I T E C Corporation Williston Vermont
Dear Cedric
As Che result of our conversation on September 7th I am forwarding the information Chat we discussed
The CesCing program format was prepared prior Co our disshycussion and will be altered slightly based on some inforshymation that was collected
A boring was established in the cencer of Che disposal pic and Che wacer Cable as well as che Impeding layer were found to be located at 29 Inches below the surface The shallow depth will allow us co place addicional wells in che area co accuracely depicc Che groundwacer copography
The plan submiCCed herewith provides general information abouc che locaclon of che plane propercy lines and sugshygested positions for Che monitors The final location of che laccer will be decermined in che field once we collect more data on water table elevations
As we are most anxious to proceed with the program your expeditious review and responsewill be most appreciated
SCuart PE
JHSadt
cc David Gee MITEC
CIVIL ENVIRONMENTAL ENGINEERS 120 LAKE STREET BURLINGTON VERMONT 0S401 TELEPHONE 802-8640094
MITEC 104e 02846
State of Vermont
AGENCY OF ENVIRONMENTAL CONSERVATION
Montpelier Vermont 05602 Department of Water Resources
Department of Fish and Game and Department of Forests Parks and Recreation
Department of Water Resources amp Environmental Engineering Environmental Engineering Natural Resources Conservation Council
September 19 1984
Mr John H Stuart PE JH Stuart Associates 120 Lake Street Burlington Vermont 05401
RE MITEC Project
Dear Mr Stuart
Chris Stone and I have reviewed the proposed soil sampling and groundwater monitoring plan for Mitec A summary of comments follows
1) The site plan did not show the location of the soil sampling sites Also we felt that additional boringmonitoring sites should be made closer to the facility The map has been re-marked to reflect these additional sites
2) It was not clear as to why the monitoring wells are to be installed 5 feet into the impeding layer However at least one boring should be made into the impeding layer to detershymine its thickness
3) Permeability tests should be performed on at least four of the test holes to determine aquifer characteristics
4) Since the water table is apparently close to the surface we feel that factory slotted pipe would be appropriate for the final monitoring wells
5) All soil1 ft 5 ft
samples 10 ft or
shouldto imp
be eding
takenlayer
at whic
depthshever
of comes
first
MITEC 104e 02847
Mr JH Stuart -2- September 19 1984
6) In addition to the soil sample in the center of the former lagoon four other locations within 2 feet of the edge of the lagoon must be sampled These locations are marked on the enclosed map
7) The State regulations do not address a level below which the metals are no longer hazardous as is done by EPA Toxicity Levels The level of contamination that is acceptable to the State is determined on a case by case basis
8) The analysis for chromium should include both hexavalent and total chromium
If you have any questions regarding our comments do not hesitate to contact us at 828-3395shy
Sincere
Sanborn C h r i s t o p h e r T Stone Environmental Engineer Hydrogeo log i s t Hazardous M a t e r i a l s Hazardous M a t e r i a l s Management Program Management Program
c r s - c t s a d e n c l o s u r e
MITEC 104e 02848
JHSTUART November 9 1984
Agency of Environmencal Conservation Deparcmenc of Wacer Resources and
Environmencal Engineering Hazardous MaCerials Management Program Attn Cedric Sanborn Environmental Engineer Mnotpelier Vermont 05602
Re M I T E C Corporation Williston Vermonc
Dear Cedric
There has been an apparent misunderstanding regarding your letter of September 19 1984 as soil and wacer sampling has been commenced ac che above location A call was placed Co your office on October 30th or 31sc and a message lefc for you indicating that we would begin on November 6ch at 8 AM
In the afternoon of November 6th I telephoned Chris Scone co inform him of our progress On che following morning you notishyfied MITEC that approval to begin had not been granced and chac work musC cease AC chac point we had completed che installashytion of five monitors and had extracted Cwo soil samples from the botcom of che wasce pic
On November 8ch I met with you and Chris to oucline che reshysulCs from our effores I was informed Chat we may have to inshystall one or Cwo additional monitors and Chac all future work muse be performed wich an Agency represenCacive in accendance
LaCe that afternoon Gerry Adams phoned Co notify me chat on short notice he was leaving to begin a large contract in rUasashychusetts and that it was unlikely that he would be back in the area for an extended period Had we been permitted to continue ttith our work on the 7th his portion of the project vould have been concluded
Enclosed you will find an updated version of the site plan orishyginally submitced wich my leCCer of Sepcember lOch A new plan will be developed buc Chis drawing will serve the purpose of locating existing and proposed wells
Whereas I am now withouc a drilling concracCor I would like chu
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05461 TELEPHONE 802 878 5171
MITEC 104e 02849
M I T E C Page 2 November 9 1984
authorization to determine groundwater elevations by auger and then establish one more monitor in a location agreed to by all che parcles I feel chac we have developed sufficient information co date to proceed in this manner
Furcher since Adams will noc be available I would also like Co extract che remaining soil samples wich a bucket auger IC can demonstrated chac che sample collected in chls manner will provide a good represencacion of che soil ac che level desired in Che profile
We are prepared co conclude chls phase of che sice evaluacion Samples from Che groundwacer monitors can be secured in a few days and I would like co follow wich che soil samples using che method described above
Please contact me at 878-5171 if you need additional informashytion
H Stuart PE
JHSadt
cc David Gee MITEC
MITEC 104e 02850
JHSTUART December 19 1984
M I T E C Corporation AtCn David Gee Manager IS Commerce Way Wllliscon Vermonc 05495
Dear David
Under Che Cerms of our agreemenc daced 10584 I wish Co proshyvide you wish an up-daCe of the project status
At the completion of 1219 we will have completed Items 1-4 as specified in the agreement specifically the soils sampling and initial set of water samples will have been collected and submitted for analysis As of chls momenC we still do not know the extent of the problem but will have a better indication once the test results are available in about a week My feelshying Is chac the problem is noc severe
We have compleCed all wells as prescribed however Che State is opting for an additional well Although the contract provides for only six the costs to date are below my target and it does not appear Chac any exCra will be necessary provided ChaC che driller concludes his work coday
The only work remaining afCer chls dace will be che collecCion of che second baCch of waCer samples and discussions wich Che State about any remedial action if necessary
Feel free to contacC me if you have any quescions
Regards
John H Stuart PE
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 878 bull 5171
MITEC 104e 02851
JHSTUART
M I T E C Corporation December 20 1984 ACCn David Gee Manager 15 Commerce Way Willaton VT 05495
Dear David
During our investigations yesterday Che work was completed on the additional monitor well as invoiced as well as drilling to the impeding layer The State decided however that two addishytional wells are required both of which will be Installed toshyday west of the Industrial park boundary line
A major change developed In Che method of testing the soils in the vicinity of the disposal pit that is not covered by our contract Instead of the four peripheral borings and one in Che center of che pic which would have produced flfceen soil samshyples che StaCe representatives decided Co require a different CesC paCCern Chac produced thirty seven samples I have collectshyed all of the samples but have Instructed the Cest lab to hold until authorization Is received Co proceed on Chls change as it Is a subsCanClal cost and will cause Che contract limit to be exceeded
Included is an invoice reflecting the additional wells the cost Co sample the groundwater for those monitors and the additional funds needed to run the soil tests I do not believe that any further surprises are in order
Regards
John H Stuart PE
JHSadt
CIVIL ft ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 06451 TELEPHONE 802 878 5171
MITEC 104e 02852
JHSTUART
December 28 1984
M I T E C Corporation Attn David Gee Manager 15 Commerce Way Williston VT 05495
Dear David
Enclosed are the results from the water quality analyses of the samples submitted to our lab I have noted in the left hand column the allowable limits for each element A copy of this information has been forwarded to John Ami-don per his request
There are several readings that are suspicious according to John The cadmium level in 4 may be an error and Che chromium found in 5 mosc likely Includes che CurbldlCy measured only in ChaC well Both should be resampled to confirm The cadmium and chromium levels in 06 exceed che allowable llmlCs but not excessively so The soil tesCs which have begun will reveal more about the ultimate disshyposition of these elemenCs
On the sewer Issue I spoke wich Frank Ailing again and his plans are Co now develop Che design and receive approval chis wincer for consCrucCion of the required Improvements this spring
JHSadt
CIVIL amp ENVIRONMENTAL ENGINEERS P O BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 5171
MITEC 104e 02853
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MITEC 104e 02855
JHSTUART January 28 1985
M I T E C Corporation Attn David Gee Manager 15 Commerce Drive WillistonVermont 05495
Dear David
On January 25th I met with John Amadon and Cedric Sanborn to discuss the contents of my 12385 letshyter The following resulted subject to confirmation by more senior members of the AEC staff
1 The water samples to be collected from wells 45 and 6 are to be checked for cadmium both chromiums and conductivity Wells 1 2 and 3 will be tested for conductivity and pH only
2 Samples will be collected from wells 4-9 for orshyganics but only wells 56 and 9 are to be checked at this time to determine the scope of contaminatshyion
3 The material to be removed from the pit is conshysidered as a hazardous waste and there are not any disposal sites located within Vermont certified to receive it I did obtain a listing of contractors that are approved for handling the material and I will provide this during our next meeting
4 Attached is a copy of the State lab results that address the organics problem
5 Based on the above we will have to amend our ashygreement to include the $1150 additional costs for the testing connected with Items 1 and 2
Call me if you have any questions
John H Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 raquo 878 bull 5171
MITEC 104e 02856
JHSTUART January 30 1985
Agency of Environmental Conservation Department of Water Resources and
Environmental Engineering Attn John Amadon Hydrogeologist Montpelier Vermont 05602
Re M I T E C
Dear John
I have had several discussions with MITEC relative to our meeting of last Friday In essence they have agreed to the program that you defined but with several provisos
They would like a letter from your office detailing the additional measures to be implemented together wich specific instructions as to what steps must be taken in the process of removing the contaminated soil
Further their acceptance to collect and sample for volatile organics is limited Perchloroethylene as I had indicated is not and has not been used by MITEC The materials stored on the premises as well as the list of suppliers for paints and solvents are available for inspection co corroborate that position MITEC will provide a complete analysis of all organics for the specified wells however fushyture testing for TCE will not be at the expense of MITEC unless its presence can be attributed to their operation
We are prepared to proceed as soon as we receive the requested notification
Stuart PE
JHSocc
CIVIL amp ENVIRONMENTAL ENGINEERS PO BOX 367 ESSEX CTR VERMONT 05451 TELEPHONE 802 bull 878 bull 5171
MITEC 104e 02857