Summit Environmental Consultants, Inc SDMS DocID 503999

summitenv.com

PN: 16819

January16, 2012

Mr. Kevin Heine US Environmental Protection Agency 5 post Office Square Boston, Massachusetts 02109-3912

RE: Investigation Plan Disposal Specialists, Inc. Landfill, Rockingham, Vermont

Dear Mr. Heine:

On behalf of Browning Ferris Industries (BFI), Summit Environmental Consultants, Inc. (Summit) is providing you two copies of an Investigation Plan for the Disposal Specialists, Inc. (DSI) Landfill in Rockingham, Vermont. This Investigation Plan has been prepared for your review in response to a letter from EPA to BF! dated October 18, 2012. The Plan addresses each of the items contained in the letter and includes a proposed implementation schedule.

Following your review of the Plan, we would be glad to discuss any comments or questions that you may have. In the meantime, feel free to contact me or Ralph Larimore of BFI with any questions.

Sincerely, SUMMIT ENVIRONMENTAL CONSULTANTS, INe.

~~ Michael A. Deyling, e.G., P.Hg. President, Principal Hydrogeologist

Cc: Ralph Larimore, BFI Joe Montello, BF!

Attachment

MAIN OFFICE: LEWISTON AUGUSTA BANGOR PORTLAND

640 Main Street 434 Cony Road 8 Harlow Street, Suite 4A 1 Industrial Way, Suite 7 Lewiston, ME 04240 Augusta, ME 04330 Bangor, ME 04401 Portland, ME 04103 207.795.6009 voice 207.621.8334 voice 207.262.9040 voice 207.221.6360 voice

207.795.6128 fax 207.626.9094 fax 207.262.9080 fax 207.221.6146 fax

Summit Environmental Consultants, Inc

INVESTIGATION PLAN DSI ROCKINGHAM LANDFILL

ROCKINGHAM,VERMONT

Prepared for: BROWNING FERRIS INDUSTRIES

5600 Niagara Falls Boulevard Niagara Falls, New York 14304-1532

Prepared by: SUMMIT ENVIRONMENTAL CONSULTANTS, INC.

640 Main Street Lewiston, Maine 04240

January 12, 2012 Project # 16819

INVESTIGATION PLAN DSI ROCKINGHAM LANDFILL

ROCKINGHAM, VERMONT

EXECUTIVE SUMMARY

In 1994 the U.s. Environmental Protection Agency (EPA) issued a Record of Decision (ROD) for the Site which presented remedial actions including capping of the landfill, installation of a landfill gas extraction system, operation of a Slope Stabilization and Seepage Control system, institutional controls and maintenance of the leachate collection system.

The ROD also established Interim Groundwater Cleanup Levels (IGCLs) to be achieved within 15 years following issuance of the ROD. The IGCLs define the restoration objectives for site groundwater.

Long term monitoring at the DSI landfill has been ongoing since the remedial measures were completed in 1995. Groundwater data collected since installation of the cover system indicate that concentrations of constituents of concem (COCs) have generally decreased, and significant milestones have been achieved consistent with the predictions of the Conceptual Site Model (CSM) presented in the Feasibility Study (URS 1994). Specifically:

• Water levels have declined within the majority of gas extraction wells in and around the landfill with 28 of the 38 gas extraction wells now dry and several of the remaining wells containing a few inches of water that may be related to condensation generated during gas extraction .

• Leachate generation rates associated with the leachate collection system have declined asymptotically and stabilized at approximately 0.1 to 0.2 gallons per minute (gpm) in the lined ash monofill portion of the landfill, with small seasonal fluctuations observed .

• Groundwater cleanup goals have been met in several monitoring wells; however, some volatile organic compounds (VOCs) and some metals have not met cleanup goals in several compliance monitoring wells.

Based upon a review of ground water quality data and water quality trends, it appears that IGCLs for arsenic, manganese, benzene, xylene and tetrachloroethene have not been met at all compliance monitoring locations.

Assessment of remedial technologies to cleanup fractured bedrock hydrogeologic systems suggests that these technologies will not be feasible or reliable with respect to meeting IGCLs at the Site. As a result, BFI is proposing to complete additional response actions for continued protection of human health and ecological receptors. This Plan has been

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prepared based on discussions with USEPA and VTDEC in 2011 following their most recent 5-Year Review Report completed DATE?

The additional actions discussed in this Investigation Plan include:

• Updating the Conceptual Site Model (CSM) to assess water quality trends, changes in Site conditions and the potential for the Site to meet clean up goals in the future.

• Establish binding provisions to supply potable water to the landowners on the properties downgradient of the landfill until cleanup goals are no longer exceeded. Provisions will include a funding mechanism for long-term maintenance and monitoring of the supply system.

• Confirm that the water supply system substantially meets existing codes for public water lines. [Note that the existing supply system is not regulated by the State of Vermont as a Public Supply because of the limited number of users and connections].

• Review the existing ground water quality monitoring program and establish an updated monitoring program until IGCLs are met.

• Expand the ground water reclassification boundary to include an additional property to the north of the existing boundary.

• Evaluate potential vapor intrUSion pathways related to structures located downgradient of the landfill.

A schedule to implement these actions, present results, and allow for review by EPA and Vermont Department of Environmental Conservation (VTDEC) is included in the Plan.

__________--'-In es"" n n n, OS! Landfill, Rockingham, Vermont __________""v"' tiq"'at""io!LL Pl aQ!J

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INVESTIGATION PLAN DSI ROCKINGHAM LANDFILL

ROCKINGHAM, VERMONT

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Site History

1.2 Purpose of the Investigation Plan

2.0 CONCEPTUAL SITE MODEL UPDATE

3.0 ENVIRONMNTAL COVENANT

4.0 POTABLE WATER SYSTEM DESIGN AND MAINTENANCE

5.0 GROUND WATER RECLASSIFICATION

6.0 LONG TERM MONITORING PLAN

7.0 VAPOR INTRUSION EVALUATION

8.0 IMPLEMENTATION SCHEDULE

FIGURES:

Figure 1 Site Location Figure 2 Site Plan Figure 3 Groundwater Reclassification Zone

APPENDICES:

Appendix A October 18, 2011 EPA Request for Additional Investigation Plan, Notice of Change in U.S. RPM, and November Site Visit

Investigation Plan, DSI landfill. Rockingham, Vermont

INVESTIGATION PLAN DSI ROCKINGHAM LANDFILL

ROCKINGHAM, VERMONT

1.0 INTRODUCTION

The Site is the BFI-Rockingham Landfill Superfund Site, also known as the Disposal Specialists, Inc. (DSI) landfill and contains an approximately 17 acre closed solid waste landfill. The Site is located along US Route 5, locally known as Missing Link Road, in the Town of Rockingham, Windham County, Vermont.

The closed landfill is located on a terrace approximately 500 feet west of the Connecticut River. Prior to landfill construction the Site was utilized as a borrow pit. Topography surrounding the Site consists of steeply dipping slopes that are generally unsuitable for development. Bedrock (phyllite of the Littleton Formation) is exposed immediately west of the Site, but the bedrock surface dips steeply to the east toward the Connecticut River. Glacial deposits overlie bedrock beneath and to the east of the landfill. The glacial deposits have been mapped as varved lacustrine deposits.

The surrounding area is rural, residential, and agricultural land. Four residences are located between the landfill and the Connecticut River. Three of the residences are supplied water by a private water line on BFI property. The fourth residence has a private water supply from a spring located upgradient of the Site on BFI property.

1.1 Site History

Prior to 1960 the Site was undeveloped woodland. From 1960 to 1968 the Site was developed as a borrow pit for construction materials. In 1968 Harry K. Shepard, Inc. created Disposal SpeCialists, Inc and operated a landfill at the Site. In 1973, BFI purchased DSI and Harry K. Shepard, Inc. and changed the Site name to Browning Ferris Industries of Vermont. The Site continued to operate as a municipal landfill until circa 1985 when receipt of waste ceased. From 1986 to 1989 a 1.5 acre lined ash monofill cell was developed for disposal of incinerator ash on the southeastern portion of the landfill.

In the late 1970's Vermont Department of Environmental Conservation (VTDEC) collected and analyzed ground water samples from several bedrock wells in the vicinity of the landfill and subsequently required DSI to supply water to 3 downgradient properties. During the 1980s, OS! undertook several hydrogeologic investigations to characterize Site conditions. In 1992 following negotiations with the U.s. Environmental Protection Agency (EPA) and VTDEC, a Remedial Investigation (RI) and Feasibility Study (FS) were completed. Between 1992 and 1994 remedial actions were

Investigation Plan, DSI Landfill, Rockingham, Vermont January 2012 Page 1

completed under EPA's Superfund Accelerated Cleanup Model (SACM). Remedial actions included:

• Installation of a multi-layer cover system on the landfill, • Installation of a Slope Stabilization and Seepage Control trench east of the

landfill, • Installation of a landfill gas extraction system, • Natural attenuation for observed ground water impacts, and • Establishing Institutional Controls to prevent or minimize risks to human health

and the environment.

In 1994 a Record of Decision (ROD) was signed that required maintenance of the remedial actions completed at the Site and established Interim Cleanup Goals (ICGs) for constituents exceeding State and Federal Primary Drinking Water Standards. ICGs were predicted to be met at compliance pOints within 15 years.

EPA conducted 5-year reviews in 1999, 2004 and 2009 to assess Site conditions and compliance with the ROD. These reviews concluded that the remedial actions and Site conditions were being properly maintained and that the Site remedy remained protective of human health and the environment. However, the third 5-year review noted that ICGs have not been met at all compliance points.

As a result, EPA, VTDEC and SFI have discussed options for maintaining protection of human health and ecological receptors in lieu of meeting ICGs. A meeting in March 2011 at EPA's offices in Boston, Massachusetts outlined additional actions that may be appropriate for the Site. In a letter dated October 18, 2011, EPA requested that BFI prepare an Investigation Plan, based on discussions at the March 2011 meeting that describes additional actions required for protection of human health and the environment. A copy of the EPA letter is attached as Appendix A.

1.2 PURPOSE OF THE INVESTIGATION PLAN

The purpose of this Investigation Plan is to present proposed actions, describe how the actions will be implemented and develop a schedule for implementation. The actions being proposed and discussed below include:

• Updating the Conceptual Site Model (CSM) to assess water quality trends, changes in Site conditions and the potential for the Site to meet clean up goals in the future.

• Continue to supply potable water to the landowners on the properties downgradient of the landfill until cleanup goals are met. Establish binding provisions to supply potable water and establish a funding mechanism for long­term maintenance and monitoring of the supply system.

I nvestigation Plan, DSI Landfi ll , Rockingham, Vermont January 2012 Page 2

• Confirm that the water supply system substantially meets existing codes for public water lines. [Note that the existing supply system is not regulated by the State of Vermont as a Public Supply because ofthe limited number ofusers and connections].

• Review the existing ground water quality monitoring program and establish an updated monitoring program until IGCLs are met.

• Expand the ground water reclassification boundary to include an additional property to the north of the existing boundary.

• Evaluation of potential vapor intrusion pathways related to structures located downgradient of the landfill.

Upon completion of the actions proposed in the Plan, an Investigation Report will be prepared documenting the actions taken, results of analysis and recommendations for future monitoring and maintenance.

2.0 CONCEPTUAL SITE MODEL UPDATE

During preparation of the RI/FS, a Conceptual Site Model (CSM) was developed by incorporating the physical setting, geologic conditions, hydrogologic setting, soil and ground water quality data to predict response(s) to the selected remedy. Monitoring conducted since the ROD was signed has proven the CSM to be largely accurate as reflected by the predicted extent of impacts, changes in ground water levels due to installation of the landfill cover system and identification of constituents of concern. However, the timeframe for meeting ICGs at all compliance pOints has extended beyond the 15 years included in the ROD.

It appears that uncertainty associated with hydrogeologie conditions immediately underlying the landfill, as well as the complexity of fractured bedrock aquifer systems, has made it difficult to predict long-term responses in the aquifer system to the remedy implemented at the Site.

BFI proposes to evaluate Site monitoring data generated during the past 15 years in conjunction with findings from fractured bedrock studies for other sites in an attempt to refine the predictions of cleanup timeframes based on natural attenuation. The specific components to be evaluated will include:

• Oxidation/reduction conditions within the aquifer and near the landfill. • Recharge and subsequent flushing of the aquifer system. • Geochemical interactions with mineralization naturally present in fracture linings. • Consistency of ground water flow paths. • Comparison of actual concentration changes with predicted changes.

Investigation Plan, DSI Landfill, Rockingham, Vermont January 2012 Page 3

The goal of the CSM update will be to refine our understanding of Site hydrogeologic and geochemical processes that affect fate and transport of constituents of concern . The CSM update will also review cleanup goals, changes in regulatory standards and if appropriate, recommend changes to the cleanup goals established in 1994.

3.0 ENVIRONMENTAL COVENANT

BF! executed an agreement with 3 downgradient property owners in 1980 to provide potable water to those properties. Water is provided to those properties from a well maintained by BFI on the Greenwood property immediately south of the landfill as shown on Figure 2. Since execution of the original agreement, BFI petitioned VTDEC and received approval in 2008 to reclassify groundwater to Class IV in an area downgradient of the landfill that includes the three properties. In accordance with Vermont regulations, Class IV groundwater is not suitable as a source of potable water, but may be suitable for some agricultural, industrial and commercial uses.

BFI intends to develop Deed Covenants with affected property owners. The Deed Covenant will be consistent with the proposed Uniform Environmental Covenants Act (UECA).

As part of Site Institutional Controls, BFI will negotiate with affected property owners to record a Deed Covenant with the following conditions:

• Potable water will be supplied to the affected residence until such time as ground water meets cleanup goals.

• A provision to maintain the potable supply (see Section 4 for more details). • A restriction against installing a ground water supply well on the property.

BFI will contact individual property owners to execute a Deed Covenant and will take all reasonable measures to negotiate in good faith with property owners to execute and record the Deed Covenant. Should property owners be unwilling to execute and record a Deed Covenant or place unreasonable demands on BFI, BFI will contact EPA to determine appropriate further actions to execute the Deed Covenant.

It should be noted that a fourth property (Rumrill) may be requested to execute and record a Deed Covenant. Currently, the Rumrill property obtains drinking water from a spring located west of their property on land owned by BFI as shown on Figure 2 and As discussed in Section 5, BFI anticipates an expansion of the ground water reclassification zone to include the Rumrill property. In that event, a Deed Covenant similar to adjoining properties will be negotiated.

It is anticipated that the covenant will be tailored using a template developed under the Uniform Environmental Covenants Act (UECA) subject to input from EPA and VTDEC.

Investigation Plan, OSI Landfill , Rockingham, Vermont January 2012 Page 4

4.0 POTABLE WATER SYSTEM DESIGN AND MAINTENANCE

The current waterline serving the downgradient properties within the restricted groundwater use area is approximately 20 years old and consists of a single flexible polyethylene pipe. The water line serves the following properties:

Banholzer Parcel 4-107-014 Johnson Parcel 4-107-012 Glynn Parcel 4-107-010

As discussed in Section 3.0 and 5.0, it is anticipated that an additional property may be added in the future.

Rumrill Parcel 4-107-008

The Federal Safe Drinking Water Act is administered by the VTDEC when the state has primary administrative authority ("primacy"). Water supply in the State of Vermont is regulated in accordance with Chapter 21, Water Supply Rule of the VTDEC Environmental Protection Rules. Based on review of this rule and discussions with VTDEC, the waterline from the Site servicing the downgradient parcels would be classified as a Non-Public Water System not requiring a state permit. However, EPA has requested that the water supply system substantially meet standards for use as a multi-user water supply system.

To meet this EPA request, BFI proposes the following actions:

1. Review the existing water line layout relative to isolation and separation distance standards set in Appendix A Part 11.4 of the VTDEC Water Supply Rule,

2. Conduct periodic water quantity testing of the supply well in accordance with Appendix A Part 11.6 of the VTDEC Water Supply Rule;

3. Conduct periodic water quality testing at the water supply well for parameters established for Non-Public water systems requiring a permit in accordance with Appendix A Tables A11-5 and A-11-7 of the VTDEC Water Supply Rule;

4. Pressure and leakage test the existing pipe in accordance with the latest edition of AWWA Standard C600;

5. Conduct water quality testing at the individual taps; and

6. Develop and implement an Operations and Maintenance Manual for the system based on the template established by the VTDEC Water Supply Division.

Investigation Plan, DSI Landfill, Rockingham, Vermont January 2012 Page 5

Develop a plan to be followed if the existing water supply line needs to be replaced in the future including specifying that materials and installation will be in substantial compliance with the most current version of the VTDEC Water Supply Rules for a Non­Public Water System requiring a Permit (even if a permit is not required by future versions of the rule).

A financial instrument suitable to EPA and VTDEC will be developed to provide a funding mechanism for future repair or replacement of the water supply system. The financial instrument will be maintained until ground water cleanup goals are met.

5.0 GROUND WATER RECLASSIFICATION

URS Corporation, on behalf of SFI, submitted a Class IV Groundwater Reclassification Petition dated November 6, 2007 for the DSI Landfill to the Director of the Water Supply Division of the VTDEC. This petition proposed the reclassification of groundwater from Class III to Class IV for properties within the area of impacted groundwater and the surrounding buffer zone. Figure 3 delineates the extent of the original reclassification area including a table of properties currently within the groundwater reclassification area. This petition was ultimately accepted by VTDEC in 2008 and groundwater reclassified to Class IV. Class IV groundwater are not suitable as a source of potable water, but may be suitable for some agricultural, industrial and commercial uses.

The original reclassification area included a 200-foot buffer placed along the cross­gradient and upgradient boundaries of the area to fulfill the requirements for a minimum isolation distance for a water supply well form a hazardous or solid waste disposal site. Subsequent review of data has determined that buffer should have been extended to the north and east. As a result, the Rumrill property, or portion thereof, (shown as Parcel 4-107-008 on Figure 3) would now be located within the revised buffer zone. Therefore, SFI is proposing to petition VTDEC to reclassify groundwater underlying the Rumrill property from Class III to Class IV. The maximum antiCipated extent of the proposed expanded reclassification zone is also shown on Figure 3.

With respect to the original reclassification petition prepared and submitted by URS in 2007, SF! will prepare an addendum to that petition to incorporate the Rumrill property in the reclassification zone. The addendum will be based on, and reference the URS petition as appropriate, and include updated and relevant information and data supporting inclusion of the Rumrill property in the reclassification zone. The original URS petition will be included as an attachment to the addendum.

As discussed in previous sections of this Investigation Plan, reclassification of the Rumrill property is ultimately expected to be coupled with a Deed Covenant and connection to the existing water line.

Investigation Plan, DSI Landfill , Rockingham, Vermont January 2012 Page 6

6.0 LONG TERM MONITORING PLAN

Upon implementation of the actions described in this Investigation Plan, BFI will review the current ground water monitoring program and make recommendations to modify the program to reflect the additional actions taken by BF!.

Given that the actions proposed in this plan will reclassify groundwater within the migration path way in an area downgradient of the landfill (including a lateral buffer zone), prohibit the installation of ground water supply wells and provide provisions for testing and maintaining a water supply to affected properties, it is anticipated that the future monitoring program will focus on "sentinel" locations at or near the lateral perimeter of the existing plume with less emphasis on the plume itself. Sentinel wells can serve to confirm plume extent or identify changes in water quality at lateral boundary locations that might indicate significant changes in ground water quality beyond the expected lateral extent of the plume.

A reduced sampling frequency may be appropriate for the current compliance wells until such time that data indicate cleanup goals have been met. At that time, a more focused verification sampling program may be warranted to determine compliance with cleanup goals.

In the interim and until EPA approves a change in the monitoring program, BFI will continue groundwater monitoring in accordance with the current EPA approved ground water monitoring program. Figure 2 highlights the monitoring wells currently included in the Long-Term monitoring Program.

7.0 VAPOR INTRUSION EVALUATION

The presence of volatile compounds in proximity to enclosed structures may pose a risk of vapor migration and accumulation in the structure. Since there is no record of discharges or releases of petroleum or hazardous substances attributable to the landfill or Site directly to the properties downgradient of the landfill, the only source of vapor would be due to off-gassing of contaminants present in ground water and migration through bedrock and/or overlying soil into subgrade structures. Migration pathways could include preferential pathways such as utility corridors (water, sewer, electric, foundation drains, etc.).

The evaluation will include the following:

1) A review of existing structures to determine if subgrade features are present (frost walls, basement foundations) and ,if possible, identify potential preferential pathways. Only structures that have subgrade features will be further evaluated.

2) A review of existing ground water quality data proximal to the properties and structures in question. If water quality results show that constituents of concern are present, further evaluation will be completed.

3) Review soil boring logs and well completion logs to determine depth to water and composition of materials above the water table.

Investigation Plan, OSI Landfill, Rockingham, Vermont January 2012 Page 7

4) Assess the concentration of constituents of concern detected in gr~und water samples and analyze partitioning based on Henry's Law to determine if significant vapor generation is likely. Alternatively, the concentrations of VOCs in groundwater that may potentially underly structures may be compared to generic EPA protection standards for vapor intrusion.

Results of the Vapor Intrusion Evaluation will be included in the Investigation Report which will provide conclusions on the likelihood of vapor migration risks and recommendations for additional investigation, if appropriate.

S.O IMPLEMENTATION SCHEDULE

It is expected that many of the actions described in this Plan will be completed concurrently. Some actions will require review and approval by the EPA and/or VTDEC (Environmental Covenant, Reclassification Petition), and as such the schedule is subject to change due to review and approval cycles. Ultimately, the completed actions will be documented in the Investigation Report. The completion schedule shown below is based upon "months after approval of this Investigation Plan" by EPA.

Action Completion Schedule CSM Update 6 months after Plan approval Environmental Covenant 12 months after Plan approval Water Supply Design Review and Maintenance Plan

9 months after Plan approval

Ground Water Reclassification Petition

9 months after Plan approval

Lonq-Term Monitoring Plan 12 months after Plan approval Vapor Intrusion Evaluation 6 months after Plan approval Investigation Report 18 months after Plan approval

Investigation Plan, DSI Landfill, Rockingham, Vermont January 2012 Page 8

Appendix A

October 18, 2011 EPA Request for Additional Investigation Plan, Notice of Change in U.S. RPM, and November Site Visit

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1

5 POST OFFICE SQUARE, SUITE 100 BOSTON, MA 02109-3912

October 18, 20 II

Mr. Ralph Larimore Envirorunental Manager Browning-Ferris Industries 5600 Niagara Falls Blvd. Niagara Falls, NY 14304-1532

Re: Request for Additional Investigation Plan, Notice of Change in U.S. RPM, and November Site Visit - BFI Rockingham Landfill Superfund Site, Rockingham, Vermont

Dear Mr. Larimore:

This letter clarifies the status of the June 2009 Field Investigation Plan as it relates to the third Five-Year Long-Term Monitoring Report and triggers the requirement for an Additional Investigation Plan. It also provides formal notification of the change in the EPA Project Manager and schedules a November Site visit.

As discussed at our March 7, 2011 meeting at the U.S. Environmental Protection Agency's Boston Office, EPA accepts the June 2009 Field Investigation Plan for the above referenced Site as a substitute for the third Five-Year Long-Term Monitoring Report that was due January 30, 20 II. The June 2009 Field Investigation Plan was prepared based on the assumption that the clean-up goals established in the September 21, 1994 Record of Decision (ROD) would not be met by the January 30, 2011 deadline.

Pursuant to the Consent Decree (Civil Action No. 2:96-CV-309) section VII, paragraph 22, EPA is formally notifying the Settling Defendants that the third Five-Year Long-Term Monitoring Report did not demonstrate that groundwater cleanup levels have been achieved and the Additional Investigation Plan discussed in Section V-2 of the Statement ofWork (SOW) shaH be prepared and submitted by the Settling Defendants to EPA and the Vermont Department of Environmental Conservation (VT DEC). This letter provides the EPA notification which initiates the 90 days for submittal of the Additional Investigation Plan.

As required by the Consent Decree (CD), once the Additional Investigation Plan is approved by EPA, the Settling Defendants shall carry-out the Additional Investigation Plan and shall submit the Additional Investigation Report required by Section V-2 of the SOW. The CD also requires the Settling Defendants to implement any other additional response actions that EPA determines (after reasonable opportunity for review and comment by the State of Vermont) are necessary to carry-out the remedy selected in the ROD or to protect human health or the environment.

A critical issue that must be addressed as a result of the failure of the remedy to achieve groundwater restoration is the provision to provide and maintain a drinking water supply to the residents currently served by the facility water line. The Additional Investigation Plan and associated implementation activities must describe the actions the Settling Defendants will

Toll Free .'-888·372·7341 Intemet Address (URL). http://www.epa.gov/regionl

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Mr. Ralph Larimore October 18, 2011

undertake to secure a long-term water supply to the three residential properties. Specifically, the Settling Defendants need to create new or amended water agreements that: I) provide access to potable water of sufficient quantity and quality for the reasonably expected uses of the properties; 2) establish a funding mechanism to address all long term inspection, monitoring and maintenance activities; and 3) designate a point of contact for any issues associated with the water supply system.

In order to assure the continued functionality and integrity of the water supply system, the Settling Defendants shall also revise the institutional controls (ICs) on the properties connected to the water line to prevent the extraction and use ofgroundwater from these properties in perpetuity. The Settling Defendants shall also make best efforts, which includes the collection and submission of any information or data requested by the Vermont Agency ofNatural Resources, to expand the existing groundwater reclassification boundary to include an three properties covered by the Water Agreement (attached to and incorporated into the aforementioned Consent Decree as Appendix D).

The Settling Defendants shall submit the Additional Investigation Plan by January 16, 2012. In addition to the requirements identified in Section V-2 of the SOW, the Additional Investigation Plan shall also:

• Define the long-term limit of groundwater extraction; • Include a draft Grant of Environmental Restriction, prepared in accordance with the

requirements of EPA and the State of Vermont, to prevent groundwater use in perpetuity for the three downgradient residential properties for EPA and VT DEC review;

• Present a draft petition to expand the reclassification boundary to include all properties where groundwater use will be restricted;

• Identify any potential vapor intrusion exposure pathways, and ifpresent, mitigation measures that may be implemented;

• Verify the water supply system meets current and anticipated state and federal standards for use as a public, multiple-user, water supply system;

• Identify the proposed long-term funding mechanisms for water supply well and water supply line maintenance and monitoring;

• Continue monitoring per the CD and the SOW, unless EPA approved a change to the monitoring program; and,

• Present a schedule with timelines and deliverables.

As a follow-up to a topic also discussed at our March 7, 2011 meeting, this letter confirms the Remedial Project Manager (RPM) for the Site has changed. In accordance with the Consent Decree, Civil Action No. 2:96-CV-309, Section XIII, paragraph 50, the project management responsibilities for the BFIIRockingham Landfill Superfund Site have changed from Almerinda Silva to the undersigned.

Finally, earlier this month I communicated to you and your Site contractor my interest in scheduling a Site visit by mid-November. As noted in my email, the June 15, 2011 inspection report prepared by Nobis Engineering and emailed to you on July 26, 2011 contained a number of corrective actions and recommendations, some ofwhich were based on observations made in

2

Mr. Ralph Larimore October 18, 2011

prior inspections. The purpose of the Site visit is to review the response to action items and recommendations identified in the report plus any additional items that may warrant repair due to post-inspection storm or other events. In the absence of receiving any possible dates, I propose scheduling the Site visit for the afternoon of Thursday, November 17 and will assume this can be accommodated unless I am informed otherwise.

Please feel free to contact me if you any questions or concerns. I look forward to working with you on this project.

Sincerely,

Kevin S. Heine, PG Project Manager

cc: Ed Hathaway, EPA Sarah Meeks, EPA Almerinda Silva, EPA Joe Montello, Republic Services Michael Deyling, Summit Environmental Consultants Michael Smith, VT DEC

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