work plan, limited field investigation · 2.7 5271.001 work plan limited field investigation...

2.7

5271.001

WORK PLAN

LIMITED FIELD INVESTIGATION

LANDFILL AREA

Burgess Brothers Superfund SiteWoodford and Bennington, Vermont

BURGESS BROTHERS SUPERFUND SITE STEERING COMMITTEE

DECEMBER 1991

O'Brien & Gere Engineers, Inc.5000 Brittonfield ParkwaySyracuse, New York 13221

WORK PLAN LIMITED FIELD INVESTIGATION

BURGESS BROTHERS SUPERFUND SITE WOODFORD AND BENNINGTON, VERMONT

TABLE OF CONTENTS

SECTION 1. INTRODUCTION 1 1.01. Summary of Background Information 1 1.02. Delineation of Study Area 4 1.03. Limited Field Investigation Purpose and Objectives 4 1.04. Scope of Work 4

SECTION 2. DATA QUALITY OBJECTIVES 6 2.01. Introduction 6 2.02. Ground Penetrating Radar Survey 7 2.03. Vapor Screening Survey 8 2.04. Monitoring Well Evaluation and Ground Water Screening 8

SECTIONS. PROJECT MANAGEMENT PLAN 9 3.01. Introduction 9 3.02. Personnel Involved in On-Site Activities and Management 9 3.03. Health and Safety Plan 10

SECTION 4. LIMITED FIELD INVESTIGATION WORK TASKS 11 4.01. Introduction 11 4.02. Inventory of Municipal and Residential Water Supplies in the Vicinity

of the Study Area 11 4.03. Historical Records and Aerial Photograph Review 12 4.04. Geologic Literature Review 13 4.05. Geographical Reconnaissance 13

4.05.01. Initial Air Quality Survey 13 4.05.02. Wetlands Assessment 15 4.05.03. Sensitive Environmental Receptor Survey 15 4.05.04. Stream Flow Measurements 15

4.06. Topographic Study Area Map Development 17 4.07. Ground Penetrating Radar (GPR) Survey 18 4.08. Vapor Screening Survey 19

December 1991 O'Brien & Gere Engineers

4.08.01. Soil Headspace Screening in Marsh Soils 19 4.08.02. Surface Water and Sediment Screening 21 4.08.03. Soil Gas Survey and Water Table Screening 22

4.09. Existing Monitoring Well Evaluation and Analyses 23 4.09.01. Well Inspections 23 4.09.02. Monitoring Well Re-Development 23 4.09.03. In-Situ Hydraulic Conductivity Testing 24 4.09.04. Ground Water Level Measurements 24 4.09.05. Ground Water Screening 24

4.10. Field Screening of Metals 25

SECTION 5. INTERIM MEMORANDUM PREPARATION 26

SECTION 6. SCHEDULE 27

FIGURES

1. Site Location Map 2. Site Base Plan 3. Existing Monitoring Wells and Sampling Points 4. Study Area Outline 5. Stream Flow Measurement Locations 6. Ground Penetrating Radar Survey Area 7. VOC Concentrations in Shallow Soils (February 1989) 8. Shallow Soil Screening Locations 9. Stream and Sediment Screening Locations 10. Soil Gas and Shallow Ground Water Screening Locations 11. Project Schedule

APPENDICES

A Decontamination Protocol of Sampling Equipment B Shallow Soil Sampling Protocol C Soil and Sediment Headspace Protocol for Gas Chromatograph Analysis D Stream Water and Sediment Sampling Protocol E Ground Water Headspace Protocol for Ground Water Sample Collection and

Gas Chromatograph (GC) Analysis F Soil Gas Protocol for Sample Collection and Gas Chromatograph (GC)

Analysis G Well Development

December 1991 O'Brien & Gere Engineers

SECTION 1. INTRODUCTION

1.01. Summary of Background Information

In August 1991, the U.S. Environmental Protection Agency (USEPA) entered into

a Consent Order with the Burgess Brothers Super-fund Site Steering Committee for a

Remedial Investigation and Feasibility Study (RI/FS) for the Burgess Brothers Superfund

Site. The following presents a Work Plan for conductinga Limited Field Investigation (LFI)

at the Burgess Brothers Superfund Site. This LFI Work Plan is submitted in accordance

with the Consent Order [Appendix I, Statement of Work (SOW), Section 2(11)], which was

effective September 4, 1991.

The Burgess Brothers Superfund Site is located directly due east of the City of

Bennington, Vermont, in the towns of Bennington and Woodford, as shown in Figure 1.

The privately owned landfill is situated on the western slope of Harmon Hill and is part of

a 60 acre plot owned by Clyde Burgess, Jr., and operated by Burgess Brothers, Inc. Dating

back to the 1940s, the site has reportedly been used as a source of sand, a metal salvage

facility, and as a disposal area for construction debris, metals, sludges, and liquid wastes.

Lead sludge was reportedly disposed from 1956 to 1970 in the lagoon area at the southern

end of the landfill area. Battery processing waste was disposed in the lagoon area from

1971 to 1976. To date, there is no record of the disposal of these wastes in any location at

the site other than the lagoon area.

The focus of the investigation is approximately a two to three acre area located in

the northeastern section of the property, adjacent to a national forest. This area is shown

on Figure 2. The portion of the area formerly used for unlined lagoon disposal has been

backfilled, cleared, graded and seeded. Except for several 55 gallon drums, materials have

been removed from the surface. An unnamed stream flows adjacent to the southeast side

of the landfill and joins Barney Brook approximately 1,500 feet from the lanaxill.

Various investigative activities have occurred at this site over the last six years under

the oversight of the Vermont Department of Environmental Conservation (VTDEC), Waste

Management Division. Sampling programs were conducted from 1985 to 1989 by

contractors for the Eveready Battery Company (EEC) and for USEPA. These programs

December 1991 \ O'Brien & Gere Engineers

were conducted to characterize the potential impact of residues from the former lagoon area

to the surrounding environment. These activities included terrain geophysical surveys, soil

and soil gas analyses, as well as surface water, ground water, soil, and leachate sampling.

A site map depicting existing ground water monitoring wells and other sampling points is

shown in Figure 3.

In the summer of 1988 the Burgess Brothers Superfund Site was placed on the

National Priorities List as a Superfund site, with USEPA assuming an active role in the site

investigation. Geraghty & Miller was retained by the Eveready Battery Company. In

February of 1989, Geraghty & Miller published a report summarizing the 1988

hydrogeologic investigations conducted at the site. In February of 1989, USEPA contractors

collected surface water samples. Subsequent to this activity, Geraghty & Miller collected

ground water and surface water samples in March 1989. In April of 1989, USEPA

contractors conducted a soil gas survey and soil sampling activities. The soil gas survey

concentrated on the former lagoon area as well as a marshy area downgradient from the

lagoon area. Five soil samples were collected from these areas, selected on the basis of the

soil gas survey. These samples were analyzed for volatile organic compounds (VOCs),

metals and base neutral/acid extractable compounds.

Results of a soil gas survey and soil sampling program conducted by a USEPA

contractor in the Winter and Spring of 1989 indicated detectable concentrations of

trichloroethene (TCE) and tetrachloroethene (PCE) in the vicinity of the lagoon area.

Specifically, soil gas samples collected around the known location of the former lagoon area

indicated detectable TCE and PCE concentrations in five of eight samples plus "several

unidentified early eluting peaks".

Screening of eight soil samples collected from near surface soils in the marshy area

also indicated concentrations of TCE and PCE in the headspace at concentrations ranging

from 1.2 to greater than 40 parts per million (ppm). Chlorobenzene was also tentatively

identified.

Soil analyses conducted at this time indicated detectable TCE and PCE

concentrations of 0.1 to 16 ppm in four of five samples in and adjacent to the former lagoon

area. Metals including lead, mercury, iron, nickel and zinc were detected at various

concentrations. Some metals (copper, nickel and zinc) in each sample were above the

December 1991 2 O'Brien & Gere Engineers

background concentration. Elevated lead, nickel, and mercury were detected in and around

the former lagoon area.

Semi-volatile compounds have been analyzed in soil samples. Analytical results

indicated that these compounds were for the most part non-detectable. A few compounds

(pyrene and fluoranthene) were detected at low concentrations in a soil sample collected

from the toe of the former lagoon area.

The Eveready Battery Company retained Geraghty & Miller to install eight

monitoring wells at the site, one upgradient of the former lagoon area and the remainder

downgradient. The downgradient wells included five shallow and two deep wells positioned

to characterize site conditions. The results of the well installations indicated that ground

water occurs in an unconsolidated deposit at depths of less than eight feet below ground

surface. Previous investigations indicate that ground water flow is predominantly toward the

south and southeast.

In the most recent March 1989 sampling program conducted by Geraghty & Miller,

VOCs were not detected in the upgradient (background) well. However, VOCs were

detected in all downgradient wells west of the unnamed stream in quantities exceeding 10

ppm. This confirmed results dating back to 1985. The main constituents detected in these

downgradient wells included TCE, PCE, dichlorethene (DCE) and vinyl chloride (VC). A

shallow and deep well on the eastern side of the unnamed stream (W-6S, 6D) did not

contain any of the VOCs detected in the other wells. The samples did however contain 80

and 22 ppb of carbon disulfide, respectively, which was not previously identified at the site.

Five surface water samples were collected at locations corresponding to original

Geraghty and Miller locations in February 1989. No VOCs were detected in the upstream

location (SW-1), but TCE, PCE, and isomers of 1,2-DCE were detected at 0.47 to 1.9 ppm

in three downstream sampling points near the former lagoon area. These concentrations

decreased by nearly an order of magnitude from February to March 1989 and may be the

result of increased dilution during wetter periods. The furthest downstream sampling point

(SW-5) has historically exhibited concentrations below quantifiable limits, and has not

exceeded federal or state drinking water standards. This point is located at the confluence

of the unnamed stream with Barney Brook.


1.02. Delineation of Study Area

Based upon the results of previous investigations, the proposed study area is shown

on Figure 4. This study area includes a one-half mile radius around the former lagoon area,

which is the focus of the investigation. Therefore, field activities will be concentrated in a

downgradient direction (southeast to southwest) from the former lagoon area. The

boundaries of the study area were developed to include the unnamed stream and a

reasonable area downgradient from the former lagoon area, considering site hydrogeology

and potential contaminant plumes identified to date.

The detailed topographic site map generated in the LFI will be utilized to delineate

an area most likely encompassing a radius of approximately 500 feet around the former

lagoon area, which may be modified later if needed. Results of efforts conducted in the LFI

will be used to modify the boundaries of the study area as appropriate.

1.03. Limited Field Investigation Purpose and Objectives

As stated in the Statement of Work (SOW), September 1991, the purpose of the LFI

is to produce a focused Work Plan for the RI/FS. Data obtained through the LFI will be

used for the refinement of the sampling plans for the Phase I RI/FS. Field activities will

consist of the collection of data obtained by non-invasive methodologies and with Levels I

and II analytical support.

The objectives of the LFI are to:

1. Increase the understanding of the site in order to enhance the scoping effort.

2. Improve the focus of the RI/FS.

3. Collect data to be used in the establishment of health and safety requirements

and procedures.

4. Identify potential past disposal locations.

1.04. Scope of Work

The scope of work described in this work plan has been developed in accordance

with requirements of the SOW. A variety of tasks have been identified which include a

background literature and document review, field reconnaissance studies, and screening


1

2

3

4

5

6

7

8

9

surveys to update site conditions. Specific tasks are as follows, in the approximate order in

which they will be conducted:

. Inventory of Municipal and Residential Wells in Vicinity of Study Area

. Historical Records and Aerial Photo Review

. Geological Literature Review

. Geographical Reconnaissance

. Topographic Study Area Map Development

. Ground Penetrating Radar (GPR) Survey

. Vapor Screening Survey

. Stream Sampling and Screening

. Existing Monitoring Well Evaluation and Field Screening


SECTION 2. DATA QUALITY OBJECTIVES

2.01. Introduction

Data Quality Objectives (DQOs) are quantitative and qualitative statements

specifying the quality of the environmental data required to support the decision-making

process. DQOs define the uncertainty in the data that is acceptable for each specific activity

during the investigation. This uncertainty includes both sampling error and analytical error.

Ideally, zero uncertainty is the intent; however, the variables associated with the natural

environment and the analytical process inherently contribute to the uncertainty of the data.

It is the overall objective to keep the total uncertainty within an acceptable range that will

not hinder the intended use of the data.

Development of DQOs for a field investigation involves defining the minimum

criteria for statistical, logistical, sampling, and analytical parameters, that must be attained

in order to generate data of the quality that is consistent with the intended use of the data.

Examples of data quality parameters for which qualitative or quantitative criteria are

developed include sensitivity, accuracy, precision, sample representativeness, data

comparability and data completeness. Statistical considerations include factors such as the

determination of sample size and identification of appropriate data analysis methods.

Sampling considerations include consideration of sample representativeness, sample

completeness, and sample integrity. Analytical considerations involve the development of

criteria for accuracy, precision, and sensitivity. To facilitate the evaluation of analytical

factors in development of DQOs, USEPA has defined four Analytical Levels (Level I

Level IV). Each Level describes a set of minimum instrumentation and Quality

Assurance/Quality Control criteria that must be attained in order to meet the appropriate

DQOs.

This section presents an overview of the DQOs established for the LFI. s\ detailed

statement of QA/QC criteria to achieve these DQOs is discussed in the field protocols

contained in the appendices. The discussion is organized according to the field tasks that

will be conducted during the LFI.


2.02. Ground Penetrating Radar Survey

The objectives of the ground penetrating radar (GPR) survey are to identify

subsurface features that may result in reflective anomalies, and to develop a clearer

understanding of the layering in the glacial overburden and top of bedrock in and around

the landfill. The rationale for conducting this survey is further explained in Section 4.07

(GPR Survey). To achieve the objectives of the survey, the following DQO parameters have

been identified for the GPR survey:

1. The GPR survey will be conducted over the entire portion of the landfill,

encompassing the former lagoon area north to the access road entrance, to

develop sufficient electromagnetic profiles. Survey lines will also be extended

northward into the adjoining material storage area. Hand held surveying

equipment will be utilized for surveying areas which are inaccessible to

vehicles. Profiles will also be conducted in adjoining areas near and around

the landfill to evaluate natural stratigraphy. The survey area is shown on

Figure 6.

2. A surveyed grid system will be established over the area which to be covered

by the GPR survey in order that the locations of subsurface anomalies may

be identified in the field. Appropriate annotation techniques will be

employed to reference grid markers on the GPR output.

3. The spacing between survey lines will be selected so that there is a low

probability that subsurface anomalies of interest may be undetected as a result

of being between the scanning range of two sequential survey lines. This

criteria will be selected based on the estimated minimum size of potential

subsurface anomalies of interest in the landfill.

4. The radar frequency will be selected so that a minimum penetration of 50 ft,

and adequate resolution of subsurface anomalies and existing soil horizons,

is obtained. The selection of the radar frequency employed will depend on the

nature of the soils present at the site, and the estimated size of subsurface

anomalies that may be present at the landfill.


2.03. Vapor Screening Survey

The objective of the vapor screening survey will be to provide qualitative screening

of the presence of VOCs in various media, and to compare findings to previous surveys. To

achieve these objectives, the following sampling and analytical parameters will be addressed:

1. Monitoring wells, sediment samples, and soil samples for the headspace

analysis will be collected from locations which have indicated the presence of

VOCs in previous surveys. Additional soil and sediment samples will be

collected, as appropriate, to estimate the approximate areal extent of VOCs

in soils and sediments in the landfill area.

2. Proper sampling techniques and equipment as presented in the USEPA

guidance document: A Compendium of Superfund Field Operations Methods

(USEPA 600/2-80-018) will be utilized for sample collection activities. If the

necessary sampling techniques are not contained in this guidance document,

sampling will be conducted according to pre-approved sampling protocols.

3. Samples will not be composited. This action will minimize the volatilization

of the residues during sample handling.

4. Headspace analysis, soil vapor analysis, and stream water analysis will be

conducted according to the USEPA Level II analytical level, as described in

the USEPA guidance document: Data Quality Objectives for Remedial

Response Activities (USEPA 540/G-87/1003) (USEPA 1987). Level II involves

the use of portable instruments to obtain qualitative and quantitative

identification of compounds. The QA/QC activities for Level II activities

include documentation of blank injections, calibration standard runs, and runs

of qualitative standards between samples.

2.04. Monitoring Well Evaluation and Ground Water Screening

Existing monitoring wells will be redeveloped and water level measurements will be

collected. In addition, groundwater samples will be collected from each monitoring well for

field screening according to USEPA Level II analytical level. The Quality Control/Quality

Assurance parameters for the ground water screening will be the same as the QA/QC

parameters identified for screening of the stream water samples.


SECTION 3. PROJECT MANAGEMENT PLAN

3.01. Introduction

The LFI will be implemented by O'Brien & Gere Engineers, Inc. (O'Brien & Gere)

and its subcontractors. The following section identifies the personnel who will be

supervising field activities and their qualifications. Field activities will be performed in

accordance with the Health and Safety Plan as described in Section 3.03.

3.02. Personnel Involved in On-Site Activities and Management

The LFI will be performed under the direction of Robert C. Ganley, P.E., who will

serve as Project Officer. Mr. Ganley is an environmental engineer with over 17 years of

experience in the field, including investigation and remediation of hazardous waste sites.

Day-to-day project management will be the responsibility of Cheryl L. Cundall, P.E., Esq.,

a chemical engineer with expertise in hazardous waste site investigation and remedial

technology assessment.

Field activities will be supervised by Mr. Richard G. Stromberg, a hydrogeologist with

over 11 years of experience in the development and implementation of hazardous waste site

investigations. O'Brien & Gere's Health and Safety Officer is Dr. Swiatoslav W. Kaczmar,

C.I.H. The O'Brien & Gere personnel who will perform on-site field work for the LFI have

received training and medical surveillance in accordance with the applicable regulations in

29 CFR 1910.

Questions and correspondence regarding the LFI should be addressed to:

Cheryl L. Cundall O'Brien & Gere Engineers, Inc. 5000 Brittonfield Parkway Syracuse, New York 13221 Phone: (315) 437-6100 Fax: (315) 463-7554


3.03. Health and Safety Plan

The Health and Safety Plan for this investigation has been prepared as a separate

document to facilitate its use during field activities.


SECTION 4. LIMITED FIELD INVESTIGATION WORK TASKS

4.01. Introduction

The following describes the work tasks which will be completed in the LFL These

tasks are presented in the approximate order in which they will be completed, although it

is anticipated that many of the tasks will overlap during implementation, as described in

Section 6.

4.02. Inventory of Municipal and Residential Water Supplies in the Vicinity of the Study

Area

An inventory of the municipal or private ground water or surface water supplies

within a one-mile radius of the landfill will be developed by updating information contained

in Appendix C of the Geraghty & Miller report dated May 1989. As of 1989, the Town of

Bennington received most of its drinking water supply from Bolles Brook in Woodford.

Bolles Brook is located several miles northeast of the site and converges with Walloomsac

River which flows westerly about a mile north of the site. According to the Geraghty &

Miller report, "the Bennington water supply system does not extend out to the houses

located downgradient from the site on Burgess Road; the eastern limit of the system is

Barney Road. Those houses not on the Bolles Brook system receive their water supply from

a separate Town source in Woodford. This source is a spring located approximately 1.5

miles east of the landfill on Burgess Road, upgradient of the site."

Also according to the Geraghty & Miller report, "two bedrock water supply wells are

located within a mile of the site in the Una Bella trailer park on Gore Road." At the time

of the Geraghty & Miller report, these were the only private wells in the immediate area,

according to the Town Listers office. According to USEPA, there are two additional

residential wells in the vicinity, the Dickinson and Kenney residences located on burgess

Road.

Gorham Heights, a proposed housing development within one mile of the landfill

near Gore Road, was expected to install bedrock wells by 1989. During a well inventory

December 1991 n O'Brien & Gere Engineers

conducted by Geraghty & Miller for the May 1989 report, no water supply wells were found

to be less than a half-mile from the site.

The Bennington Municipal Water Department, the Woodford Public Works

Department and the Bennington County Board of Health will be contacted to obtain

updated information on water supplies, including Morgan Spring, which serves as a backup

water supply for the Town of Bennington. Additionally, protected zones and areas of direct

or indirect recharge to water supplies, if designated, will be researched. The Vermont

Agency of Natural Resources (ANR) will be contacted to review information potentially on

file concerning current water uses, requirements, and regulations and those planned in the

future. Finally, the Vermont Department of Health (VTDOH) will also be contacted.

4.03. Historical Records and Aerial Photograph Review

A series of black and white aerial photographs which provide historical coverage of

the site and surrounding areas will be obtained from the Earth Science Information Office

in Reston, Virginia. This office maintains a file of commercially available photographs

which was last updated in 1989. In addition to the black and white aerial photographs,

color infrared photos will be selected from several years depending on availability.

Additionally, private mapping companies and other agencies will be contacted if necessary

to fill in gaps in the coverage provided by this agency. At present, it appears that photos

are available for this site from 1952 until 1987 with reasonable coverage.

A review will be conducted of available historical information relative to activities

conducted at the site and nearby surrounding areas. Appropriate state and local agencies

will be contacted. Agencies and other public sources to be contacted will include, but not

be limited to, the Bennington Free Library, the Town Listers Offices in Woodford and

Bennington, Planning and Building Departments, Tax Assessor's Office, and Town Clerk.

VTDEC's Solid Waste Management Division and the Hazardous Materials Management

Division will also be contacted regarding information concerning use and releases of oil,

hazardous wastes, and solid wastes in the study area.


4.04. Geologic Literature Review

A summary of the regional geology of the Bennington area has been provided in

Appendix A of Geraghty and Miller's hydrogeologic report dated May 1988. A literature

review will be conducted to further define the nature of the unconsolidated glacial deposits

and bedrock in the area.

Based on a visual reconnaissance of the site by an O'Brien & Gere geologist in June

1991, the glacial sequence in the area consists of ice contact kames and glacio fluvial

deposits over glacial till and bedrock. The kame and glacio fluvial deposits are primarily

sandy in nature but fine grained silt and clay layers are known to occur in the study area.

These layers may be significant in affecting ground water and associated contaminant

movements, especially east and south of the site. Additionally, the nature and orientation

of fracture zones in the bedrock is important and will be further researched.

Ms. Diane Conrad (acting State Geologist) of the State Geologist's office in

Waterbury will be contacted to identify geologic and hydrologic publications for the area of

study. The U.S. Soil Conservation Survey office in Bennington will also be visited to review

information.

Information obtained from these efforts will be used together with previously

developed information at the site (such as from soil borings and geophysical surveys) to

develop a conceptual understanding of the site geology and hydrogeology.

4.05. Geographical Reconnaissance

The geographical reconnaissance will consist of a number of surveys and assessments

which will constitute the initial field surveying effort. These surveys will be conducted at

times corresponding to optimum field conditions and, if possible, will occur after the data

from tasks described in Sections 4.02 through 4.04 are collected and reviewed.

4.05.01. Initial Air Quality Survey

Upon entering the vicinity of the former lagoon area and landfill area, an initial air

quality survey will be conducted in the breathing zone at surveyed control points around the

landfill to determine whether concentrations of site related indicator compounds (VOCs and

particulates) in the air require personal safety precautions. The air quality survey will be


conducted using: an HNu photoionization detector to measure total VOCs; an ASP-1

radiation detector to measure total beta and gamma emissions; and a MIE miniram to

measure airborne respirable particulates. The air quality survey will be performed at

monitoring points around the perimeter of the landfill and within the landfill. The survey

will be a walkover assessment of conditions. If findings from the walkover indicate readings

of concern as presented in the Health and Safety Plan, a plan for more detailed screening

or a higher level of PPE will be submitted to USEPA

A photoionization detector (PID) will be used to monitor the air for total volatile

organic compounds. The PID will be fitted with a 10.2 eV lamp to provide the highest

range of detection capability. The PID will be calibrated to isobutylene standard calibration

gas.

Respirable dust will be monitored during suitably dry conditions using a mini-ram or

equivalent dust monitoring meter. An Eberline ASP-1 radiation detector, or equivalent,

with a HP-260 beta/gamma probe and SP-A-8 gamma probe will also be used to assess total

beta and gamma emissions from the study area with respect to background levels. If

considerable dust is present, alpha emissions will also be quantified using a ASP-1 radiation

detector equipped with an AC-3-8 alpha scintillation probe. The radiation detector will be

calibrated to the manufacturer's specifications for the particular type of sensor used.

The monitoring points around the perimeter of the landfill will be located at

approximately eighty-foot intervals. The monitoring points located within the landfill area

and lagoon area will be located along a parallel line approximately forty feet east of the

retaining wall. This will correspond to an approximate total of twenty-one measuring

locations, of which approximately fifteen will be around the perimeter and approximately

six will be within the landfill area. Measurements will be taken at approximately eighty-foot

intervals. Locations for follow up and/or continued sampling, if necessary, will be

determined at the site, based on the results of these air samples. Meteorological conditions

preceding and during the air quality survey will be recorded and reported with the data. A

hand-held anemeter will be used to determine the wind conditions. The wind direction,

which will be determined at each monitoring point prior to sampling, will indicate whether

the measurements are upwind or downwind of the landfill. Monitoring will be a "breathing

zone" elevations (i.e., five feet above ground surface). HNu, ASP-1, and miniram


measurements will be taken for a minimum of three minutes. The high, low, and apparent

average readings and wind conditions will be noted in the health and safety notebook.

4.05.02. Wetlands Assessment

A preliminary wetlands survey will be conducted to evaluate areas around the site

that exhibit the characteristics of wetlands. A review of local, state and federal wetland

delineation maps will be conducted prior to the assessment to define existing designated

wetlands. Additionally, maps from the U.S. Soil Conservation Survey will be reviewed.

Existing delineations will be reviewed to identify the presence of hydrophitic

vegetation and hydric soils. Local hydrology will be reviewed for wetland characteristics.

Existing boundaries will be checked if they exist and if no wetlands have been designated,

areas exhibiting some or all wetlands characteristics will be identified. This assessment will

involve a visual screening of soil samples to evaluate coloration, structure and water content.

The area to be surveyed will extend 500 feet around the upgradient side of the site and

1,000 feet downgradient in a south and southeasterly direction.

4.05.03. Sensitive Environmental Receptor Survey

A preliminary review of the presence of rare and endangered or threatened species

will be conducted to identify the potential for sensitive environmental receptors.

Existing information developed by ANR's Department of Fish and Wildlife Natural

Heritage program will be reviewed to assess fragile areas. The Fish and Wildlife Board,

Water Resources Board, and Forests, Parks and Recreation Board will also be contacted

regarding sensitive areas.

4.05.04. Stream Flow Measurements

Stream flow measurements will be conducted during the course of the RI to develop

a data base containing surface water flows and estimates of runoff around the site. At the

time of flow measurements, antecedent precipitation conditions will be noted to provide a

qualitative assessment of flow during varying runoff conditions to evaluate the components

of ground water and surface water runoff to the streams.


During the LFI, one round of stream flow measurements will be collected at several

locations. When the stream flow measurements are collected, information regarding local

precipitation during the previous 72 hours will be noted.

Stream flow measurements will be collected at six specific points which will be

surveyed for future measurements. The points to be measured are shown on Figure 5 and

will include:

1. the unnamed brook at the toe of the former lagoon area

2. the unnamed brook 50 feet upstream from its confluence with Barney Brook

3. Barney Brook 50 feet upstream from its confluence with the unnamed stream

4. Barney Brook 50 feet upstream from its confluence with the Walloomsac

River

5. the Walloomsac River 50 feet up from its confluence with Barney Brook

6. the feeder stream adjacent to the eastern toe of the landfill.

These locations are shown on Figure 5. Additional stream measurements will be collected

during the course of the RI as specified in the RI work plan.

Readings of velocity will be collected using a mechanical Price Pygmy® rotating

current meter or equivalent for unit widths of the stream including correction factors for

friction, and turbulence. The operation and calibration of the meter will be completed

according to methods in the manufacturer' manual. Velocities will be measured at one-foot

stream segments at the midpoint of each section. The resultant velocities will be multiplied

by the measured channel area to obtain discharge in gallons per minute (gpm). The stream

flow measurements will be conducted according to procedures in the "National Handbook

of Recommended Methods for Water Data Acquisition", United States Department of the

Interior, 1981, and the "Stevens Water Resources Data Book", Stevens, Inc., 1987.

Open channel stream gauging stations will be established at locations where flows are

too low, (<0.10 ft/sec) to measure with a rotating meter device. Since stream flow

fluctuates and at times may be non-existent, V-notched water weirs will be constructeu at

the appropriate station. Triangular or V-notched weirs permit the accurate measurement

of very low flows and greatly reduces the random uncertainty of measurements. If

appropriate, notifications will be made to local agencies concerning the weirs.


To accommodate the range of flows anticipated, a 90° notched, sharp crested weir

with a metal strip will be constructed of marine plywood at each location. A six mil sheet

or plastic tarp will be installed on the upstream side of the weir lining the adjacent stream

channel and weir to prevent leaking. A splashboard will be used on the downstream side

to prevent erosion. Two by four studs and boulders or blocks will be placed along the weir

to support it. The stream area will be nine times the notch area to provide a consistently

measurable head. The notch will be 1.5 times as deep as the expected maximum head and

the weir crest or apex will be placed to accurately measure very low flow conditions and to

prevent overtopping.

A staff gauge or stilling well will be installed in the stream channel upstream of the

weir a minimum of four times the length of the maximum anticipated head. The gauge or

well will be surveyed relative to two independent reference points by running a level from

known points to elevation. The gauges will be affixed if possible to permanent structures.

The head reading above the weir crest or apex will be used together with a rating table to

establish flow.

4.06. Topographic Study Area Map Development

The USGS 7.5 minute Bennington and Pownal quadrangle topographic maps will be

used to develop a study area map which will present topographic, physiographic and cultural

features around the former lagoon area. This map will include an area of roughly one half-

mile radius around the former lagoon area. The map will show a larger area in

downgradient directions from the former lagoon area.

Following review of information gathered from the geographic reconnaissance, a

registered land surveyor will supervise the preparation of a base map of the former lagoon

area and immediately surrounding areas. The area included in this map will encompass a

radius of about 500 feet around the former lagoon area. The datum used will serve as a

benchmark for the USGS map (19z7 North American datum) along Burgess Road.

This map will present two foot topographical contours, existing monitoring wells,

sampling point locations, buildings, roads, drainage patterns, and fill areas as identified by

visual observations. Control points will be established at key areas around the landfill for

use in the geophysical surveys and screening efforts.


4.07. Ground Penetrating Radar (GPIO Survey

Terrain geophysical surveys have been previously conducted at the site by Geraghty

& Miller together with Zonge Engineering and Research in June 1988. This information

was summarized in the "Results of the 1988 Hydrogeologic Investigation at the Burgess

Brothers Superfund Site," Geraghty & Miller, 1989.

Results from the previous geophysical surveys conducted in the landfill area

qualitatively identified trends and estimated depths of the bedrock surface beneath the site.

The exact depth to bedrock, however, could not be determined. These surveys according

to Zonge suggest that a fault zone underlies the landfill and trends N 30° E.. A zone of

porous alluvium may be associated with the fault zone. The surveys also suggest that the

bedrock surface dips to the northwest at 13°. These geophysical surveys identified features

which may exist in the subsurface, but their presence was not confirmed. Therefore, a GPR

survey will be performed to further develop these hypotheses and to provide further

delineation of clay layers and the top of bedrock. According to Mr. Daniel Stanfill of.

Detection Sciences, the resistivity of the soils in the area as developed in the Zonge survey

is sufficient enough to permit penetration of 50 to 75 feet outside of filled land. The

penetration of the GPR beneath the landfill will be hindered by objects in the landfill.

Therefore, the GPR survey will be used to identify objects and the structure of the landfill

and naturally occurring stratigraphy outside of it.

A standard transmittal source of 120 mhz will be used unless resolution is required

in the uppermost layers (< 30 inches) in which a higher frequency transmitter will be used.

The GPR survey will be conducted to prepare an electromagnetic profile of the

subsurface structure, particularly in the overburden, in and around the site through a series

of continuous profiles. The general GPR survey area is shown on Figure 6. The survey will

focus on the structure of the landfill and the stratigraphy of immediately surrounding areas.

The primary objectives of the survey are to identify subsurface reflective anomalies i.e.

objects in the landfill and to develop a better understanding of the layering in the glacial

overburden around the landfill. The GPR survey will be used to evaluate the extent of clay

layers on the top of glacial till which could affect ground water movement. A secondary

objective of the survey is to identify the bedrock surface if it occurs at depths shallower than

50 to 75 feet. The GPR survey will be conducted using surveyed control points in an area


approximately 300 ft x 600 ft around the landfill. An all-terrain vehicle (ATV) will be used

in accessible areas. Otherwise, hand held equipment will be used. A low frequency

transmission source will be used to provide the maximum depth penetration and the greatest

resolution. The survey will be conducted by Detection Sciences, Inc. under contract with

O'Brien and Gere.

GPR traverses will be established along a regular grid spacing inside the landfill

boundaries. The initial spacing of the traverses on the landfill will be approximately twenty

feet apart and will run the entire length of the landfill boundary (as surveyed in 1985).

Subsequent traverses will be conducted based on the results of the initial transects.

Traverses around the landfill will be made in accessible areas radiating outward from

the landfill. Surveyed control points will be used to assist in locating the horizontal position

and vertical elevation. Exact traverses will be determined based on the site history review,

aerial photographs, geologic literature review, and data collected in the field which further

define fill conditions and geological stratification. Electrical ground conductivity data

developed by Zonge Engineering will be forwarded to Detection Sciences to develop the

best operating frequency for maximum penetration. At this point, an operating frequency

of 120 MHz is anticipated.

If the results of the GPR survey indicate that resolution of subsurface stratigraphy,

particularly outside of the landfill area, is unsuccessful, a seismic refraction survey or

electrical resistivity survey will be considered for the RI. These surveys, if necessary, could

be used to delineate the bedrock surface if it occurs deeper than the penetration capacity

of the GPR.

4.08. Vapor Screening Survey

A soil gas survey and a headspace screening survey will be conducted in and around

the former lagoon area. These surveys will be conducted to provide qualitative screening

of the presence of VOCs in various media and to compare findings to previous surveys.

4.08.01. Soil Headspace Screening in Marsh Soils

A screening program will focus on the presence of VOCs in near surface soils in the

marshy area downgradient of the landfill. Previous investigations have indicated that VOCs


have been detected in marshy area soils. These compounds have been identified as TCE,

PCE, and 1,2-dichloroethene isomers. The location of previous sampling points and

April 1989 total VOC concentrations in mg/kg are shown on Figure 7.

Analytical results indicated by soil sample numbers SS-3 through SS-7 (except SS-5)

indicated detectable VOC concentrations ranging from 100 to 16,000 mg/kg in the former

lagoon area and along the southeastern toe of the lagoon dike. Soil analyses were limited

to this area except SS-2, which was collected several hundred feet upgradient.

Soil headspace analyses conducted from samples along the toe of the lagoon dike,

again indicated detectable VOC concentrations of 2.7 to greater than 62.3 ppm. An area

of detectable VOCs was described in the R.F. Weston report and is shown on Figure 7. It

should be noted that additional samples were not collected outside of this zone to verify this

boundary.

This soil screening survey is designed to provide for a further delineation of VOCs

in near surface soils in the marshy area adjoining the former lagoon area. The soil gas

survey described in Section 4.08.03 will be used to screen for VOCs within the landfill and

in shallow ground water beneath the marshy area. The protective equipment to be worn

by field crews during sampling and surveying activities is described in the Health & Safety

Plan.

A total of eighteen soil samples will be collected from a depth of six to twelve inches

below grade. The proposed soil sample locations are shown on Figure 8. The soils will not

be composited to minimize the loss of volatiles to the atmosphere. A cleaned stainless steel

trowel or scoop will be used to excavate the hole. Cleaning procedures are discussed in the

decontamination protocol in Appendix A. Larger gravel sized rock fragments will be

manually removed from the sample.

At each location, the top six inches of soil will be removed. The exposed area will

then be screened with a PID calibrated as described in section 4.05.01. Readings will be

recorded in a field log. The operator will note potential factors affecting readings such as

temperature, humidity, and methane. The soil sample will then be collected according to

the procedure described in the protocol in Appendix B.

A constant temperature bath will be used to stabilize the temperatures of the soil

samples prior to analysis by the portable GC. A portable gas chromatograph (Photovac


10S70) equipped with a CPSIL-5 capillary column, isothermal column oven, and either a

10.6 or 11.7 eV photoionization detector will be used. The samples will be analyzed within

2 days (48 hours) of collection. The analytical procedures are described in the protocol in

Appendix C.

4.08.02. Surface Water and Sediment Screening

Nine stream sediment and surface water samples will be collected from the unnamed

stream, the feeder stream, and Barney Brook. Stream sediment and surface water samples

will also be collected from the same locations corresponding to SW-1 through SW-5

locations employed previously by Geraghty & Miller. These samples were collected to

evaluate water quality: 1) in the unnamed streams at locations upgradient, at, and

downgradient of the landfill area, and 2) in Barney Brook, up and downgradient from its

confluence with the unnamed stream. Sediment and surface water samples will also be

collected from: 1) The unnamed strea, upstream from the landfill area, 2) the feeder

stream, near its confluence with the unnamed stream, 3) Barney Brook, 50 feet upstream

from its confluence with the unnamed stream, and 4) Barney Brook, 50 feet upstream from

its confluence with Walloomsac River. The methods to be used to collect the samples are

described in the protocol in Appendix D. Seven samples will be collected as shown in

Figure 9.

In collecting surface water and sediment samples at each location, the surface water

sample will be collected from approximately one foot from the shore closest to the landfill

area. Sediment samples will be collected from the depositional areas of the stream. The

sampler will stand downstream to minimize agitation of the stream bed and surface water.

Samples will be collected at the downstream point first, proceeding upstream. In collecting

sediment samples, a cleaned shovel or post hole digging device will be used to collect a

sample to a depth of six inches below the stream bed. The sample will be placed in a clean

stainless steel tray and the least disturbed portion below the top two inches will be used for

the sample. Each sampling point will be staked and marked for future reference.

The headspace in the sediment sample will be screened using the portable GC

according to procedures in Appendix C. The stream water will be analyzed using the

portable GC following the same protocol as will be used for ground water (Appendix E).


Temperature, pH, specific conductance, and dissolved oxygen will be recorded. A

qualitative physical description of the sediment samples will also be recorded, including

parameters such as color, grain size, and presence of organic matter.

4.08.03. Soil Gas Survey and Water Table Screening

The soil gas/ground water table screening survey will be conducted in areas with

surveyed control points and a gridded system to maintain areal control of survey data. Each

sampling point will be flagged or staked and clearly marked for future reference.

Soil gas samples will be collected in the landfill area and in areas of higher terrain

around the landfill where sufficient vadose zone exists. Soil gas extractions will be collected

according to a regular grid on the landfill at 25 to 35 foot centers, although locations may

be altered somewhat based on in-field results. The soil gas survey will expand on the

previous survey which was limited to the southern half of the landfill. Ground water

headspace screening will be conducted in the marshy area around the unnamed stream.

This survey will be conducted to assess the presence of dissolved VOCs in the water table

zone associated with the marshy area.

The approximate location of the sampling points is shown on Figure 10.

Approximately 20 soil gas samples and approximately 10 ground water samples will be -•

collected. The exact number and location of each may change based upon screening results

obtained in the field. The PID will be used to pre-screen organic vapor concentrations to

identify subsequent sample locations. The sampling grid will be expanded until the total

VOC concentration falls below 100 ppb in each direction. The ground water sampling and

headspace screening will be conducted according to the protocol in Appendix E. The soil

gas screening will be conducted according to the protocol in Appendix F.

A transect will first be established, which will pass directly through the previously

identified "Hot Spot" in a north/south direction. This transect will run from the landfill into

the marshy area as shown on Figure lu. Samples will be spaced at approximately 25 to 35

foot intervals along this transect. Subsequent transects will then be established parallel and

perpendicular to this transect.


4.09. Existing Monitoring Well Evaluation and Analyses

4.09.01. Well Inspections

Existing monitoring wells W-l through 6, W-4D, and W-6D will be inspected to

evaluate their suitability for collecting additional water quality data and physical

measurements of water levels. The seal around the protective casing will be checked for

integrity to minimize infiltration of surface water into the monitoring well. Additionally,

slumping that has occurred around the well, which may indicate improper channelling of

surface or ground water will be assessed. If cracks are observed, they will be repaired with

an appropriate mixture of cement and bentonite. The depth of the well will be checked and

compared to the original depth. Relative plumbness will also be checked. Other than

minor sedimentation, the wells are expected to be usable because they are relatively shallow.

Particular attention will be paid to well W-4D, since it has been reported that the PVC

casing near the surface had cracked due to expansion of water from freezing.

4.09.02. Monitoring Well Re-Development

The wells will be re-developed to enhance the hydraulic connection of the well screen

to the aquifer interval bracketed. The goal of the re-development is to restore the hydraulic

conditions around the well to its natural state, and to minimize chemical alteration of

samples. Wells will be developed using a pre-cleaned stainless steel or disposable high-

density polyethylene (HDPE) bailer or other suitable device, , such as WaterraR hand

operated, positive displacement pump or equivalent. The bailing will cause a steepened

hydraulic gradient near the well which will cause sediment to flow into the well. Methods

to be used are described in the protocol in Appendix G.

Water from wells W-l, W-6 and W-6D will be screened for volatile organics and, if

none are detected, discharged at grade Water from other wells will be contained in five-

gallon buckets and transferred to D.O.T. type 17-E drums in the staging area, which will be

established on a suitable spot on the landfill. The screening and disposal of the

containerized water will be addressed in the Phase 1A RI Work Plan. Well development

will continue until the appropriate criteria are met as described in Appendix G.


4.09.03. In-Situ Hydraulic Conductivity Testing

The in-situ hydraulic conductivity tests will be performed by removing water from the

monitoring well in order to create sufficient hydraulic potential between the monitoring well

and the aquifer. The rate of change will then be analyzed using Bower & Rice or the

Papadopolus method.

If no significant drawdown can be obtained by bailing the monitoring well, an Enviro-

Labs Model DL 120 MCP pressure transducer system, or equivalent, will be utilized. This

test will involve inserting a teflon rod into the well in order to create a positive potential

between the well and aquifer. After the Enviro-Labs system records the response to the

positive potential, the teflon rod will be removed in order to create a negative hydraulic

potential between the well and the aquifer. The rate of the ground water recovery will then

be recorded using the Enviro-Labs system. The data collected from both the positive

displacement and negative displacement will be analyzed and compared to the results

obtained in previous investigations performed by Geraghty & Miller.

All equipment that is placed down the monitoring well will be cleaned with a

phosphate-free detergent wash and a distilled water rinse between each monitoring well.

4.09.04. Ground Water Level Measurements

A measuring point on each well that is not susceptible to the effects of frost heaving

will be identified and marked. These points will be surveyed during development of the site

topographic map to provide updated elevations relative to the USGS datum on Burgess

Road. Additionally, the distance between the well riser and the protective casing will be

checked and recorded to evaluate potential movements.

A minimum of 24 hours after development, water elevations will be measured by a

decontaminated electronic interface probe that senses both water and non-polar liquids i.e.

floating hydrocarbons. The readings will be recorded in a field log and dated. Readings

will be collected to the nearest 0.01 feet.

4.09.05. Ground Water Screening

Similar to screening performed on surface water and the water table zone in the

marshy area, a sample will be collected from each well for GC screening of deeper ground


water. The same protocols will be followed as will be used for other water screening tests.

(See Section 4.08.02 and Appendix E).

4.10. Field Screening of Metals

A semi-quantitative method will be used to screen for two metal ions in ground water

and surface water. E.M. Quant® colorimetric test strips will be used to screen the ground

water and surface water samples for indicator lead and nickel ions. The reported sensitivity

of the strips is in the low parts per million (ppm) range. Screening will be performed in

accordance with the protocols developed by the manufacturer (E. Merck, Dalmstadt,

Germany).

The samples to be screened for these ions include each of those in the following

sections of the LFI Work Plan:

Section 4.08.02 - nine surface water samples

Section 4.08.03 - ten shallow ground water samples (marsh area)

Section 4.09.04 - eight ground water samples from each existing well.

Screening will be performed in accordance with the protocols developed by the

manufacturer (E. Merck, Dalmstadt, Germany).


SECTION 5. INTERIM MEMORANDUM PREPARATION

Following completion of the tasks described in this LFI work plan, O'Brien & Gere

will prepare an interim memorandum. This memorandum will be submitted to the Burgess

Brothers Superfund Site Steering Committee, USEPA, and VTDEC.

The interim memorandum will summarize in narrative and tabular form the results

of the LFI work tasks and an assessment of the attainment of the DQOs. The

memorandum will also include a discussion of the findings of the field program compared

to previous results, any problems associated with the program, and contingencies

implemented to address the problems. A summary of the current environmental conditions

will be presented and significant data gaps will be identified. If necessary, recommendations

will be developed to address the need for emergency response measures or short-term

mitigation activities. Finally, the memorandum will identify the need for short- and long

term data gathering efforts in the form of objectives for Phase 1A of the remedial

investigation. Recommendations for changes in the scoping effort and focus of the remedial

screening will also be provided, if appropriate. The results of the LFI will be included in

the Work Plan for the RL


SECTION 6. SCHEDULE

Upon receipt of written approval by USEPA, efforts associated with the LFI will

begin. It is anticipated that the tasks described herein will be completed in six weeks and

that an interim memorandum will be submitted to USEPA six weeks following completion

of field tasks. The anticipated schedule for the LFI is shown in Figure 11.

Respectfully submitted,

O'BRIEN & GERE ENGINEERS, INC.

Robert C. Ganley, P.E Vice President

djb/wp27

Prepared by: Aamer Raza Richard G. Stromberg S. Edward Wilson, Jr., C.I.H.

Reviewed by: Jeffrey E. Banikowski Cheryl L. Cundall, P.E., Esq. John C. Tomik, C.P.G.


Figures

FIGURE 1

BURGESS BROTHERS

SUPERFUND SITE

WOODFORD AND BENNINGTON, VERMONT

SITE LOCATION MAP FILE No. 6271.001.01P

OrcniENGGERE ENGINEERS. ISJC

8

o Q..UJ ^ tN Z is WF O

OC

TOBE

R

99O(?5vj z o

ID ujt-OQQ mz UJ ec

FO-w§ 03 Z> 8|5BO §s s

m^ o

VE

LU n; o

^ o o o

§1

CO-

If i g A& 0

o

I1!o> o o 0!- <D

CD Q CQZ UJ C3 or CE Sz

(/>§; 03 UJ I

Z) Ek"£ VER

m o goS% O

CDw u. or o

CD 39 e o

o o

*

(*

dVD SSVU8 KLIM !N3hnNOW

iOVHL 30IAW3S !S3yOJ 'S'n jisavw w 9 » u 9

vl ^

FIGURE 4

STUDY AREA—'• LANDFILL AREABURGESS BROTHERS

SUPERFUND SITE

WOODFORD AND BENNINGTON, VERMONT

STUDY AREA MAP •ITt.OOLO

o o

gs 01 o o

i

LU a:

UJ "J2; s* o: LU

00 Ld li o o

Z> o

m o

o z UJ

u. O O o

/

1 \\ ,

4>:

•̂ <&-^x

UJtyUJh U 1

if o u

o 1, < O3

CD 1 dVO SSV8H CD HUM 1N3HONOW

s r u 9 * u 9

L. I { i

z o o

CD O) o

Oc/5 o> I CD Q o

LJ qo: Q

85 i uo: O mID

Z

°ro Q' e O 0 5

omc75 o u_ o oo

Of ol 10 I

I 03 GJ O C

X § >*. 3

V

\ \

o

OJ S o»

£S*"•»>._Hir^Su

JUZ dvo ssvsa HUM !N3^nNOtN

318dVfl W 9 * W 9

0.90

I

CO

O o5u Iff

| 3 *50 "̂ 000 b

O^O Z5-i -j 0> b^> n Z I

OD Q GQ OLU es l l s O)

C£ UJ UJ — fe o; =J(E ^3 o: O 00 OQ LU U. (/>(/) 2_l CNCD z> 10

o e o ino Q O Ol O O)

CO

b o

Q

en en CD

o o_ I— o to

UJ < 3^^: <. Q-

s? I*

Q . O> O liJ

§*: £s

'1 dvo ssvyg HUM !N3|AiniMOIAI

318HVW ^ 9 x U 9 •$• » CD • mmOD

II

O>-_J 2 O

O

2X=r! ZCOLj-LUQ^O

LU o: ID o

3$U-X

Ii 3OIOOD

5 S Q

Oil O a. o

-UJtoiccCDQ

? z

m 2

o Q

O)

CD O

o

Q_

—''

Qi

o (O

Q. 0) O I

O o

o

O O

co.

cc

ct s

$• «

•**

*

CD CD

§to oo

few UJ >o o zz 2 </>

8tr

^

IDVUl 30IAy3S 1S3HOJ 'STI

0

UJ a: rv-

ID 0

O< ^tOLrt

C)O — J

ol tt: <M

Ld UJ ct: ft:JrroW(f)

fl«<

8

2 i^^.

4

9s;

* * N!\ x

N

ssvya VHNO^

10VM1 30IAt)3S 1S3MOJ S n TiBbvnw 9 «w q

II

Oo: £o

•z.o

Q.11 Oo£ •z.

(— O in z O) S§£ ? O a:"' 0) UJ CO 00 Q ̂ £5 I" "S""1 ~z. <

JRG

ESS

PE

RFU

N

CTO

BE

R

sS5i£ a: fi2s I-. CM If}

O

— __J < h- UO -rf Q: _Jo2 < a. 0 (/:

a. §8 <t ° < < £235. u.

ctr o—' QJ CO ̂ 3 I-L. P UJ ^_ Q+ CO O 0

O

O

, 5 *

^ *

o r>

Q CD

IDVdl 30IAM3S

w g, S. Q | S

^ o 1n I

wact

iviti

es i

n t

scri

bes

« »i |j33

t-": 0*

IX (

activ

ities

in

2 ** I S ?V C 1IP i 1 \v c -3 < •->^ E P S •a*" c 5u *~" •9 w-o0 3 OT Q •S3UOT3 •

|| Vi J^H V<4 ao Q a-*CO 00 Pv,

EC. O

H 1 1i—i "S J CO O : ;

i—is i ; Q; ;

I||' ^ !'li—i 1 InP

f ~ i-4 i ;

IGA

TIO

N R

FUN

D

E- w CO III' CL— S'c

S f t\*. 5 *—* •

BR

OTH

ERS

SU

and

Ben

nin

gl

PRO

JECT

SC

HED

} 121 EQ S 1 \A!1 •̂ fc.1 •̂ o

| .* 0) •—i

E «a£ Is0 o

x£—< A08 4> nv *z.O £ f C aj okA

Flow

M

eas.

•—

•tw4

Inve

ntor

yri

eal

Rec

ord

lands

Ass

essm

ent

« is

itiv

e R

ecep

tors

«•••

earn

w| - 3 g i « S i § . c B i ; S « « 3 £ a s - i ? Irtoa ««'5J2-'-> - < ^ W 1 7 3 Q*0,W <s= * * a ^ c « « ^ ^ 0 -i W ' - ' C J o o ^ - j - ?;_

Rev

ie

aiu

re

nevi

ew "

•Q

uali

ty

Su

rvey

—

C C - "*"*E-H

Map

D

evel

opm

ent

o gE- T2 :co C C I) CDSH : <U 1 * * I. »- >>5 > ^ mOT- ^ w , o ( X i n -«̂0} iso

*" >> S (d W Q. S T3 CU

s O : w 5) C Jic o > o £ i C *»t>: t i £ cs 3 O*>"O <0nJ o CO "5 0. t<«O ^ w S , |5*s l

M^ \ n g < > W * - Q 'n

: "̂ => "o o — •£ "̂ P1—) O ^1CQ

m * i i •43 i o — Q c p ° 'D* CD nrt ^i « . ••3 o ; _ ^ H ^ H 2 5 4 > ^ cn 3

1° 0iCO

E^ CO W CO -* i r 3 i Q U 3 i o « D r - c o c o o J C » O J O 9 < O O 0 <3 O O O O O O O O O O O O *»1 c

^,^ ,^ ,^ .^^ .^ .^ ,^^c •* •* ^* •* ^*

w e-o z = a ECO

FIG

UR

E 1

ED

FIEL

D

INV

E

X

APPENDIX A1

DECONTAMINATION PROTOCOL OF SAMPLING EQUIPMENT

Introduction

Decontamination of reusable equipment used to collect samples is essential in order

to maintain chemical data integrity between screening locations. In general,

decontamination should allow for adequate cleaning of the sampling tools for the

contaminants found at the site. Different chemicals or mixtures of chemicals will require

the use of different cleaning methods or compounds. Compounds detected to date at the

Burgess Brothers site include metals and volatile halogenated organics. Screening in the

limited field investigation will include a cleaning method appropriate for these compounds.

Procedure

The method for decontamination will be that which most fully removes site

contaminants from the sampling equipment with least interference to the ultimate screening

procedure.

The general decontamination methods and compounds that will be used to remove

volatile organic compounds are as follows.

Equipment used for collection of samples for volatile organics analysis will be cleaned

by the following steps:

1. Wash equipment with a non-phosphate detergent solution (e.g. Alconox) and

a brush.

2. Rinse with potable tap water.

3. Rinse with reagent grade methanol.

4. Rinse thoroughly with deionized water.

5. For water samples, rinse the equipment at least two times with the media

being sampled before collecting a sample.

Information partially excerpted from "Standard References for Monitoring Wells", Massachusetts Department of Environmental Protection, Publication No. WSC-31091. (1991)

December 1991 i O'Brien & Cere Engineers

6. Repeat this procedure at each location.

7. For field screening, a simple swabbing and rinsing procedure will be sufficient

consisting of the steps noted above.

The source of rinse water is often from nearby public sources. The water used in this

program will be from the Bennington Municipal Supply. This should be noted and water

quality results obtained prior to use. If no volatile organic compound data are available,

a sample will be collected and analyzed by EPA Method 624 for volatile compounds prior

to field activities.

Cleaning fluids will be contained in appropriately sized tubs or buckets and will be

transferred to D.O.T. type 17-E liquid drums which will be stored and labelled in the drum

storage area on-site.

December 1991 ii O'Brien & Gere Engineers

APPENDIX B

SHALLOW SOIL SAMPLING PROTOCOL

Introduction

The purpose of this protocol is to provide methods and procedures for the collection

of soil samples that will reduce variability and encourage continuity in sample collection

protocols by samplers.

This protocol describes sampling devices and procedures for the collection of

disturbed samples at sites that are presumed to be either uncontaminated or contaminated.

The following sections describe various methods and equipment used to obtain

representative samples and some of the constraints upon their use. Samples to be collected

at the Burgess Brothers site will be near surface and will represent disturbed samples.

Method

Soil samples may be either discrete or composite. A discrete sample represents a

single location within the soil column; it must be used for all volatile organic analyses. A

composite sample represents a mixture of soil from more than one discrete location. Such

compositing procedures are not appropriate for samples obtained for analysis for volatile

organic compounds because the agitation of the sample results in a loss of volatiles from the

sample. Discrete soil samples will be collected from near surface soils at locations identified

in the work plan. The sampling device used to collect the soil samples will be either

cleaned or disposable scoops, hand trowels, or shovels. The practical sample depth of

scoops, hand trowels and shovels ranges from the surface to about two feet.

Procedures for Use

1. Carefully remove the top 6-inch layer of soil to the desired sample depth with

a clean tool.

2. If applicable, screen the area to be sampled using an organic vapor analyzer

and record readings in the field log. The PID screen is used as a field safety

procedure as well as for selecting potentially contaminated soil samples. The

December 1991 iii O'Brien & Gere Engineers

soil readings should be compared to action levels presented in the Health and

Safety Plan. The operator of the PID must be experienced in its use and

aware of the effect of factors such as temperature, humidity, or methane

affecting the instrument readings.

3. Using a clean tool, remove and discard a thin layer of soil from the area that

came in contact with the shovel.

4. Obtain a discrete soil sample using a stainless steel lab spoon or its

equivalent. If the sample is to be utilized for headspace screening, fill the

container halfway, leaving a more than adequate volume of headspace for

screening. Place the sample into two 40 ml VOA vials with teflon SEPTA

and screw on cap. In addition to analytical samples, a reference sample

considered representative of the soil may also be collected in a wide mouth

jar and stored for future use.

5. Check that a teflon liner is present in the cap of all analytical sample jars, if

required. Secure the cap tightly. Chemical preservation of solids is generally

not required. The samples will be analyzed according to the method in

Appendix C.

6. Label the sample bottle with the appropriate sample tag. Be sure to label

the tag carefully and clearly using indelible ink. Complete all appropriate

screening forms and record in the field log book. Use of pre-labeled bottles

aids greatly, particularly if gloves are being worn or weather conditions are

adverse.

7. Decontaminate equipment after use and between sample locations. Also

decontaminate sample containers and/or isolate them (such as sealing in

Ziploc bags).

8. Clearly mark each location with a stake or flag displaying the sample number.

December 1991 iv O'Brien & Gere Engineers

APPENDIX C

SOIL & SEDIMENT HEADSPACE PROTOCOL FOR

GAS CHROMATOGRAPH (GO ANALYSIS

Following are the procedures for headspace analysis of soil and sediment samples.

The samples will be analyzed using a Photovac 10S70 portable gas chromatograph (GC)

equipped with a CPSIL-5 capillary column, isothermal column oven, and a 11.7 eV

photoionization detector.

Sample Collection/ Preparation

Soil samples will be collected from a depth of approximately twelve inches below the

ground surface using a steel hand trowel or similar device. The following steps will be taken

to prepare each sample for portable GC analysis:

1. Two 40 ml voa vials equipped with teflon septa, filled halfway with soil, are

placed in a constant temperature bath at approximately 40° Celsius for 15

minutes.

2. The vial is then inverted and shaken thoroughly for 1 minute. The sample

is then allowed to reach thermal and phase equilibrium by standing in the

constant temperature bath for an additional 10 minutes.

4. A precise aliquot (20-100 M!) of headspace is withdrawn from the vial with a

gas-tight syringe and injected into the GC. The second vial serves as a

backup sample should reanalysis be required.

GC Calibration

The GC calibration will consist of: 1) initial calibration, and 2) continuing

calibration.

Initial Calibration: Prior to initiation of field activities, a four point calibration will

be performed for trichloroethene, tetrachloroethene, vinyl chloride, dichloroethene, 1,1

dichloroethane, 1,2-dichloroethane, 1,1,1-trichloroethane, toluene, ethyl benzene, andxylene.

Included will be a zero level standard or method blank and three unique concentration

December 1991 v O'Brien & Gere Engineers

levels. Detection limits are expected to be in the range of 1-25 ppb, with the exception of

1,1-dichloroethane, 1,2-dichloroethane, and 1,1,1-trichloroethane which are expected to be

in the range of 500 ppb due to their high ionization potentials.

A least squares regression will be used to develop an equation, for each calibrant,

relating calibrant peak area and concentration. Results of the sample analyses will be

quantified by comparison to the calibration equations. Sample peaks which are consistent

with a calibrant standard peak (on the basis of retention time) will be quantified using the

corresponding calibration equation. Sample peaks inconsistent with calibrant standards, if

any, will be quantified using the average of all calibrant equations.

Continuing Reference Calibration: During the field investigation, a mid level benzene,

toluene, and xylene (BTX) standard will be run at the start of each day and after every ten

samples to account for variations in instrument performance (e.g. retention time shifts,

detector response) throughout the study period.

The excursion value for retention time shift and response will be 20 percent. A

retention time shift or response variation of greater than 20 percent will facilitate

recalibration of the portable GC. Syringe blanks will be run until instrument response

returns to baseline. Baseline response will be established via the instrument blank run at

the beginning of each day of sampling. Duplicate analyses must agree within 20 percent,

on a total VOC basis, to be valid.

Quality Control

Quality assurance measures will be taken to increase the validity of the data,

including: (1) GC blanks, (2) equipment decontamination, (3) sample collection blanks, (3)

syringe blanks, (5) sampling variability evaluation, and (6) consistent and accurate record

keeping.

1. GC Blanks - GC blanks will be run at the beginning of every day. A GC

blank is a complete run done without injection, performed 10 evaluate

baseline instrument response. As appropriate, instrument response from the

"blank run" is subtracted from subsequent sample and calibrant runs, thereby

minimizing quantification errors associated with integration over baseline

variations.

December 1991 vi O'Brien & Gere Engineers

2. Equipment Decontamination - The hand trowel used to obtain the soil

samples will be decontaminated prior to collection of each sample.

Decontamination will involve a soapy water wash followed by a deionized

water rinse.

3. Sample Collection Blanks - A vial blank will be collected for analysis once per

day to assess the contribution of VOCs from the hand trowel and vial. A

sample collection blank is obtained by transferring one half of a vial worth

of clean sand into a vial using the hand trowel. Sample preparation and

analysis is conducted as described in the sample collection/ preparation

section.

4. Syringe Blanks - A syringe blank will be run after each calibrant run and after

each environmental sample which exhibits detectable levels of VOCs, syringe

blanks will be repeated as necessary until the instrument response returns to

baseline levels.

5. Analytical Variability - In order to assess the variability associated with

analysis of the soil headspace samples at the project site, two sets of duplicate

analyses will be performed.

6 Record Keeping - All chromatograms will be taped into an analytical

notebook. Information detailed on each chromatogram will include: Sample

number, site name, date/time of collection, date/time of analysis, column and

detector type, and gain settings. In addition to the information printed on the

chromatograms, field notes will be added as appropriate.

December 1991 vii O'Brien & Gere Engineers

APPENDIX D

STREAM WATER AND SEDIMENT SAMPLING PROTOCOL

STREAM WATER SAMPLING PROTOCOL

Introduction

The objective of surface water sampling is to collect a representative water sample

of the streams in the vicinity of the Burgess Brothers landfill.

Sample Containers

Place sample containers (40 ml VOA vials) near the sampling location. Label a self

adhesive label with an indelible marker immediately before sampling. Include sample

location, time, date, and sampler's initials. Attach the label to the container. Place clear

polyethylene tape over the completed label to protect it from water and abrasion.

Sample Collection

Sample locations for this project have been identified along streams containing

relatively low flows. It will be assumed that the midpoint of the stream about 6 inches from

the water surface represents an area of equal mixing. Therefore, take samples at this point

at each sampling location. Take the furthest downstream sample first and progress

upstream to minimize the affect from disturbance of the stream bed. Note, sediment

samples as described in the following section will also be collected from these locations at

this time. Water samples will be collected first.

Stand in the water downstream from where the sample containers will be filled. In

slow moving streams, care must be taken not to disturb sediments that may move upstream

to the collection area. Put on a pair of disposable PVC or latex gloves. Submerge the

sampling container and take off the lid. Rinse out the container once with the stream water.

Throw this rinse downstream of the collection area. Fill the container almost to the top.

For those samples to be screened, no preservative is necessary. Fill VOA vials completely,

i.e., do not leave any headspace or bubbles. Check to see that volatile vials are filled

December 1991 viii O'Brien & Gere Engineers

properly by inverting the vials immediately after filling. There should be no air bubbles

visible.

SEDIMENT SAMPLING PROTOCOL

Introduction

The objective of sediment sampling is to collect a representative sediment sample.

It is implicit in these procedures that associated surface water samples will be collected prior

to sediment samples in order to avoid collection of sediment materials which become

dispersed in the water column.

Sample Containers

For sediment samples, use two 40 ml VGA vials that contain a Teflon SEPTA. Fill

out a self-adhesive label using a waterproof marker immediately before sampling. Include

the following information: sample location, time, date, and sampler's initials. Place this

label on the jar and then place clear polyethylene tape over the completed label to protect

it from water and abrasion.

Sample Collection

A stainless steel scoop or spoon will be used to collect sediment samples. For

streams deeper than approximately one foot, attach the scoop to a piece of PVC pipe or

suitable conduit, adjust the angle to minimize spillage, and collect several sediment samples

below the current surface of the sediment. Place these scoops of sediment in a pre-cleaned

glass baking dish. For shallower streams, wade to the same spot the water samples were

collected, put on latex or PVC gloves, and scoop the sediment into the baking dish.

After collecting enough sediment to fill the glass vials, place the sediment in the vials

with a pre-cleaned, stainless steel cooking spoon or kniie to sample taking care to minimize

agitation. Scoop the sediment into the glass jar. Fill the jar half full. Decontaminate the

equipment according to the procedures in Appendix A.

December 1991 ix O'Brien & Gere Engineers

APPENDIX E

GROUND WATER HEADSPACE PROTOCOL FOR GROUND WATER

SAMPLE COLLECTION AND GAS CHROMATOGRAPH (GO ANALYSIS

Following are the procedures for headspace analysis of ground water samples. These

procedures are based upon the method of V.D. Roe, M.J. Lacy, and J.D. Stuart (Anal.

Chem. 1989, 61, 2584-2585).

The samples will be analyzed using a Photovac 10S70 portable gas chromatograph

(GC) equipped with a CPSIL-5 capillary column, isothermal column oven, and either a 10.6

or 11.7 eV photoionization detector.

Sample Collection/ Preparation

Temporary ground water well points, consisting of a slotted aluminum shield point

attached to a length of teflon tubing, will be installed via a hardened steel probe driven by

a hand held impact hammer (Bosch model #11209). Well points will be installed within the

top 2 feet of the first saturated zone if it occurs less than three feet below grade. The exact

depth of each temporary well will depend on the ground water elevation in the area. If

ground water is not encountered at the depth chosen for sampling (3 feet), a soil vapor

sample will be collected at a depth of preferably one to two feet above the water table at

that location. The approximate depth to ground water will be checked at each location by

inferring from water depths in wells. Protocols for the collection and analysis of soil vapor

samples are included as Appendix F.

Prior to collection of the sample, the hardened steel probe will be retracted 3-6

inches leaving the shield point intake slots exposed to ground water. Samples will be

collected in duplicate 40 ml glass vials, equipped with teflon septa, using a peristaltic pump.

Ground water samples collected from monitoring wells for headspace analysis will be

collected in accordance with the following procedures.

Sampling Procedures (BAILER)

Well development (appendix g) can be substituted for purging if done immediately

prior to sampling.

December 1991 x O'Brien & Gere Engineers

1. Identify the well and record the location on the Ground Water Sampling

Field Log.

2. Put on a new pair of disposable latex gloves.

3. Cut a slit in the center of a plastic sheet, and slip it over the well creating a

clean surface onto which the sampling equipment can be positioned.

4. Attach enough polypropylene rope to a bailer to reach the bottom of the

well, and lower the bailer slowly into the well making certain to submerge it

only far enough to fill one-half full. The purpose of this is to recover any oil

film, if one is present on the water table.

5. Pull the bailer out of the well keeping the polypropylene rope on the plastic

sheet or entirely off the ground. Empty the ground water from the bailer

into a clean glass container and observe its appearance.

6. Record the physical appearance of the ground water on the Ground Water

Sampling Field Log.

7. If a floating product is observed, estimate its volume and note this on the

Ground Water Sampling Field Log. Collect the floating product, if present,

into a 40 ml VOA container for volatiles analysis, if required. This sample

may also contain a water phase; however, only the floating phase will be

analyzed for volatiles. After this sample is collected, or if no floating product

is found, proceed to the next.

8. Continue sampling by lowering the bottom loading stainless steel bailer slowly

into the well making certain to submerge it only far enough to fill it

completely. Calculate the volume of water present in the well casing at

stagnant conditions and then bail three to five volumes prior to collecting the

sample.

9. Record the physical appearance of the ground water observed during

sampling on the Ground Water Sampling Field Log and fill the \ OA vials

carefully to minimize agitation. Make sure no air bubbles can be seen in the

vials.

10. Clean the bailer according to procedures in Appendix A. Store the clean

bailer in a fresh plastic bag.

December 1991 xi O'Brien & Gere Engineers

11. Replace the well cap, and lock the well protection assembly before leaving

the well location.

12. Place the polypropylene rope, gloves, and plastic sheeting into a plastic bag

for disposal.

13. Completely fill the 40 ml VOA vials with water from the bailer, taking care

to minimize agitation by pouring carefully along the inside wall of the vial.

14. Seal each vial with a septum and cap, making sure no air bubbles are

entrapped in the vial.

Sample Preparation

The following steps are taken to prepare the sample for headspace analysis:

1. Two 40 ml voa vials equipped with teflon septa, filled completely with

sample, are placed in a constant temperature bath at 40° Celsius for 15

minutes.

2. A syringe needle is placed through the septum of one vial to act as a vent

while 10 ml of the water sample is removed by a 10 ml glass syringe.

3. The vial is then inverted and shaken thoroughly for 1 minute. The sample

is then allowed to reach thermal and phase equilibrium by standing in the

constant temperature bath for an additional 10 minutes.

4. A precise aliquot (20-100 M!) of headspace is withdrawn from the vial with a

gas-tight syringe and injected into the GC. The second vial serves as a

backup sample should reanalysis be required.

GC Calibration


calibration.






December 1991 xii O'Brien & Gere Engineers













Quality Control




keeping.


blank is a complete run done without injection, performed to evaluate




variations.

2. Equipment Decontamination - The peristaltic pump used to obtain the water

samples will be decontaminated prior to collection of each sample.

Decontamination will involve purging the tygon tubing within the pump head

with deionized water.

3. Sample Collection Blanks - A peristaltic pump blank will be collected for

analysis once per day to assess the contribution of VOCs from the collection

mechanism. A sample collection blank is obtained by passing deionized

December 1991 xiii O'Brien & Gere Engineers

water through the peristaltic pump tubing and collecting it in a 40 ml glass

vial. Sample preparation and analysis is conducted as described in the

sample collection/ preparation section.




baseline levels.

5. Sampling and Analytical Variability - In order to assess the variability

associated with collection and analysis of environmental samples at the

project site, two sets of replicate samples will be collected and analyzed and

a two sets of duplicate analyses will be performed.

6. Record Keeping - All chromatograms will be taped into an analytical





December 1991 xiv O'Brien & Gere Engineers

APPENDIX F

SOIL GAS PROTOCOL FOR SAMPLE COLLECTION AND

GAS CHROMATOGRAPH (GO ANALYSIS

Following are the procedures for the collection and analysis of soil vapor samples.

The samples will be analyzed using a Photovac 10S70 portable gas chromatograph (GC)

equipped with a CPSIL-5 capillary column, isothermal column oven, and either a 10.6 or

11.7 eV photoionization detector.

Sample Collection

Slotted aluminum shield points attached to a length of teflon tubing will be installed

via hardened steel probes driven by a hand held impact hammer (Bosch model #11209).

Due to the variability in depths to ground water at the site, an attempt will be made to

insert the probe from one to two feet above the water table. Prior to collection of the

sample the hardened steel probe will be retracted 3-6 inches to expose the vapor intake slots

of the shield point. A sample is collected by attaching a 50 ml ground glass syringe to the

installed teflon tubing/shield point assembly and drawing back the plunger. The sample is

secured by closing the stopcock of the syringe until analysis is initiated. A precise aliquot

(20-100 M!) is then drawn from the 50 ml syringe by a graduated, gastight 100 v\ syringe and

injected into the GC.

GC Calibration


calibration.






December 1991 xv O'Brien & Gere Engineers













Quality Control




keeping.


blank is a complete run done without injection, performed to evaluate




variations.

2. Equipment Decontamination - The hardened steel probes used to install the

aluminum shield points will be decontaminated between samples either by

1) wiping down the probe and flushing ambient air through the system, or 2)

ysing a soapy water wash following by a deionized water rinse.

3. Sample Collection Blanks - A sample collection blank will be collected for

analysis once per day to assess the contribution of VOCs from the collection

apparatus. A sample collection blank is obtained by passing ambient air

December 1991 xvi O'Brien & Gere Engineers

through the sample collection apparatus and collecting it in a 50 ml glass

syringe.




baseline levels. Syringe blanks will be run for both the 40 ml ground glass

syringe and the gas-tight 100 ul syringe.

5. Sampling Variability - In order to assess the variability associated with

collection of environmental samples at the project site, two sets of replicate

samples will be collected and analyzed.

6. Record Keeping - All chromatograms will be taped into an analytical





December 1991 xvii O'Brien & Gere Engineers

APPENDIX G

WELL DEVELOPMENT

Introduction

Each monitoring well will be developed to remove fine grained materials and

sediments and to allow the screen to transmit representative portions of the ground water

from the entire screened length. Development will be accomplished by bailing from the well

five to ten well volumes of ground water or until it yields stabilized readings of pH,

conductivity, and temperature, which ever occurs first.

Procedure

Removal of five volumes of water from the PVC annulus will be sufficient to replace

two volumes of water from the filter pack. After five volumes are removed, tests of pH,

specific conductance, and temperature will be conducted a minimum of every 1/2 well

volume by use of a Corning series PS portable pH meter or equivalent and a YSI Model

salinity, conductivity, temperature (SCT) meter or equivalent. Readings of pH fluctuating

not more than one-half of one pH unit, specific conductance not more than 25

micromhos, and temperature not more than 2°C for two consecutive events together with

a visual appearance of clear water with little or no suspended particles will constitute

cessation of development. If after 10 volumes the water appears clear but a fluctuation

described above for any or all parameters is exceeded, development will cease.

The meters will be calibrated every morning or as needed by use of pH 4.0 and 10.0

buffer solutions for the pH meter and calibration functions included in the SCT meter.

Ground water will be bailed from the well using a decontaminated stainless steel

bailer or disposable HDPE bailer. Development volumes will be measured by a graduated

containment vessel. A clean plastic sheet will be placed on the ground to avoid

contaminating the bailing equipment with any surface contamination. A new polypropylene

rope will be used on the bailer for each well. Development water from wells W-2, W-3,

W-4, W-4D, W-5, and W-5D will be contained and stored at a drum storage area on site.

Development water at wells W-l, W-6, and W-6D will be screened for volatile organics; if

December 1991 xviii O'Brien & Gere Engineers

none are detected, the development water will be discharged to ground surface away from

the well head at each respective well location and allowed to percolate back to the water

table. Contaminated development water will be properly stored for subsequent disposal.

December 1991 xix O'Brien & Gere Engineers

work plan, limited field investigation · 2.7 5271.001 work plan limited field investigation...

Documents