Mr. Russell W. Rohloff DuBois & King. Inc. P.O. Box 339 Rardolph~ VT 05060

74812 Decerltler 1 , 1988

lflPOPftTOfY Hl!V1C£S

Box 339 Randolph, Vermont 05060-0339 (802) 728-3379

SlBJECT: Mt. Mansfield Coopany Special Wastes Analysis

Dear~=

Attact-ecl are the VOC and Oil & Grease results for the Mt Mansfield Corrpany. The sarrple identification rurreers are as follows:

ID #

1 2

3 4 5 6 7 8 9

MATRIX

Soil Soil

Soil Soil

Water Water Soil Soil Soil

DESCRIPTI(J\1

Coopressor Pad - Post Excavation Downgradient from Diesel Fill Spouts - Post Excavation Con-pressor Pad - Excavated Material QJad Chairli ft Site Spruce Peak Maintenance Area~ upstream of culvert Con-pressor Pad Area, upstream of culvert Underreath Oil Storage Tank - Excavated Material Underneath Oil Storage Tank - Post Excavation Spruce Peak Maintenance at wall base - Excavated Material

Oil & Grease was determined using Sohxlet extraction and gravimetric analysis using Standard Method 503C.

VOC 's were determined using EPA Extraction Method 5030 and analysis by Method 601 & 602.

If there are any CJJSStions~ please feel free to call me.

RJL/jf

Very truly yours,

.--..... 5lCilEST, DC. 'i

( _) r 1' '/ (.--z~~Uc~- JC,J~~ ROderick J~ ~the Laboratory Director

LABORATORY f£~T

a....IENT ~= Ht Mansfl.eld Co, Inc. DATE CF ~: 11/09/88 DATE CF f£CEIPT: 11/12/88 DATE ~ YZED: 11/22/88

~ UX'ATICJ\1: Sites 1-9 LABORATORY N.ffiER: 1564-88 PROJECT NUMBER: 74812

SOILS

PA~R SITE #1 SITE #2 SITE #3 SITE #4

Chloranethare <100 <100 <100 <100 Bromoform <100 <100 <100 <100 Bromomethare <100 <100 <100 <100 Dibromochloromethane <100 <100 <100 <100 Vinyl Chloride <100 <100 <100 <100 2-ctlloroethyl vinyl Ett-er <100 <100 <100 <100 Chloroethane <100 <100 <100 <100 Methylene Chloride <100 <100 <100 <100 Trichloroethylene <100 <100 <100 <100 Trichlorofluoromethane <100 <100 <100 <100 1,1-Dichloroethene <100 <100 <100 <100 1,1-Dichloroethane <100 <100 <100 <100 cis or trans-1,2-Dichloroethylene <100 <100 <100 <100 Chloroform <100 <100 <100 <100 1,2-Dichloroethane <100 <100 <100 <100 1,1,1-Trichloroethane <100 <100 <100 <100 carbon Tetrachloride <100 <100 <100 <100 Bromodichloromethane <100 <100 <100 <100 1,2-Dichloropropane <100 <100 <100 <100 trans-1,3-Dichloropropene <100 <100 <100 <100 cis-1,3-Dichloroprqpene <100 <100 <100 <100 1,1,2,2-Tetrachloroethane <100 <100 <100 <100 1,1,2-Trichloroethane <100 <100 <100 <100 Tetrachloroethylene <100 <100 <100 <100 Benzene <100 <100 <100 <100 Toluene <100 <100 <100 <100 Ethylbenzene <100 <100 <100 <100 Chlorcbenzene <100 <100 <100 <100 1,4-Dichlorobenzene <100 <100 <100 <100 1,3-Dichlorobenzene <100 <100 <100 <100 1,2-Dichlorobenzene <100 <100 <100 <100 Xyleres <100 3010 <100 214 BTEX <100 3010 <100 214 &Jrrogate Recovery

(sec - Buty/benzene) 96.0% 109.1% 90.9% 76.4%

EPA Method 601 & 602; all results reported as ug/kg (ppb) dry weight of soiL

Respec:tfull y 5Ubmi tted,

~~ . "· 1 ~J. '~ Laboratory Director

R.JL/jf

®~~.~1I~~v

LABORATORY REPORT

QIENT Nt¥'£: Mt Mansfield Co, Inc. ~ LOCAT!()\1: S:i tes 1-9 LABORATORY I'U13ER: 1564-88 PROJECT N..ffiER: 74812

PAM"ETER

Chloromethane Bromoform Bromomethane Dibromochloromethane Vinyl Chlonde 2-chloroethylvinyl Ether Chloroethane Methylene Chloride Trichloroethylene Trichlorofluoromethane 1,1-Dichloroethene 1,1-Dichloroethane cis or trans-1,2-Dichloroethylene Chloroform 1,2-Dichloroethane 1,1,1-Trichloroethane Carbon Tetrachloride Bromodichloromethane 1,2-Dichloropropane tr.ans-1,3-Dichloropropene cis-1,3-Dichloropropene 1,1,2,2-Tetrachloroethane 1,1,2-Trichloroethane Tetrachloroethylene Benzene Toluene Ethylbenzene Chlorobenzene 1,4-Dichlorobenzene 1,3-Dichlorobenzene 1 ,2-Dichlorobenzene Xylenes BTEX

WATERS

SITE

<1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 r· -..l

<1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1

1 <1 <1 <1 <1 <1

4 5

MTE CF ~: 11/09/88 MTE CF f£CEIPT: 11/12/88 DATE ~.YZED: 11/22/88

1t5 SITE #6

<1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1

EPA Method 601 & 602; all results reported as ug/1 or ppb.

Respectfully subnitted,

RJL/jf

LABORATORY kEPORT

O....IENT ~: Mt Manfield Co, Inc. DATE CF ~: 11/09/88 DATE CF NECEIPT: 11/12/88 DATE ~YZED: 11/22/88

~ LCCATI(]\j: Sites 1-9 LABORATORY NJ'13Ek: 1564-88 PROJECT NUMBER: 74812

PA~R

Chloromethare Bromoform Broroomethare Dibromochloromethane Vinyl Chloride 2-chloroethylvinyl Ether Chloroethane Methylene Chloride Trichloroethylene Trichlonofluoromethane 1,1-Dichloroethene 1,1-Dichloroethane cis or trans-1,2-Dichloroethylene Chloroform 1,2-Dichloroethane 1,1,1-Trichloroethane carbon Tetrachloride Bromodichloromethane 1,2-Dichloropropane trans-1,3-Dichloropropene cis-1,3-Dichloropropene 1,1,2,2-Tetrachloroethane 1,1,2-Trichloroethane Tetrachloroethylene Benzene Toluene Ethylbenzene Chlorobenzene 1,4-Dichlorobenzene 1,3-Dichlorobenzene 1,2-Dichlorobenzene Xyleres BTEX SUrrogate Recovery

(sec-Buty benzene)

SOILS a.A...ITY CXNTFn.. SPIKE CF SITE #1

SITE #7 SITE#S SITE #9 @2540 LG/KG

<100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 113

<100 <100 <100 <100 <100 578 691

98.2%

<100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100

92.5%

<100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100

94.5%

<100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 <100 86.6% 87.9% 90.1% 96.5% 84.2% 84.7% 87.2% 85.0%

87.6%

EPA Method 601 & 602: all results reported as ug/kg (ppb) dry weight of soil Spike Results e><pressed as % recovery

Respectfully submitted,

RJL/jf

QIENT ~:

ADDJ£SS:

ATTENTICJ\f:

LMORATORY f£PORT

lfiBORfiTORY HRVIC'£5

Box 339

Randolph, Vermont 05060-0339 ( 8021 72 8-3379

Mt Mansfield Co. LMORATORY REFERENJE 1'1[). : 1564-88

c/o DuBois & King, Inc. Pm:JECT 1'1[). : 74812 P.O. Box 339 Randolph, VT 05060 DATE CF f£CEIPT: 11/12/88

DATE CF f£RJRT: 11/23/88

Russell Rohloff DATE CF ~PLE: 11/09/88

f£SLLTS

(Expressed as milligrams per liter mg/1 except as noted)

1 2 3 4 7 8 9

RJL/jf

% SCLIDS

89.5 86.2 84.3 89.4 92.4 93.3 90.8

% OIL & GREASE

0.512 2.07 2.33 1.77 3.45 0.312 O.CE

rick J. Lamothe Laboratory director

OIL&~

I"§/ KG

5120 20700 23300 17700 34500

3120 00

QIENT NlV'£: Mt Mansfield Co., Inc.

ADDRESS:

A TTENTI(J\1:

DuBo1s & Klng, Inc. P.O. Box 339 Randolph, VT 05060

Mr. Russel W. Rohloff

lf!80RfiTORY S£RV1C£S

Box 339

Randolph, Vermont 05060-0339 (8021 728-3379

LABORATORY REFEREf\0: t-U.: 1564-88

PROJECT f\[).:

DATE CF ~!=Lf: DATE CF RECEIPT: DATE CF EXTRACTI (J\1: DATE CF ~ YSIS: DATE CF KERJRT:

1 1/CA/88 11./12/BS 11/21/BS 12/02/BS 12/13/88

K£Sl.LTS

(Expressed as micrograms per kilogram ug/kg except as noted)

PA~R

Benz ere Toluere Ethylbenzere Total Xylenes BTEX Chlorobenzere 1,2-Dichlorobenzene 1,3-Dichlorobenzere 1,4-Dichlorobenzere n-Hexare Total FID Hydrocarbons (including BTEX) as n-Hexare

EPA Method 602 with FID scan.

RJL/jf Form 01

SITE tt8 ---

<100 <100 <100 <100 <100 <100 <100 <100 <100 <100

365

Respectfully submitted,

SCI TEST, INC. i I

I

\ / ·:, -\I 1~ I , \.r1~ V-._ \../ r Jo). Jl'>- 1\.Utl

Rodenck J. Lamothe Laboratory Director

SITE ttl

<100 <100 <100 <100 <100 <100 <100 <100 <100 <100

647

a TENT ~: Mt Mansf1eld Co., Inc.

ADDRESS:

ATTENTia-J:

fXJBOl '5", & K 1 ng , l nc . P.O. Box 339 Randoloh, VT OSC«"J

Mr. Russel W. Rohloff

tABO~RTORY S£RVlC£S

Box 339

Randolph, Vermonr 05(''>0-0339

(802' 728-3379

LABORATORY ~REI\Ct f\0.: 1564-88

PROJECT 1\[). :

DATE CF SAt1FLE:

DATE CF F\ECEIPT:

DATE CF ANALYSIS:

DATE CF F\EFORT:

11/00/83

11/12/88

12/02/88

12/13/88

RESU..TS

(Expressed as micrograms per liter ug/1 except as noted)

PA~R

Benzene Toluene Ethyl benzene Total Xylenes BTEX Chlorobenzene 1,2-Dichlorobenzene 1,3-Dichlorobenzene 1,4-Dichlorobenzene n-Hexane Total FID Hydrocarbons (including BTEX) as n-Hexane

EPA Method 602 with FID scan.

RJL/jf Form 01

SPRl..CE (SITE #5) CCJ'1PRESSOR

<1 <1 <1 <1

1 <1 3 <1 4 <1

<1 <1 <1 <1 <1 <1 <1 <1 <1 <1

15 <1

Respectfully submitted,

(SITE #6)

lfl!ORRTORY HRVICES

Box 339

Randolph, Vermont 0.".060-0339

(802' 728-3379

a_ rENT ~: ML Manshel d C'.ofl"Pc3nv LPBORATORY REFEREf\Cf" I'D_ : 1564-88

ADD~SS:

ATTFNTJ(]\1:

Property ():)eratl on<;; Stowe, VT 05672

Jim Marsh

PR'"'JJECT f\¥.1. : 74R1~

DATE CF RECEIPT: 11/11/88

DATE OF REPORT: 01/05/89

DATE CF ~!=LE: 11/10/88

-------------------------------------------- -------

RESLLTS SOIL IDtt 1

(Expressed as milligrams per kilogram mgjkg except as note::!)

PAfW'ETER REPLICATE 1 REPLICATE 2 REPLICATE 3 AVERAGE %RECOVERY -----·---

Cactnium 1.06 1.30 1.18 99

Chromium 25.4 30.6 28.0 112

Copper 33.2 32.2 32.7. 92

Lead 17.0 13.0 15.0 96

Nickel 45.9 49.8 47.9 103

Zinc 95.4 102.6 99.0 73

Barium 26.9 30.6 36.5 31.3

Silver <1.4 <1.5 <1.4 <1.5

Mercury <0.10 <0.10 112

Arsenic 12.9 13.1 13.0 78

Selenium <0.35 0.84 0.60 50

Al T!NTJ[J~:

U~DRATORY REFEREN:T NJ.: 1564-88

Property Q:ler-atlon=. Stowe, \/1 05672

J 1m M.=wsh

RESLLTS

PROJECT NJ. :

DATE CF RECEIPT:

DATE CF REFDRT:

DATE CF ~!=t_E:

SOIL ID# 2

74812

11/ll/88

01/05/89

ll/10/BE

(Expressed as milligrams per kilogram mg/kg except as noted)

PAR~ER RE!=t_ I CA TE 1 RE!=LJCATE ..., RE!=t_TCATE 3 BYE RAG: %~CO'v'ERY "---------- -------

carnnum 1. 14 1.34 1.24 99

Chromium 22.9 '7?.9 26.4 103

Copper 28.3 35.4 31.9 101

Lead 14.5 16.5 15.5 95

Nickel 30.1 37.0 33.6 102

Zinc 84.3 g::}_9 92.1 112

Barium 31.9 37.8 35.2 35.0

Silver <1.2 <1.6 1.8 1.5

Mercury <0.10 <0.00 <0.10 108

Arsenic 10.4 11.3 10.9

Selenium <0.30 <0.39 <0.39

lJENl ~ Mt ~ref J ela LPBORA TORr RE.t- Ek£r._.I N..J. : 1 StA -ffi

ADDJ:;ES.C:- :

;;TTFNTTCN:

Property Q::Jer at 1 :x~

Stowe, Y1 0567':'

J1rn ~rsh

PROJECT NJ.:

DATE CF R:::Cfl PT:

MTE CF REJ:DRT:

DATE CF SA"'lf:t..E:

~SLLTS

SOIL Irnt3

(Expressed as m1llig~ams per kilogram mg/kg except

PAR?V-ETER RER .. ICATE 1 FC!=LICATE ::? f\£!=L I CA TE 3 --------- ------~--~--

Cacinium 1.14 1.86

Chromium 40.5 53.8

Copper 24.8 27.4

Lead 17.0 16.6

Nickel 54.7 56.7

Zinc 89.5 104.6

Barium 27.0 44.0 39.5

Silver <1.4 <2.0 1.5

Mercury <0.10 <0.10

Arsenic 8.9 10.9

Selenium <0.35 <0.49

7481':'

jl/11/88

01/0S/f3CI

11/10/88

as noted)

AVERAGE %RECOVERY ---------- ------------

1.50 go

47.2 90

26.1 97

16.8 105

55.7 82

97.1 103

36.8

<2.0

<0.10 100

9.9 67

<0.49 70

L~ORATORY h£!=GRI

0~ !EN1 r~: Mt M3nsfle1d LPBORATORY REFERENCE 1\U. : 1 ~.4-BS

ADDR:::SS· Propertv CPerat1ons Stowe , \.'T 056 72

PRCDECT 1\U. : 74812

ATTENTifl'>l: Jim M3rsh

DATE CF hECEIPT:

DATE CF RE!=GRT =

DA IT CF SCV1R_E :

RESLLTS SOIL IDn 4

11/11/88

01/05/88

11/10/88

(Expressed as milligrams per kj logram mg/kg except as noted)

PARI't'ETER RER..ICATE 1 REJLICATE 2 %RECCNERY ---- "-----·· -

Cadnium 1.36 1.25 1.30 <;l]

Chromium 61.4 41.8 51.6 98

Coppe:- 28.1 29.3 28.7 88

Lead 23.0 19.8 21.4 90

Nickel 92.1 80.7 86.4 78

Zinc 186.8 ?=)7 .8 242.3 46

Barium 40.9 40.3 43.8 41.7

Silver <1.7 <1.5 1.5 1.5

Mercury <0.10 0.15 0.12 80

Arsenic 8.1 11.5 9.8

Selenium 1.11 0.59 0.85

ADDFC~·.

ATTFNTI Cl\1:

;_,!::i"iQRh TOh'Y R::PORT --------~----··-·------

r-·~- o;::>er· tv C.r>er-at 1 orr:: PRCJ.JECT t.n .. ~:vlW". VT oc-..:·,7:::

Jim Marsh

DAIT CF RF<TJGT· 11/Jl/88

DATE OF REPORT: 01/05/89

f£SLLTS SOIL IDtt 7

11/10/88.

(Expressed as milligrams per kilogram mg/kg except as noted)

PAF¥V"ETER J;EFLICATE 1 I£FLICATE 2 REFLICATE 3 AVERAGE %1£CCYv'ERY ----·- ----·-- ----------

Cadnjum 1.2::' 1.3(, ] . '27 97

Chromjum 81.5 74.6 78.1 119

Copper- ,.,- -L..) • .) 23.7 23.5 92

Lead 67.5 71.0 69.3 96

Nickel 124.6 108.3 116.5 95

Zinc 153.7 164.3 159 9]

Barium 32.0 41.6 38.9 37.5

Silver <1.2 <1.4 <1.6 <1.6

Mercury <0.10 <0.10 <0.10 104

Arsenic 8.6 6.8 7.7 168

Selenium <0.30 <0.36 <0.36 70

LABORATORY REJ:DRT

Q TENT Nl\'f: Mt M3nsfleld C~any

ADDJ;ESS:

ATTF.NTia~:

Property Q:>erat1ons Stowe, VT 05672

PROJECT 1\[}. : 74812

DATE CF RECEIPT: 11/ J 1/88

.J 1 m M3r--sh

DATE CF h£AJRT: 01/0~/8':~

DATE CF S?V1P, F:

RESLLTS SOIL ID# 8

11/10/88

(Expressed as milligrams per kilogram mg/kg except as noted)

PA~R REA..ICATE 1 REA..ICATE 2 REA..ICATE 3 AVERAGE ----·-

Camium 1.25 1.20 1.22 CA

Chromium 65.3 92.1 78.' 86

Copper 24.2 23.2 23.7 92

Lead 26.4 32.2 29.3 88

Nickel 106.4 128.8 117.6 62

Zinc 78.5 77.9 78.2 87

Barium 31.6 37 . .4 38.4 35.8

Silver <1.5 <1.5 <1.5 <1.5

Mercury 0.00 0.09

Arsenic 7.6 8.9 8.3

Selenium 0.81 <0.37 0.59

D TENT ~ · 11! M:o~ns+ 1 e} a Corrpan\ LABORATOPY I;EITF;E"N:£ NJ.: 15cA-8F.

ATTENTJCN: J1m Marsh

Pm.JECT r'I[J. : 7481::'

f>.ClTF CF ~Cf"J PT: J 1/ l 1/BR

DATE CF h£PORT: 01/05/SCI

DATE CF S?Y1R...E:

J;£St.L TS SOIL H»> 9

11/10/88

(Expressed as milligrarms per kilogram mg/kg except as noted)

PARt¥-ETER h£~ICATE 1 --------

Cactrnum ] .28

Chrcxmum 62.5

G::1pper 30. J

Lead 22.6

Nickel 98.6

Zinc 85.8

Barium 33.9

Silver <1.5

Mercury <0.10

Arsenic 8.6

Seleniun. 0.68

RJL/jf

REH ... ICATE 2 ME~ICATE 3 AVER/¥2£ %M£COVERY

1.14

84.5

34.9

22.1

122.7

81.1

33.5

<1.3

0.12

8.2

0.60

1.21 101

73.5 79

32.5 87

22.4 103

110.7 72

83.5 85

35.5 34.3

1.6 <1.6

<0.12 102

9.4 8.7

0.64 100

Respectfully submitted,

~ST, I. N~C

\!~ ' 1lr o~ a. f11v\,~ .

Roderick J. Lamothe Laboratory Director

STEPHE~ C. KNIGHT. JR., P.E.

KNIGHT CONSULTING Ei,;GJI'EERS. lNC.

P.O. Box 29 WII.LISTO!\, VERMONT 05495

RoGER w. DoRWART, P.E. ELRm L LANGDEtl. P .E. Gn' BARLOW, P.E.

:')! :r )!S ~ '-::!"".!·:""~ INC. i .

00l'AlD .~ PARKER, P.E. BoNNII L CARPESTH .• P.E.

· · r /!/Of l [ · ~·~ · ~ ~ o./ sr-f,/

For: DuBois & King

Prcject: Mt. Xansfield (KCE #88649)

Date: 12-19-88

Subject: Coefficient of Permeability by the Falling Head Method.

Sample: #1 ~~ OPTIMUM DRY DENSITY: 120 pcf * OPTU1UM MOISTURE: *Estimated Value. DENSITY OF SAMPLE AS TESTED: 119. 2 pcf % OF OPTIMUM DENSITY: 99 % *

COEFFICIENT OF PERMEABILITY:

Sample: #2 SPRUCE PEAK OPTIMUM DRY DENSITY: 126 pcf * OPTIMUM MOISTURE: *Estimated Value. DENSITY OF SAMPLE AS TESTED: 125.7 pcf % OF OPTIMUM DENSITY: 100 % *

COEFFICIENT OF PERMEABILITY:

Submitted by: Reviewed by:

- %

-5 2.4x10 em/sec.

"' - /o

-5 3.3x10 em/sec.

!j#1ir ~v:S:J ~~rwart, P.E.

! Jeffrey Fay

Vice President JF/kld

File: 88649-LAB2-1

100

90

80

70 I­X CJ 60 iii 3: > 50 m a: w 40 z u: -&. 30

20

10

0 200

SIEVE l'/l.,. '1'' I '/1 '' ' ,. lf'i,. 'h" '3/r/ #-~ ~

l(,

to S'()

100 1.,00

8 16 30 50 140 270 3 2 11/z 1 3.4 1fz% 4 10 . 20 . 40 • 60 100 • 200 U.S. Standard s· I I I I I I I I I

t'-

' " I\. "' ~

~

~, ........

......... "'-..

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r- ......

.............

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~

60 20 6 2 0.6 0.2 0.06 0.02 0.006 0.002 GRAIN SIZE IN MILLIMETERS

I GRAVEL I SAND I SILT or CLAY

C I M I F C I M IF

REQ'D REQ'D %FINER %FINER SIEVE %FINER %FINER SAMPLE INFORMATION

100 SOUBCE~~ ....... tt. Pf•'K s ........ e1. ~~s DATEBECJ1: ) '2.. ~_:_i~ « l' .s DEL'D_BY· c..\lt ..... \

'H.~ RE~F'EC:

'1'1, I {,<6',0

t s .I _lil__

lit.J 11.~ 1 ~ ,) . - CLASSIFICATIQ.t:UP_E;_5C.81~1QN

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en rcn - ~c: N m -t r-

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c... ~ m 0 > - z -i N 0

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100

90

80

70 ... :X: C) 60 u:; :: >50 m a: w 40 z u: ~ 30

20

10

3 2 1112 1 34 1f23fe 4 I I I

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!'-..

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8 16 30 50 140 270 10 . 20 ' 40 .60 100 • 200 U.S. Standard s·

I J _I I I

10

20

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t"-

""-, 50

"" 35

j\~ 20

I. - -- ------ 10

0 200 60 20 6 2 0.6 0.2 0.06 0.02 0.006 0.002

GRAIN SIZE IN MILLIMETERS

I GRAVEL I SAND I SILT or CLAY

C I M I F C I M IF

REQ'D II I I REQ'D SIEVt I %FINER I %FINER SIEVE %FINER %FINER II SAMPLE INFORMATION

I' h" I 0 0 _ . _ SOUP.CE:___li~"\st~H-~ ~...,. p \c, _ __&~---~;,- --q5', b-- _DATE_AECJ);_____)1__:_~-~~g _______ _

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:sf~,. "),I __ -- ------------f'li - _ '1 r; .r_ __ _ ______________ _ ,1 --{~·.~-- I I I --- -----,

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I 0 (I 3 ~ . ~ I II I I II_Q__LAS.SJFICATIO_Nl_QESCB1r=.110r-.l - I

1oc.. 1-2'l.O -----11---- _, 1------ ------1

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MOUNT MANSFIELD RESORT STOWE, VERMONT

HAZARDOUS WASTE REMEDIATION INTERIM REPORT

JANUARY 1989

ENGINEERING • PLANNING • DEVELOPMENT • MANAGEMENT

TABLE OF CONTENTS

1 • 0 EXECUTIVE SUMMARY • •••••••..••••.•••••••••••••••••••••••••••••.•

2. 0 BACKGROUND INFORMATION. • • • • • • • • . . • • • • • . . • • . • . • • • . . • • • • • • . • • • . • • 3

2. 1 Site Information...................................... . . . . 3 2.2 Chronology of Action & Correspondence to Date............. 3

3.0 DESCRIPTION OF SITE REMEDIATION................................ 5

3. 1 General Remediation Plan. • . • • • • • • • • • • • • • • • • • • • • • • • • . • • • • • • 5

3. 2 Mansfield Base Compressor Building........................ 6

3.2.1 3.2.2 3.2.3 3.2.4

Sources and Limits of Contamination ••••••••••••• Site Remediation Actions •••••••••••••••••••••.•• Site Sampling and Analysis •••••••••••••••••••••• Further Site Work . ............................. .

6 7 8 9

3. 3 Spruce Maintenance Building.. • • • • . . • • . • . • • • • • • • • • • • • • • • • • • 9

3. 3. 1 3.3.2 3-3-3 3.3.4

Sources and Limits of Contamination ••••••••••••• Site Remediation Actions •••••••••••••••••••••••• Site Sampling and Analysis •••••••••••••••••••••. Further Site Work . ............................. .

10 11 12 12

3.4 Quad Chairlift Control Structure.......................... 13

3.4.1 3.4.2 3.4.3 3.4.4

Sources and Limits of Contamination ••••••••••••. Site Remediation Actions •••••••••••••••••••••.•• Site Sampling and Analysis •.•.•••••••••••••••••• Further Site Work ..........................•....

13 13 13 14

3. 5 Tom Lot Laydown Area. . • . • . • • • . • • . . . • • • . . . • . . . . . . • . . . . • . . . . 14

3. 5. 1 3.5.2

Sources and Limits of Contamination ••••••••••••• Further Site Work ..........................•....

14 14

3. 6 Temporary Stockpile Area. • • • • • • • . • • • • • • • • • • • • . . • • • • • • • • • • . 15

3. 6. 1 Location and Layout • • • • • • • • • • • • • • • • . • • • • • • • • • . • • 15 3.6.2 Generalized Construction and Security........... 15

4. 0 SAMPLING AND ANALYSIS.. • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 17

4.1 Sampling and Analysis Methods............................. 17 4.2 Mansfield Base Compressor Building Analysis Results....... 19 4.3 Spruce Maintenance Building Analysis Results.............. 20 4.4 Quad Chairlift Control Structure Area Analysis Results.... 21 4.5 Other Site Analysis Results............................... 21

TABLE OF CONTENTS

- CONTINUED -

5. 0 CONCLUSIONS AND RECOMMENDATIONS. . .. • • .. • • • . .. • • • • • • • • • • • • • • • • • • 23

5. 1 Conclusions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 5. 2 Recommendations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

APPENDICES

A. Copy of Site Remediation Plan of Operation for Waste Oil Contaminated Sites, November 1988; Diane Conrad's November 14, 1988 response to the plan; letter from SCITEST, Inc., laboratory director to Diane Conrad on November 14, 1988 confirming testing requirements and analysis methods.

B. Analysis Reports for soil samples, water samples, and miscellaneous samples.

C. Exhibits, Field Sketches, and Pictures of the various sites including: .

Exhibit 1: Generalized Location Plan of Mansfield Base Compressor Building, Spruce Maintenance Building and Quad Chairlift Control Structure

Exhibit 2: Generalized Location Plan of Tom Lot

Field Sketch 1: Mansfield Base Compressor Building Remediation Plan

Field Sketch 2: Spruce Maintenance Building Remediation Plan

Field Sketch 3: Quad Chairlift Control Structure Remediation Plan

Field Sketch 4: Tom Lot Remediation Pl~j

Field Sketch 5: Temporary Stockpile Area General Layout Plan

Picture 1: Mansfield Base Compressor Building Site

Pictures 2-5: Spruce Maintenance Building Site

Pictures 6-7: Quad Chairlift Control Structure Site

Picture 8: Tom Lot Drum Storage Site

SECTION 1.0

EXECUTIVE SUMMARY

The Mt. Mansfield Company, Inc., operates a variety of facilities and operations at the ski resort in Stowe, Vermont. The State of Vermont Agency of Natural Resources (ANR) conducted field inspections at these facilities during he fall of 1988 in response to an anonymous complaint concerning potential releases of petroleum products to the environment. As a result of those inspections, four specific areas were identified as requiring addi­tional study and remediation. These included: the seasonal compressor staging area and waste storage area at the Mansfield Base Compressor Building; the discharge of the floor drains, the underground waste oil tank area, and the general southern side of the Spruce Maintenance Building; a small area immediately beneath the Quad Chairlift Control Structure; and a drum storage area at the Tom Lot.

The Mt. Mansfield Company, Inc., completed remediation of two of these sites, and partial remediation of a third site in the fourth quarter of 1989. This remediation involved field inspection and excavation of soils within the spill zones to the limits of visual contamination. The excavated soils and remediated areas were sampled to determine the ultimate disposal method for the contaminated soils and the levels of residual site contam­ination remaining after cleanup. The excavated soils have been temporarily stockpiled in a weather-resistant liner and cover system until state approval is obtained for disposal in the 2nd-3rd quarter of 1989.

The field investigations indicated that there were no measurable chlorinated solvents released to the environment in the areas excavated, and that the other petroleum contaminants were contained within the soil layers immediately surrounding the actual spill zone. An impermeable sandy silt underlying each of the spill sites appears to have prevented migration of contamination downward into lower soil strata or groundwater, and the majority of the contamination was removed by simple excavation. The spread of contamination in surface water run-off was considered a much more likely mechanism for contaminant movement, but field inspection and sampling of surface water runoff did not reveal significant movement of the contaminants beyond the immediate drainage areas associated with each spill site.

The types of potential contaminants identified in each of the facil­ities, and an evaluation of the site remediation and analysis work completed to date indicates that the releases of hydrocarbon products to the environ­ment was caused primarily by sloppy housekeeping, maintenance, and fuel transfer practices, and not intentional disregard for public health or environmental protection. The vertical and horizontal spread of contamina­tion, and the levels and types of contamination detected indicate that this was not as severe an incident as ~riginally indicated, and that the only hazardous wastes released to the environment appear to have been small quantities of waste oil and diesel fuels. These are not federally clas­sified hazardous wastes but are regulated by the Vermont Agency of Natural Resources.

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No further site clean-up work is recommended for the soils located in the remediated areas. There are, however, significant improvements to the physical facilities, operating procedures, and inventory control methods that should be implemented to prevent reoccurrence of hydrocarbon releases. No groundwater evaluation or monitoring work is recommended for thf Mansfield Base Compressor Building or Quad Chairlift Control Structure areas based on the field investigations and sampling programs completed to date. At this time no groundwater work is suggested for the Spruce Maintenance building, but a final determination of these requirements is pending on the additional site remediation work to be completed in 1989. No determination of the groundwater evaluation requirements for the Tom Lot can be made until full site remediation and analysis is completed in 1989.

The analysis of the contaminated earth products that have been ex­cavated to date and stockpiled in a secured area at the Tom Lot indicates that there are no chlorinated hydrocarbor.s present in the soils, that the levels of other hydrocarbon compounds is not significant and requires no special treatment for removal, and that the levels of total metals within the soils are well below state requirements published for land application of waste sludges. It is, therefore, recommended that the contaminated soils stockpiled to date be disposed of by land application and aeration by tilling at the Tom Lot. This should take place with the approval of, and within the recommended guidelines of the Agency of Natural Resources as soon as weather and conditions permit in 1989.

It is unfortunate that any contamination of ground surfaces or poten­tial contamination of surface water run-offs occurred at the Mt. Mansfield Company, Inc., facilities. However, Mt. Mansfield Company, Inc., has reacted with an immediate and strong commitment of resources and personnel to clean-up the contamination sites in a timely fashion, and has made sufficient management commitments to implement facility and procedural improvements to prevent reoccurrence of such incidents in the future.

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SECTION 2.0

BACKGROUND INFORMATION

2.1 Site Information

The Mt. Mansfield Company, Inc., (Mt. Mansfield) operates a ski area located on Route 108 approximately six to eight miles northwest of Stowe Village, Vermont. The ski area includes various operational control buildings for the different lift systems, snow making systems, and other support services required. It also has on-site facilities for the maintenance of the various vehicles utilized in area operation.

An unknown quantity of diesel fuel and waste petroleum-based products (normally utilized in the maintenance and operations of rotating equipment and company vehicles) had been spilled over an extended period of time on unprotected earth surfaces at four such facilities owned and operated by Mt. Mansfield. These facilities include the Mansfield Base Compressor Building, the Spruce Maintenance Building, the Quad Chairlift Control Structure, and the Tom Lot drum storage area. This interim report is intended to be a summary of the site remediation work completed by Mt. Mansfield to date at each of the contaminated sites.

2.2 Chronology of Action and Correspondence to Date

The information included below summarizes the pertinent com­munications, meetings, and actions initiated by the various parties involved in the site remediation project in order to provide a histor­ical overview of the project:

1. The State of Vermont, Agency of Natural Resources (ANR), conducted an inspection of the Mt. Mansfield facilities in response to an anonymous complaint. This inspection was completed by Mike Nelson (ANR) on September 26, 1988 and documented in his letter to Mr. James Marsh (Mt. Mansfield) dated October 5, 1988.

2. The ANR conducted a follow-up site visit and meeting with Mt. Mansfield on October 12, 1988. The meeting was intended to further identify the scope of the contamination problem and establish a preliminary response action. This is documented in a letter from Richard Spiese (ANR, Hazardous Materials Management Division) to Mr. James Marsh (Mt. Mansfield) dated October 17, 1988.

3. Mt. Mansfield personnel conducted a site visit on October 17, 1988, with DuBois & King, Inc., (D&K) and Mike Green (Depart­ment of Forest, Parks & Recreation) to further assess possible remediation efforts and long term engineering or operational improvements to the facilities. This is docu­mented in a memo from John Benson (D&K) to the DuBois & King Inc., project files.

- 3 -

4. A coordination meeting was held on November 2, 1988 at the ANR Water Quality Division offices. The meeting was attended by representatives of Mt. Mansfield Company, Inc., DuBois & King, Inc., and the Petroleum Management Section, Solid Waste Management Section, Hazardous Sites Management Section, and the Hazardous Waste Management Division of the ANR. The meeting was intended to discuss the previous field inspec­tions, define the areas of state concern, and establish a plan of action to be implemented by Mt. Mansfield. The general content of the meeting is documented in a memo from Russell Rohloff (D&K; to the Dubois & King Inc., project files (with a copy sent to Diane Conrad, ANR contact).

5. A plan of operation prepared by DuBois & King, Inc., for the proposed site remediation work was forwarded to the state for their review, comment, and approval. This is documented in a letter from Russell Rohloff (D&K) to Diane Conrad (ANR) dated November 3, 1988.

6. Mt. Mansfield Company, Inc., began site remediation work on November 9 and 10, 1988. Representatives of the ANR and D&K were on hand to oversee and document the site clean-up.

7. The ANR forwarded their comments on the proposed site remediation plan of operation. They assessed the plan as adequate for the immediate state concerns and made some suggestions on the types of analysis to be completed and the content of the final report. This is documented in a letter from Diane Conrad (ANR) to Russell Rohloff (D&K) dated November 14, 1988.

8. Roderick Lamothe, Director of SCITEST, Inc., confirmed the testing protocol to be used for analysis of the soils samples with the State Hazardous Waste representative. This is documented in a letter from Roderick Lamothe (SCITEST, Inc.) to Diane Conrad (ANR) dated November 14, 1988.

9. The ANR issued an Assurance of Discontinuance which detailed the alleged violations of various state statutes by the Mt. Mansfield Company Inc., and the actions that must be taken to correct the current situation. This was documented in a letter of transmittal from Patrick Parenteau (Commissioner, ANR, Department of Environmental Conservation) to the Mt. Mansfield dated December 7, 1988.

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SECTION 3. 0

DESCRIPTION OF SITE REMEDIATION

3.1 General Remediatior. Plan

The nature of the suspected spill materials was such that a deep (vertical) penetration or widespread (aerial) travel of the materials through the site soils was not anticipated. The plan for site remedia­tion was, therefore, based on four main steps. First, immediate corrective actions to facility construction details, operating proce­dures, and inventory control were implemented by Mt. Mansfield to prevent further release of waste hydrocarbon products to the environ­ment. Second, the contaminated soils were identified and removed by excavation to the limits of visual contamination. These soils were transferred to a secured, weather resistant stockpile area for tem­porary holding until spring. Third, composite samples were taken of the excavated soil in order to characterize the types and levels of contamination present, and to document the residual levels still remaining at the excavation sites. Finally, an engineering evaluation was begun to assist in bringing Mt. Mansfield into compliance with pertinent state regulations, and to develop a detailed work plan for site, operational, and procedural improvements to minimize the chances for future incidents.

Mt. Mansfield decided to complete site remediation by excavating more soil than would have been defined by simple visual examination in the field. This decision represented an attempt to remove as much of the contamination as possible, and included both the heavily con­taminated soil in the actual spill zone, and the trace contaminated soils at the zone interfaces. Preliminary soil excavation was com­pleted utilizing a Fiat-Allis 605B front end loader with a nominal 2 CY bucket. Final site clean-up ~as accomplished using laborers with shovels and rakes. Soil was transported from the excavation sites to the temporary stockpile area in a nominal 6 CY dump truck. For purposes of estimating the quantity of soil excavated, a heaped dump truck load was assumed to contain 7 CY of soil.

Soil samples were collected from the most visually contaminated sections of the excavated soil and analyzed to determine the type and levels of contamination present. This was intended to provide the waste characterization that would allow a determination of the ultimate method of disposa: that would be required by the state. If chlorinated solven~s were present, the state had indicated that the soil would have to be packaged and transported to a certified hazardous waste disposal facility out of state. If no chlorinated solvents were present, two in-state methods of ultimate disposal were possible. The first involved obtaining approval by the state to treat the soi~ as a special waste and landfill it in an approved facility. The second involved land applying the contaminated soil in thin layers and turning it over on a frequent basis until levels of organic contamination were mini­mized. Soil samples were also taken at the limits~ of_ excavation to __

- 5 -

quantify the amounts of residual contamination that may have been present in the underlying soils. This would assist in determining whether future groundwater contamination might be reasonably expected based on analysis results and site specific characteristics.

Finally, additional testing of underlying soil at the spill sites was completed to characterize other soil properties. This provided additional sub-surface information that was used in assessing the likelihood of groundwater contamination and the vertical penetration of the contaminant products. The extent and results of the site remedia­tion work are summarized for each of the specific contamination sites in the following sections.

3.2 Mansfield Base Compressor Building

The Mansfield Base Compressor Building is used for a variety of ski area functions. These include providing:

1. A central building to house the snow-making compressors, pumps, controls and ancillary equipment.

2. A location for temporary air compressor units to be season­ally installed and operated for snow making.

3. Maintenance facilities for snow making and trail care equip­ment.

4. Underground fuel storage for various diesel engine driven equipment and vehicles.

5. Aboveground temporary storage of used lubricating oils and other miscellaneous vehicle hydraulic fluids.

The generalized 'location of the Mansfield Base Compressor Building relative to the other Mt. Mansfield facilities is shown on Exhibit 1.

3. 2. 1 Sources and Limits of Contamination:

There were three primary sources of contamination in this area. The first was lubricating oil leakage from the seasonal rental air compressors that were located behind the compressor building. The second was diesel fuel spillage associated with fuel transfers into the underground storage tanks, and from the tanks to the diesel users via an area fuel pump. The third was waste oil transfer spills to bulk waste oil tanks located in this vicinity. Based on these potential sources of contamination, it was expected that the primary contamination detected in the soil samples would be oil and grease (from the waste and lube oils), and BTEX (from the diesel fuels).

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3.2.2

The approximate limits of contaminated soil are indicated on Field Sketch 1 and in Picture 1. Area One was contaminated with primarily lubricating oil products, al:hough a faint diesel fuel odor was present during field excavation. Area Two was con­taminated primarily with diesel fuel spills and secondarily with compressor oils that had been flushed down by sJrface water run­off. Test holes excavated in the area with a hand spade indicated that the contamination was uniformly heaviest in the upper six inches of depth (consisting of mixed soils). There was varying degrees of contamination present at depths of six to twelve inches (consisting of coarse sand and mixed soils). The entire con­tamination zone was underlain by a tightly compacted, gray sandy silt layer which had no visually discernable discoloration except at the immediate interface with the upper soil layers. It appeared that small levels of contamination were being carried from the site in surface water run-off. This run-off was col­lected in a shallow drainage trench that discharged into a culvert under the parking lot.

Site Remediation Actions:

Two distinct areas were excavated at the Mansfield Base Compressor Building. The first area· (Area 1 as shown on Field Sketch 1) was located between the existing concrete compressor pad and the fill/vent pipes for the underground diesel storage tanks. This area was roughly 18' x 18', and approximately eighteen to twenty-four inches of soil depth were taken out. This amounted to almost four truckloads, or 26 CY of soil. The second area (Area 2) was located between the base compressor building and a line formed by the diesel tank fill/vent pipes, an electrical trans­former, and an electrical access manhole. This included the portion of the drainage course connecting this area to the culvert drainage. The area was roughly 6' x 20', and approximately twelve to eighi;een inches were taken out of this section. This amounted to almost one truckload, or 6 CY of soil.

The site was left to stand overnight, and was checked in the morning by a state representative using an HNu organics detector. Although there was still some diesel fuel odor in the area the next morning, the HNu testing indicated that the area had been excavated to acceptable levels. After testing and acceptance by the state, Mt. Mansfield backfilled the area with clean sand fill.

Mt. Mansfield also completed the following additional items to prevent or minimize recontamination of the area prior to implementation of long term engineering and operational improve­ments:

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1. The waste oi: bulk storage tanks were moved to an area closer to the maintenance building to allow closer monitoring of their use. Arrangements were made with a waste oil hauler to pump the tanks in order to minimize the amount of oil in them during the winter months until a final resolution as to their long term use could be reached.

2. The curbing in the temporary compressor concrete pad area was repaired to prevent large amounts of lube oil drips from being washed onto the earth surfaces.

3. Rental compressors that were identified as having abnormal oil leakage were returned to the supplier and replaced with newer units.

4. Drip pans were placed under the compressors which were located on earth surfaces to collect and contain and oil leakage during operation.

5. Closer control on diesel fuel transfer operations were implemented among the maintenance and operating per­sonnel.

6. Since the only identified contamination leaving the site was in surface water flowing through the compressor area and entering the drainage culvert, temporary hay bales were installed at the entrance of this culvert to collect the trace amounts of free oil present in the water.

7. Meetings were held with all operating and maintenance personnel to stress proper procedures, housekeeping and site monitoring to prevent further releases of the environment.

Site Sampling and Analysis~

Three soil samples were collected at the Mansfield Base Compressor Building. Sample No. 1 was a composite soil sample taken from the gray sandy silt base underlying Area 1 after excavation and clean-up of the contaminated soils were completed. Sample No. 2 was a composite soil sample taken from the gray sandy silt base underlying Area 2 after excavation and clean-up of the contaminated soils were completed. Sample No. 3 was a composite soil sample taken from the most visibly contaminated sections of the entire soil volume ~xcavated from both areas and stockpiled at the Tom Lot.

- 8 -

3.2.4

Each of the three soil samples were analyzed for Oil & Grease, to detect typical lubricating and hydraulic oil com­ponents; for Volatile Organic Compounds (VOCs), to detect chlor­inated hydrocarbons and those aromatic compounds associated with petroleum fuels; and for total metals, to quantify trace metals associated with waste automotive and maintenance oils. Soil Sample No. 1 (a "clean" sample) was further analyzed to quantify total hydrocarbons content in the remediated area in order to detect other straight chain hydrocarbons associated with petroleum oils and fuels.

A sample of the water entering the drainage culvert was also collected to determine if there were identifiable dissolved organics being carried from the contamination site by surface water runoff. This was Sample No. 6 and was analyzed for VOCs to detect the presence of chlorinated organic compounds, and to quantify total dissolved organic compounds. The results of all analysis and a discussion of the methods used are included in Section 4.0.

Further Site Work:

Mt. Mansfield has authorized an engineering evaluation of the following areas or operations relating to the Mansfield Base Compressor Building as part of their long term spill prevention planning:

1. Evaluate the seasonal, rental compressor area to identify improvements to oil drip containment; to the building drainage system and oil/water separator to document proper design; to the outside equipment area to minimize surface water and precipitation from entering the area.

2. Review the maintenance practices and procedures cur­rently in place and make recommendations for improving inventory control of maintenance fluids, proper handling of waste fluids, tighter control on fuel transfers, and shop improvements to contain small spills.

3. Review the current diesel fuel underground tank arrange­ment to determine if improvements are necessary to insure future compliance with regulations or improved safety in operation.

3.3 Spruce Maintenance Building

The Spruce Maintenance Building is used primarily for maintenance work on a variety of ski area vehicles. This includes both preven­tative maintenance activities and vehicle repair or rebuilding. The maintenance building maintains a stock of automotive lubricants, hydraulic fluids, and other similar fluid~ in 55 gallon drums within an inside storage area. Until recently, waste oils were stored in an underground bulk oil storage tank. The generalized location of the Spruce Maintenance Building relative to the_other Mt. Mansfield facilities·· is· shown· on-· Exhibit 1.

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3' 3. 1 Sources and LimH5 of Contamination:

There were three primary sources of contamination in this area. The first was lubricating oil leakage from the inside drum storage area through a gap in the southern wall of the maintenance building. The second was a more concentrated waste oil spillage associated with transfers ir.to the underground bulk waste oil tank. The third was trace waste oil and other shop fluid drainage out of the open floor drains to a small drainage course located west of the building. Based on these potential sources of contamination, it was expected that the primary contamination detected in the soil samples would be oil and grease (from the waste and lube oils), and possibly chlorinated hydrocarbons from various solvents used in parts degreasing and clean-up.

The approximate limits of contaminated soil are indicated on Field Sketch 2 and in Pictures 2-5. Area One was contaminated with lubricating and hydraulic oil products which had seeped through the building foundations. Area Two was contaminated more heavily with mixed waste oils from overfilling of the underground bulk oil tank. Area 3 was lightly contaminated on the surface with waste oils that had been drained from the building floor drains. This was the area where traces of solvents were also expected. Test holes excavated in the area with a hand spade indicated that the southern side of the building consist of sand backfill placed during building construction. The depth of this fill at the building foundation was 3 to 5 feet. Contamination in area 1 was minimal and confined to the upper twelve inches of sand. Deep penetration of the oil had not occurred, possibly since the amounts of oil released in this area were not large. Contamination in Area 2 was heavily concentrated for a 3 to 5 foot radius arounc the bulk oil tank fill/vent pipe, and extending 3 to 4 feet deep in the sand layer. The entire contamination zone was underlain by a tightly compacted, gray sandy silt layer which had no visually discernable discoloration except at the immediate interface with the upper soil layers. The heavy contamination around the bulk oil tank had migrated horizontally along this impermeable layer and had formed two identifiable oil seeps at the base of the sand fill as shown on the Field Sketch. It did not appear that these oils had spread beyond this immediate area due to surface water runoff.

Test holes excavated at the outlet of the drainage system on the western side of the building indicated minimal sand fill and mostly native materials. Area 'l:hree was lightly contaminated with visible discoloration to a depth of three to ·four inches. The entire length of the drainage course showed some discoloration, although the worst contamination appears to be confined tc the first three to five feet downstream from the drainage pipe outlet.

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3.3.2 Site Remediation Actions:

Two distinct areas were excavated at the Spruce Maintenance Building. The first area (Area 1 as shown on Field Sketch 2) was located along the southern building foundation area and extended around the southeast corner towards the overhead doors. This area was roughly 12' x 20', and approximate:y three feet of soil depth was removed. This amounted to a:most five truckloads, or 32 CY.

The second area (Area 2) was located around the combination fill/vent pipe for the underground bulk storage tank. A wedge was excavated out of the southwest corner of the fill extending down .to the compacted sandy silt layer. The bulk storage tank is buried in or beneath this impermeable layer and there was no indication that the contamination had penetrated beyond this point due to the overfilling incidents. About three to four feet of soil were excavated from this area. This amounted to amounted to 3-1/2 truckloads, or 24 CY of soil. Both areas were checked by the ANR field engineer and excavated to limits which were satis­factory to the Agency.

No excavation of Area 3 took place due to insufficient time to complete site remediation before winter weather conditions proved prohibitive to excavation and stockpiling. This area will be excavated and sampled in the spring of next year.

Mt. Mansfield also completed the following additional items to prevent or minimize recontamination of the area prior to implementation of long term engineering and operational improve­ments:

1. The underground waste oil bulk storage tank was pumped empty by a certified waste oil hauler. The tank will remain in place until next year when it will be aban­doned in place according to state guidelines, or excavated and placed into above ground waste oil storage after inspection for structural integrity.

2. The gaps in the southern building foundations were sealed using a cement grout that was keyed into the maintenance building floor and extended above the wall/floor junction along the entire southern wall.

3· The number of oil and hydraulic fluid drums in the maintenance building was minimized, and drip pans were installed under each of the spouts to minimize spillage on the floor.

4. All degreasing operations were modified to utilize self­contained parts washers in which solvents were collected and recycled by the equipment supplier.

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5. An oil/water separator was purchased for installation on the floor drain exit pipe and this will be installed in the spring.

6. Meetings were held with all operating and maintenance personnel to stress proper procedures, housekeeping and site monitoring to prevent future releases to the environment.

3.3.3 Site Sampling and Analysis:

3.3.4

Three soil samples were collected at the Spruce Maintenance Building. Sample No. 9 was a composite soil sample taken from the most visibly contaminated earth removed from Area 1 Sample No. 7 was a composite soil sample taken from the most visibly con­taminated earth removed from the tank Area 2. Finally, Sample No. 8 was a composite sample taken the gray sandy silt base underlying both areas after excavation and clean~up of the contaminated soils were completed.

Each of the three soil samples were analyzed for Oil & Grease, for Volatile Organic Compounds (VOCs), and for total metals using the methods outlined in Section 4.0. Sample No. 8 (a "clean" sample) was further analyzed to quantify total hydrocar­bons content in the remediated area.

A sample of the water entering the drainage culvert at the southwest corner of the building was also collected to determine if there were identifiable dissolved organics being carried from the contamination sites by surface water runoff. This was Sample No. 5 and was analyzed to detect the presence of chlorinated organic compounds and to quantify total dissolved organic com­pounds. The results of all analysis are included in Section 4.0

Further Site Work:

Mt. Mansfield has authorized an engineering evaluation of the following areas or operations relating to the Spruce Maintenance Building as part of their long term spill prevention planning:

·1. Le:.:.ign, specify and supervise installation of an oil/water separator on the outlet of the floor drains from the maintenance building. This drain system should only handle wash water or snow melt from the vehicles in the shop area, but may contain trace amounts of free oil products from minor drips and leaks on the floor surface.

2. Review the maintenance practices and procedures cur­rently in place and make recommendations for improving inventory control of maintenance fluids, proper handling of waste fluids, and shop improvements to contain small spills.

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3. Review the long term options for waste oil storage at the facility and assist in the design and permitting of such an operation.

3.4 Quad Chairlift Control Structure

The Quad Chairlift Control Structure houses the controls and drive equipment for the Quad Chairlift at this location. This includes a diesel storage tank for the engine drivers located in the control structure. The generalized location of the Quad Chairlift Control Structure relative to the other Mt. Mansfield facilities is shown on Exhibit 1.

3. 4. 1 Sources and Limits of Contamination:

There was one source of contamination in this area. It was caused by a spill of diesel fuel during transfer operations to the engine oil storage tank. The spill was confined t0 an area immediately below the control structure. There was no apparent spread of the diesel fuel spill into nearby drainage culverts around the structure. It was expected that only diesel fuel components would be detected in any analysis of the soil samples collected in this area.

The approximate limits of contaminated soil are indicated on Field Sketch 3 and Pictures 6-7. Test holes excavated with a hand spade indicated that the area was covered with a thin (2-3 inches) of sand and gravel and that it was underlain by the same gray sandy silt layer that was experienced at the other sites.

3.4.2 Site Remediation Actions:

The areas of discoloration was completely excavated. This area was roughly 5' x 15', and approximately one to two inches of soil depth were taken out. This amounted to leDs than a half bucket load (1/2 CY) and was stockpiled with the soil excavated from the Mansfield Base Compressor Building area. The ANR field engineer inspected the site and confirmed that the contaminated soil had been satisfactorily removed.

Site Sampling and Analysis:

Because of the small amount of contamination, only one soil sample was collected at the Quad Chairlift control Structure. Sample No. 4 was a composite soil sample taken from the gray sandy silt base underlying the area after excavation and clean-up of the contaminated soils were completed.

The sample was analyzed for Oil & Grease, for Volatile Organic Compounds (VOCs), and for total metals using the methods outlined in previous sections. This "clean" sample was further analyzed to quantify total hydrocarbons content in the remediated area. No other sampling was deemed necessary because of the minor nature of_the fuel spill.

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3.4.4 Further Site Work:

Mt. Mansfield will review the fuel transfer operations at this site and will institute changes in procedures to insure tighter control of fuel handling. As part of the overall work plan for the complex, a review of the spill prevention and control measures currently in place will be completed and recommendations for their upgrade made.

3.5 Tom Lot Laydown Area

The Tom Lot is an open area located southeast of the Mansfield Base Area on Route 108. It has been used in the past for a variety of temporary storage activities of scrap metal, usable spare parts, and empty oil drums. This report only addresses the problems associated with the empty drum storage area. The generalized location of the Tom Lot relative to the other Mt. Mansfield facilities is shown on Exhibit 2.

Sources and Limits of Contamination:

There was one source of contamination in this area. It was caused by the storage of empty lubricating oil, hydraulic oil, and other unspecified 55 gallon product drums in one section of the laydown area. Some of the drums were knocked over onto the ground, and others appeared to have other minor leakage allowing the residual amounts of fluids in the drum to enter the immediate ground surface. There was no apparent spread of the oils beyond the immediate laydown area since it is slightly dished and there are no major drainage courses through it or along its borders. It is expected that lubricating oil components and possibly solvent components will be detected in the soils removed from this area for analysis.

The approximate location of the contaminated soil are indi­cated on Exhibit 1 and Picture 8. No test holes or other field investigation has been completed due to the winter weather precluding further work this fall. The site will be investigated and remediated in the spring of 1989.

Further Site Work:

Mt. Mansfield will no longer utilize the Tom Lot for empty drum storage and is arranging with a certified disposal company to remove the drums currently at the site. A more detailed engineer­ing investigation of the extent and types of contamination at the site will be completeq in the spring, and the contaminated soil will be excavated to the limits of contamination and disposed of in a state approved manner.

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3.6 Temporary Stockpile Area

The site remediation project was started late in the fourth quarter of 1988. Because the winter weather season was close at hand, a decision was made (with state approval) to excavate as much of the contaminated soil as possible and store it temporarily in a stockpile area at the Tom Lot until spring. This would allow the required testing and characterization of the waste soils tc be completed and a decision made by the various state agencies as to its final dispo­sition.

3.6.1 Location and Layout:

The general location and plan of the Tom Lot is shown in Exhibit 2. The approximate extent of the stockpile area is indi­cated on this exhibit. A more detailed layout of the stockpile area is shown on Field Sketch 5.

Three separate contaminated earth stockpile areas were established at the Tom Lot. Area 1 contains the contaminated earth taken from the Mansfield Base Compressor Building and Quad Chairlift Control Structure excavation areas. A field estimate of the amount of soil in this area was 35 CY. This corresponds well with the estimates made at the excavation sites based on truck counts and assumed volume. Area 2 contains the lightly con­taminated earth taken from the Spruce Maintenance Building foundation excavation. Area 3 contains the heavily contaminated earth taken from the area around the underground waste oil tank at the Spruce Maintenance Building. The soils were segregated until analysis could be completed in order to allow flexibility in f~~al disposal options.

3.6.2 Generalized Construction and Security:

The area chosen at the Tom Lot for the stockpile area is higher than the immediately surrounding area. There was no indication of wetness on the ground surface during the stockpiling activities, and there appears to be suffici~nt drainage courses around the periphery of the area to divert heavy surface water flows away from the stockpiled earth.

Fiber reinforced blue poly tarps were used as the base for each stockpile area. The coqtaminated earth was arranged on these tarps and the edges of the tarps bent upward over a ring of hay bales surrounding each stockpile. The hay bales formed a contain­ment area to minimize the movement of the dirt during the winter storage period, and helped to minimize the likelihood of surface water run-off infiltration into the stockpiled earth.

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Each pile of contaminated earth was covered with either blue poly tarps or 4 to 6 mil polyethylene sheeting. The covering system was interlocked into the hay bales (which served as anchors) in such a way that rain or snow melt would run off the pile to the outside of the hay bales. Sufficient surface anchors were laid on the covering material to minimize wind damage.

There was some residual moisture in the soils which entered during the excavation period (due to precipitation) and it is expected that the piles will partially freeze, at least at the surface, to add stability during the winter storage period.

The location of the piles is in the further corner section of the Tom Lot which has never been used for temporary laydown areas, and warning signs were posted on each side of the stockpile area to identify the potential hazardous waste piles to any persons who may inadvertently enter the area.

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SECTION 4. 0

SAMPLING ANr ANALYSIS

4.1 Sampling and Analysis Methods

Three types of soil samples were ccllected at each of the remedia­tion sites. The first type was collected from the contaminated earth products that were excavated from each site. Because of the large quantity of soils excavated, a composite sampling method was utilized to characterize the entire soil volume. Grab samples were collected from the excavated soil which appeared to be most heavily contaminated (as identified by visible discoloration, the presence of free oil on the soil surface, or by hydrocarbon odors). These samples were composited in a larger container, thoroughly mixed, and sampled in duplicate for laboratory analysis. This sampling methodology was chosen as representing the most conservative method for soil charac­terization. By sampling the "worst" contaminated soil in the entire excavated soil volume, the assumption was made that the balance of the soi: volume would be at contamination levels less than those indicated by the composite sample.

The second type of soil sample was collected from the upper 3 to 6 inches of base soil underlying each excavation zone. After excavation and clean-up of the contaminated soils was completed, soil samples were taken throughout the entire excavated base on roughly 5 feet x 5 feet grid spacings. These samples were composited in a larger container, thoroughly mixed, and sampled in duplicate for laboratory analysis. These samples provided an indication of the average levels of con­tamination remaining at each site after the remediation by excavation had been completed.

The third type of soil sample was collected from the typical gray sandy-silt soil layer that was found to underlay each of the contamina­tion sites. Sufficient volume of soil was collected to allow a standard sieve analysis and a falling head permeability analysis to be completed by a soils laboratory.

The water samples were collected in duplicate using laboratory prepared VOC vials and standard sampling protocol for Volatile Organic Compound analysis.

Table 1 summarizes the soil and water· samples taken and cross refer­ences them to the type of sample, the analysis that was completed, and the location.

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Type of

TABLE 1

MT. MANSFIELD SITE REMEDIATION SAMPLE IDENTIFICATION

Types of Analysis Completed Sample ID Sample Location VOC's Organics Grease Metals Other

---------------------------------------------------------------------------

2

3

4

5

6

7

8

9

10 11

Soil "Clean" soil from XX XX XX XX Base Comp. Area /11

Soil "Clean" soil from XX XX XX Base Comp. Area /12

Soil Contaminated soil XX XX XX @ Base Comp. Area

Soil "Clean" soil from XX XX XX Quad Chairlift Area

Water Inlet to Spruce XX XX Maint. Bldg. culvert

Water Inlet to Base Comp. XX XX Area culvert

Soil Contaminated soil XX XX XX from tank area @ Spruce Maint. Bldg.

Soil "Clean" soil from XX XX XX XX Spruce Maint. Bldg.

Soil Contaminated soil XX XX XX from foundation area, Spruce Maint. Bldg.

Soil Representative sample XX of gray sandy-silt material underlying remediation sites

All soil samples were analyzed for Volatile Organic Compounds using the EPA 5030 extraction method followed by EPA analysis methods 8010 (which detects and quantifies purgeable chlorinated hydrocarbons) and 8020 (which detects and quantifies purgeable aroffiatic compounds). The representative "clean" soil samples composited from the base areas of the site remediation excavations, were further analyzed using an FID scan. This is not a published EPA analysis method, but provides an approximation of the total purgeable hydrocarbons in a sample and is useful when compared to the results of the 8010 and 8020 analyses.

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All soil samples were analyzed for total Oil & Grease using a gravimetric determination as Gefined in Standard Method 503-C. The soil samples were Sohxlet extracted using a freon solvent. The extract was then evaporated and the oil and grease determined by the weight of the residue remaining in a tared flask.

All soil sa~ples were analyzed for total metals. The soil samples were dried, digested using EPA methods 3050 and 7471, and analyzed by Atomic Absorption Spectrometry.

All water samples were analyzed for Volatile Organic Compounds using the EPA analysis methods 601 (which detects and quantifies purgeable chlorinated hydrocarbons) and 601 (which detects and quan­tifies purgeable aromatic compounds). The water samples were further analyzed using an FID scan to quantify the total purgeable hydrocarbons present in the sample.

The sample analysis data sheets for each of the soil and water samples are included in Appendix B of this report. The following is a general discussion of the results that were obtained for each of the remediation sites.

4.2 Mans~ield Base Compressor Building Analysis Results

Three soil samples and one water sample were taken from the Mansfield Base Compressor Building site. Soil Sample No. 1 was collected from the "clean" base soil underlying Area 1 (topographically upgradient of the diesel fuel tanks); Soil Sample No. 2 was collected from the "clean" base soil underlying Area 2 (topographically down­gradient of the diesel fuel tanks); and Soil Sample No. 3 was collected from the most heavily contaminated soil excavated from both areas. Water Sample Nc. 6 was collected at the inlet to the drainage culvert in order to identify potential hydrocarbon run-off from the main site remediation area into the surface water streams.

The analysis for purgeable hydrocarbons indicates that there are no chlorinated hydrocarbons present in any of the areas. These types of compounds are most often associated with solvents and are not utilized in the area where the Jontaminant release occurred. The soil sample taken from the base of the excavation area downstream of the diesel ~uel tanks showed a residual level of BTEX compounds (associated with diesel fuel) but the majority of it appears to be held in the soil matrix since the water sample in the culvert downstream of this point did not indicate significant levels of these compounds.

The analysi~ for total purgeable hydrocarbons indicates that there is still a residual amount of contamination remaining at the site (probably associated with the lubricating oils). Again, the level of contamination is not significant.

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The Oil & Grease analysis indicates that Area 1 at the Mansfield 1.~~ ~~:S ll'e Base Compressor Building (which was excavated by front enc loade!") ~f~ c\' ~ ffl!iS achieved a high level of cleanup. There is still some residual oil ~i ~~~eb remaining in the soil, but it does not appear to be a major concern. ~ 0 l~~/ loWn~ Area 2 (which was excavated by hand) doet not appear to have been vPC ~~ cleaned up as well at first review of the data. However, the .:ajority ~ ,MIJ('e; of the contaminated scil was removed and the residual contaminant m ~'~V levels indicated may be caused by concentrations found iu the upper W inch or so of the confining base layer. ~t;if.~~

The total metals analysis for all samples indicates that there is~~!ls · no significant difference in metals concentration between the base ,,.~ soils and the contaminated soils. A comparison of the total metals concentrations in the soils to the state maximum concentrations allowed for sludge land application indicates that there are no potentially harmful metals concentrations in any of the samples.

4.3 Spruce Maintenance Building Analysis Results

Three soil samples and one water sample were taken from the Spruce Maintenance Building site. Soil Sample No. 7 was collected from the heavily contaminated soil excavated from Area 2 around the underground waste oil tank on the southwest corner of the building. Soil Sample No. 8 was collected from the "clean" base soil underlying the excava­tion area; and Soil Sample No. 9 was collected from the most heavily contaminated soil excavated from Area 1 along the southern foundation of the building. Water Sample No. 5 was collected at the inlet to the drainage culvert in order to identify potential hydrocarbon run-off from the main site remediation area into the surface water streams.

The analysis for purgeable hydrocarbons indicates that there are no chlorinated hydrocarbons present in any of the areas. These types of compounds are most often associated with solvents and were not expected to be found in the area where the contaminant ~eleQse occurred. The soil sample taken from the area around the waste oil storage tank showed a residual level of BTEX compounds but the majority of it appears to be held in the soil matrix since the water sample in the culvert downstream of this point did not indicate detectable levels of these compounds.

The analysis for total purgeable hydrocarbons indicates that there is still a residual amount of contamination remaining at the site (probably associated with the lubricating oils). Again, the level of contamination is not significant.

The Oil & Grease analysis indicates that the excavation achieved a high level of cleanup. There is s:ill some residual oil remaining in the soil, but it does not appear to be a major concern. The most highly contaminated soil was that excavated from around the waste oil storage tank. This contamination occurred by overfilling of the tank with waste oil and was expected to be high.

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The total metals analysis for all samples indicates that there is no significant difference ir. metals concentration betweeL the base soils and th~ contaminated soils. These sample concentrations were slightly higher than those found at the Mansfield Base :ompressor Building areas and this may be due in part to the types of maintenance activities completed at this facility and past fuel storage practices. However, a compariso~ of tne total metals concentrations in the soils to the state maximum concentrations allowed for sludge land application indicates that there are no potentially harmful metals concentrations in any of the samples.

4.4 Quad Chairlift Control Structure Area Analysis Results

One soil sample was taken from the Quad Chairlift Control Struc­ture Area because of the limited extent of the contamination, the type of contaminant released (diesel fuel in a single incident) and the small amount of soil that was excavated from the area in the site remediation. Soil Sample No. 4 was collected from the "clean" base soil underlying the remediation area.

The analysis for purgeable hydrocarbons indicates that there are no chlorinated hydrocarbons present in the area. The soil sample does indicate a small residual level of BTEX compounds which would be expected with a diesel fuel oil spill. The levels remaining are not considered significant and will attenuate with time due to normal volatilization.

The Oil & Grease analysis indicates some contamination remaining which may have been caused by normal maintenance activities associated with rotating equipment lubrication, or by vehicle parking over the conta~inated area. The levels are not considered significant and are in an area partly protected from precipitation and not subject to other surface water infiltration.

The total metals analysis for the sample indicates results similar to the other remediation sites. A comparison of the total metals con­centrations in the soils to the state maximum concentrations allowed for sludge land application indicates that there are no potentially harmful metals concentrations in any of the samples.

4.5 Other Site Analysis Results

Two soil samples were taken from the gray soil underlying the major site remediation areas. One sample was collected at the Mansfield Base Compressor Building area, and one sample was collected at the Spruce Maintenance Building area. These samples were evaluated to allow some judgement to be made as to the likelihood of residual contamination (or past contamination) being transmitted vertically into the groundwater in these areas.

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Each of the samples was analyzed using standard sieve sizes to prepare a grain size distribution curve. ~hese are includec in Appendix 2 of this report. From the curves, the underlying gray soil can be roughly characterized as having 50% coarse sand and gravel, 25% medium and fines sands, 25% silts of finer. This is generally clas­sified as a sandy silt type soil.

Each of the samples was further analyzed for permeability using the Falling Head method in the laboratory. The results of this analysis indicated that the samples had a permeability of less than 0.06 inches per hour. Permeability is a measure of water movement Jd#/ downward through a soil profile, and the Soils Conservation Service has ijii~Vov-V given soils having a permeability less than 0.06 inches per hour theiri~ r­lowest permeability classification of "Very Slow".

Based on the limited characterization completed, field observa­tions of the different soil strata, and comparison to other laboratory analysis completed, it can be concluded that the gray soil layer underlying each of the sites acts as an impermeable layer which definitely impedes downward movement of both water and water borne contaminants. It is expected that any spread of contaminants would be horizontally along the interface of the upper soil and this confining layer, and that any contamination of the confining layer would be found primarily in the upper few inches of soil. This corresponds to the field observations noted during excavation of each of the remediation areas.

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SECTION 5.0

CONCLUSIONS AND RECOMMENDATIONS

5.1 Conclusions

The following conclusions are made based on initial site visits, a review of the types of potential contaminants at each area, a deter­mination of the modes of contaminant release at each area, field observations during site remediation excavation, and review of the chemical and physical property analysis of soil and water samples collected at the remediation sites.

1. A review of the various contaminated sites indicated that remediation could most economically be accomplished by excavating the contaminated soil in each of the areas to the limits of contamination defined by visual observation.

2. Mt. Mansfield excavated more soil than would have normally been identified as contaminated. This insured that the most heavily contaminated soils in the immediate spill zone were removed as well as trace contaminated soils at the outside edges of the spill zone.

3. Contamination at the Mansfield Base Compressor Building resulted from three primary mechanisms: lubricating oil leakage from seas0nal rental compressors; sloppy transfer or waste oils and fluids to above ground bulk oil storage tank; and spillage associated with filling and transfer operations from below ground diesel storage tanks

4. Contamination at the Mansfield Base Compressor Building was most heavily concentrated in the upper six inches of soil surface with less contamination identified in deeper layers. Contamination was confined to the upper twelve to eighteen inches of soil by the presence of a compacted, impermeable gray sandy silt layer underlying the entire spill site.

5. The levels of dissolved hydrocarbons in the surface water draining from the Mansfield Base Compressor Building are minimal and do not appear to be high enough to cause environ­mental problems. There is some free oil present on the water surface which can be skimmed and collected by simple absor­bent materials to prevent downstream transfer.

6. Site remediation work at the Mansfield Base Compressor Building was completed to a satisfactory level of cleanup as certified by a state representative and testing of residual contaminant levels in the soil. No further remediation work is required at this site and all efforts should be directed to preventing reoccurrence of petroleum releases.

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...,

8.

9.

10.

11 .

12.

13.

The likelihood of groundwater contamination at the Mansfield Base Compressor Building is judgec to be minimal and no additional groundwater testing programs are recommeJided. The potential for surface water con~amination at this site remains higher, but can be minimized by improvements to operating facilities and procedures, simple oil collection devices, and improvements to drainage in the area.

Contamination at the Spruce Maintenance Building resulted from three primary mechanisms: lubricating oil and other maintenance fluids leaking fro~ storage drums inside the building; overfilling of an underground bulk waste oil storage tank; degreasing operations allowing various solvents and waste oils to enter floor drains.

Contamination at the Spruce Maintenance ~uilding was most concentrated around the fill pipe for the underground waste oil tank, and present in varying degrees in the sand fill mounded against the souther foundation area. Contamination was confined to the sand fill layer by the presence of a compacted, impermeable gray sandy silt layer underlying the entire spill site.

The levels of dissolved hydrocarbons in the surface water draining from the Spruce Maintenance Building are ~inimal and do not appear to be high enough to cause environmental problems. No free oil was apparent in the water and it does not appear that the waste oil products have moved much beyond the immediate contamination zone.

Site remediation work in Areas 1 and 2 at the Spruce Main­tenance Building was completed to a satisfactory level of cleanup as certified by a state representative and testing of residual contaminant levels in the soil. No additional I remediation work is required in these two areas. Area 3, the drainage course below the outlet of the building floor drains, will be excavated and analyzed in Spring 1989. Continuing efforts should be directed to preventing reoccur­rence of petroleum releases.

The likelihood of groundwater contamination at the Spruce Maintenance Building is judged to be minimal and no addi­tional groundwater testing programs are recommended. The potential for surface water contamination at this site remains higher, but can be minimized by improvements to operating facilities and procedures and installation of oil collection systems.

Contamination at the Quad Chairlift Control Structure appears to have resulted from a single diesel fuel spill incident during transfer to equipment fuel tanks.

- 24 -

14.

15.

16.

17.

18.

The horizontal and vertical limits of contamination at the Quad Chairlift structure was minimal, and no spread of contamination beyond the visible limits was noticeable. Site remediation work at the Quad Chairlift was completed to a satisfactory level of cleanup as certified by a state representative and testing of residual contaminant levels in the soil. No further remediation work is required at this site and all efforts should be directed to preventing In~) reoccurrence of petroleum releases. ~~~~

The soil type underlying each of the remediation sites can be Aef~~~ generally characterized as a compacted sandy silt, having a ~~1 ar~v very slow permeability. Downward migration of water and ~~

water-borne contaminants is judged to be minimal, and waste 'ow·r migration from actual spill zones is expected to be primarily~~ horizontal along the surface of this impermeable strata.

The types and quantities of potential hydrocarbon con­taminants identified at each of the sites remediated to date are such that widespread contamination beyond the immediate zone of the spill is unlikely. These contaminants are expected to be contained in the soil matrix of the spill zone with only minimal quantities being dissolved or flushed out as free oil with normal precipitation run-off. Because of these characteristics site remediation by excavation of the limits of discernable contamination appears to be a proper method.

The contamination zone at the Tom Lot drum storage area, and' the remaining drainage course at the Spruce Maintenance Building should be excavated and as soon as weather and conditions permit in the Spring of 1989.

The soils excavated at the sites have been segregated into three distinct piles. No chlorinated hydrocarbons have been detected in any of the piles, and the levels of other hydro­carbon contaminants (such as aromatics, fuel components, lube oils) are not significantly high to pr 3e an undue risk to the environment. The total metals concentration in the soils are well below the allowable limits established by the state for the land application of sludges. Based on the analysis data, land farming appears to be the best choice for the ultimate disposal of the contaminated soils.

5.2 Recommendations

The following recommendations are made based on the conclusions identified in the preceding section:

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1. Mt. Mansfield should proceed with developing a work pla~ for each of the sites which should detail improvements to physical facilities, operating procedures and practic~s, and surface water drainage pctterns to prevent reoccurrence of contamination to underlying soil layers or surface waters. The content~ of this plan should be implemented as soon as practical.

2. Contamination of surface water, rather than groundwater, is more likely to occur at the Mt. Mansfield facilities. Mt. Mansfield should incorporate the short term mitigation items included in this report to minimize contamination until all items in the detailed work plan are implemented. Furthermore, Mt. Mansfield should prepare contingency plans and provide sufficient emergency response kits for containing and cleaning up oil spills that may occur in any of their facilities during normal operations.

3. The below ground waste oil tank at the Spruce Maintenance Building should no longer be used, and should be abandoned in place, or excavated for disposal in accordance with state guidelines and requirements.

4. No additional clean-up work is required at the sites remedi­ated and documented in this report. Mt. Mansfield super­visory personnel should commit sufficient effort and re­sources towards prevention of future releases to the environ­ment.

5. No groundwater evaluation or monitoring activities are warranted based on the site analysis and work completed to date. This may still prove necessary at the Spruce Main­tenance Building or Tom Lot based on the final site remedia­tion that remains to be completed in Spring of 1989.

6. The contaminated soil currently stockpiled at the Tom Lot should be ultimately disposed of by land farming during the Summer of 1989. This should be completed at the Tom Lot to minimize additional handling and transfer of the soil, and in accordance with state recommendations and guidelines for this type of in-situ treatment.

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APPENDIX A

(;::1-...,

1. 0 0/I;R\'ID~

M;Xmr f/A'\SfiELD CQ. lNC. Stowe: , Ve.rnpnt

Site f<snediation Plen o! cperation fo; Waste 0:1 Contaminated Sites

Noverr!ber 1 1988

An unknONn quantity of waste :t=etrolelD'll based products 1 that are normally utilized in the maintenance and O:p:!rations of rotating equipnent and vehicles, has been spilled over a period of time on unprotected earth surfaces at facilities owned by Mount Mansfield Canpany, Inc. The nature of the waste products is such that deep or widespread renetration of the earth surface is not anticipated. The l-'.ount Mansfield Canpany, Inc., in roo~ration with the various State of Venoont agencies having jurisdiction over such spills, proposes the following plan of operation to begin site remediation via contaminated soil excavation.

2.0 SITE LOCATIOOS

T'ne following sites have been identified by state field inspections as requiring renEdiation work. Tne approximate areas have been identified by field in~ction by the Mount ~mnsfield canpany, Inc. , sub­contracted engineers, DuBois & King, Inc.

1. Quad Chair Control Facility: A small quantity of diesel fuel has been spilled under the control terminal during a maintenance operation. The area is approximately 5' x 15', and there is a run-off trail follCJ\oti.ng the natural surface drainage and extending about 3 1 wide by 20' long.

2. Canpressor Building at the Mt. Mansfield Base: Moderate amounts of waste oil, engine oil, compressor lubrication oil, and diesel fuel s~lls have occurred on one side of the compressor building used for snow making o:t=erations. The affectec area is approxi­rnately 25' x 30', and there is a run-off trail entering a drain culvert that flows under the aojaamt parking lot. T'nis area is currently congestecl with canpressors, electrical transformers, oil storage tanks, buried fuel storage tanr~ (·v.'ith ancillary fill/vent piping) and other piping.

3. Spruce f.lai.ntenance Shop: Moderate amounts of lubrication oil, hydraulic fluid, transnission fluid, crankcase oils and degreasing sol vents have been discharged on two sides of this facility. The first location involves oil/fluid seepage through the foundation wall resulting in an affected area approximately 25' x 15 1

• T'ne second location involves a drainage swale fran the discharge point of a floor drain pi];:e ana involves an area approxirrately 5 1 \\-'ide x 25' long.

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··]i; {:J

)

4. Tcr., Lot: Small amounts of clean lubricatino oils, hvdrau!ic fluids, transmission fluids anc aegreasins sol vents have been discharged onto the gro\.l!"'C in an enpty drwr storage area. The affe~e:Q area i.s approximately i.O' x 25' .

The follar:ing steps ¥-"ill be canpletea to initiate site ranediation war~; at the above identif iec Mount t-'..ansf ield Canpany, Inc. facilities:

1. Mount l·~sfielc Canpany, Inc., will prepare a temporary stoch.'Pile area in which all excavated, cx:mtami.nated earth will be storea until sampled, analyzed, and ultimately disposed of at a state approved off-site location. This stockpile area will be pre~rea on a flat, accessible area at the Tar. Lot and will be surrounded by a one foot high earth berm to minimize surface water infiltra­tion. 1. base lor'ill be preparea using a reinforcea plastic tarp \o:ith all seams joined by overlapping a minimum of one foot and taping one side \o:ith a suitable waterproof tape. A similar arrangarent \\'ill be used to cover the contaminated earth once it is in place. Tne cover \o.'ill extend over the stockpiled earth and the contaillii'Ent bern. to minimize rain water infiltration into the piles.

2. Mount Mansfielc Canpany, Inc., will supply the equipnent and op:rators required to excavate contarninateo earth waste, transport it to the Tan Lot, place it in the prev'iously prepareci stockpile area, and prepare it for tenporary storage by proper covering and a.'l'lchorinc against the weather. DuBois and King, Inc. , will prO\•ide a field engineer to nonitor the excavation process in conjunction with a state appointea fielc representative. Tne soils will be excavated until no visible contamination is noted.

3. Clean fill or si. te arcrli.na \dll be used to restore the excavated sites to normal grades. Mt. r-~sfielo Canpany, Inc., will initiate procedures, facility improvements and/or new upgrades to m:i.n.irl'ize the likelihood of future contamination of the ranedi.ated areas.

4. Tne contarninatee earth products fran each location will be segregated frm. each other in order to better Cifferentiate the typ;s of contaminants representative of each site. Tnis may cllCM more flexible Cisposcl op+-....ions to be pursued for less regulatee waste contaminants.

..... Cne composite sail sample \o.'i.ll be taken from the :portion of the excavated earth waste that app;ars to be nost contaminateo at each site. This sample will be analyzed as follows: 1) a EP 624 analysis will be run to characterize the volatile organic cam­pouncs in the soil; 2) an EP Toxicity test will be run to charac­terize the leachable priority netals; 3) a total Oil and Grease test \-.'ill be completee.

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,·~It "...,;~

6 · Two CXJnposite sail samples \t.'ill be taken fran the base soil at the: limits of excavation in each of the four ziter. <eight totc.l samples). T'nese samples \tdll be taken fran coreE collected frar the upr:er si>: indles of the: soil using a hand auger. Tne sar.1ples will be taken on a roughly 5 1 x 5' grid across the lirr.its of the excavation and thorougbly r..ixed together tc prO\'iae the necessary canposite samples. The sail samples \t>'ill be analyzed identically to those identified in iteir. 4 above.

7. Mount l-'..ansfielc1 CCJ:11Amy 1 Inc. 1 will initiate contacts \<lith state certified hazardous waste haulers to contract for the ultimate disposal of the ex>ntarr.inatea earth products which carmot be treatea or disposed of in-state. The disposal options and decisions will be coordinated with the respective state agencies having jurisdiction over these matters. Mdi tional sampling and characterization of the contaminated earth ltw'ill be initiated at this tim=, if re::Juired, for ultimate disposal.

8. Warning signs will be installed on each side of the stockpile area which will identify the site as a tSTpOrary stockpile: area for waste materials which have been classified as hazardout: by the State of Vermont.

9. A final report ltw"ill be prepared by DuBois & King, Inc. on behalf of Mount J.jansfield Can:pany, Inc., \\tlich will docunent the site ranediation work completed, results of all soils analysis, and calculation of the amounts of contaminated earth that 'll'ill need to be treated and/or disposed of under the existing state solid waste and hazardous waste rules.

4. 0 SCHEIXJLE FOR SITE REMEPIATICJY

Mount Nansfielc1 Canp:my, Inc., intends to begin excavation of the con­taminated earth at their facilities as early as the week of Novenber 7, 1988, pending state approval of the plan of operation. They will minimally excavate the visual limits of soil contamination at the Spruce Z.laintenance Building, the Quae Chair control structure, and the Tom Lot drlJii, storaae area. Because of the concestion at the Base Canpressor Building outside eguipnent area it ~7 not be possible to excavate the affected soil in this area until spring, 1989. If this is the case, Mount Iv'.lansfielc Canpany, Inc., \tw'ill take steps to re<Juce surface ~ater run-off through the oil contarrinatee earth area, and will install sane type of absorbent material prio: to the entrance to the drainage culvert in an attanpt to intercept entrained oil products.

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State of \" ertnont AGENCY OF NATURAL RESOURCES I 03 SOUTH MAIN STREET Waterbury, Vermont 05676 Dep8rtmem of Fish nnci Wildlifr

[" .,rtrnen~ of r or est< Parks anri At~( ,,...;lltnn

S1<1te Geoloaist Department of Environmental Conservation

')

November 14, 1988

Mr. Russell W, Rohloff Dubois and King, Inc. Box 339 Randolph, Vermont 05060-033~

Dear Mr. Rohlotta

I have revi•wad the "site Ramadiation Plan of Operation" submitted by you on behalf ot Mount Man•tiald Co,, Inc. of Stowe, Vermont.

Generally, I tin~ the rlan tn be adaquata to address our immediate concerns. 'l'h• raw •p•oific onmmanta I have are outlined below.

Page 2, #51 We •ug~e•t thftt aftctt aoil composite be analyzed for EPA 8020 and 8040 constituents, and oil and grease. Results of those analyses will then determine it aoil• ahould be analyzed for total metals or EP Tocicity.

Page 3, #9: The tinal report aubmitted by Dubois and King should address the necessity ot the installation of a groundwater monitoring network in the area or the Compressor Building and, potentially, the Spruce Maintenance Shop. If Dubois and King feel that further investigatio.1 is not warranted, a rationale should be included to support that conclusion. It is our feeling that contaminants have, in all likelihood, migrated to surface water behind the Compressor Building, and further investigation in that area will be necesary.

As I understand it, work began on Wednesday, November 9, with Agency oversight and still continue•.

Thank you tor the t!maline•• ot your raaponse. It I can be of assistance aa thi• process continua•, please contact me at 244-8702.

Sincerely,

()~ Diane Conrad, Chiet Hazardous Sites Program

DC:bgc347

cc: James P. Marsh Director ot Mountain Operations

R•·•ponal OfficPs. BattP./F~~r.x Jct./Pittstord/N. Springfield/St. Johnsbury

Ms. Diane Conrad Agency of Natural Resources Department of Environmental Conservation 103 South Main Street Waterbury, VT 05676

Sl.JBJECI': Mt. Mansfield Soil Samples

Dear Ms. Conrad:

74812 November 14, 1988

SCIU~£3U lftBORftTORY SfRVICfS

Box 339 Randolph, Vermont 05060-0339 (802) 728-3379

Confirming our telecom on 11/14/88 concerning the soil samples from Mt. Mansfield, we will follow these steps:

1. Determine VOC's using Methods 8010 & 8020 following an extraction Method 5030

2. If Method 8010 (halogenated volatile compounds) have unidentifi­able peaks a GC/MS confirmation will be performed on the extract.

3. An oil & grease analysis (sohxlet extraction) will be performed on soils.

4. Results will be submitted to the Agency for review and a decision will be made determining appropriate disposal method.

5. If land application is deemed the appropriate treatment, the soils will be analyzed for total metals.

6. If landfill is deemed the correct disposal method, an EP Toxicity or TCLP Test will be performed.

If you have any questions or comments, please feel free to call me.

J RJL/jf cc: RuSsell Rohloff, DuBois & King, Inc.

Very truly yours,

SCITEST, INC.

Roderick J. Lamothe Laboratory Director

Jim Marsh, Mt. Mansfield Company, Inc.

APPENDIX B