HRS DOCUMENTATION RECORD COVER SHEET

Name of Site: Jard Company, Inc. 

EPA ID No.: VTD048141741 

Contact Persons

Site Investigation: Weston Solutions, Inc. (WESTON)/ (978) 552-2100 

Superfund Technical Assessment and 

Response Team III (START)

3 Riverside Drive

Andover, MA 01810 

(Mr. G. Hornok, Ms. C. Casiello Imbres, Ms. S. Bitzas, and Mr. J. F. Kelly)

Documentation Record: U.S. Environmental Protection Agency (617) 918-1407 

(EPA) Region I

5 Post Office Square, Suite 100 

Boston, MA 02109-3912 

(Ms. Martha Bosworth and Ms. Nancy Smith)

Pathways, Components, or Threats Not Scored

The surface water overland/flood migration component, and the soil exposure and air migration pathways were 

not scored as part of this Hazard Ranking System (HRS) documentation record, as the scoring of the ground water 

migration pathway and the ground water to surface water migration component of the surface water pathway are 

sufficient to qualify the site for the National Priorities List (NPL).

Surface Water Overland/Flood Migration Pathway (component not scored) 

Surface water runoff has potentially been responsible for the limited migration of polychlorinated biphenyls 

(PCBs) to drainage swales and sewers immediately adjacent to the Jard Company Inc. property [10, pp. 72, 148-

149, 214-218, 234-235; 31, pp. 33, 56 -57; 41, pp. 1 -4]. In addition, flood events, including one event in August 

2011, may have caused the migration of hazardous substances associated with source areas on the Jard property 

[126, p. 28; 127]. The ground water to surface water component is a primary mechanism of transport of hazardous 

substances associated with the site (see ground water to surface water component section) [31, pp. 56-57; 65, pp. 

28, 54]. The HRS directs selecting the higher of the two scores for the two components of the surface water 

migration pathway, therefore, the overland/flood migration component is not included in the HRS scoring of this 

site [1, pp. 51604-51605, Section 4.0.1]. 

Soil Exposure Pathway (not scored)

Sampling has documented the presence of PCB contamination in surface soils on residential properties within 200 

feet of residences, downgradient of the Jard Company, Inc. property [10, pp. 77, 187, 190-193, 200-202, 204-205, 

208-210, 224-226, 228-231, 249, 252 ]. Due to the limited number of residents impacted by the PCB 

contamination, this pathway does not contribute significantly to the listing decision. Therefore, this pathway is not 

evaluated in the HRS scoring of this site. 

Air Migration Pathway (not scored) 

No release of hazardous substances to the ambient air from sources has been documented to have occurred, and 

no impacts to nearby residential populations or sensitive environments have been documented. The evaluation of 

Jard Company, Inc. HRS Documentation Record

VTD048141741
Jard Company, Inc. HRS Documentation Record

VTD048141741

the air migration pathway would not impact the listing decision. Therefore, this pathway is not evaluated in the 

HRS scoring of this site. 
Jard Company, Inc. 1 HRS Documentation Record

VTD048141741

HRS DOCUMENTATION RECORD

Name of Site: Jard Company, Inc. Date Prepared: May 2014 

EPA Region: 1 

Street Address of Site*: 259 Bowen Road 

City, County, State, Zip Code: Bennington, Bennington County, Vermont, 05201 

General Location in the State: Southwestern Vermont

Topographic Map: U.S. Geological Survey, Bennington, Vermont-Bennington Co., 7.5-minute series 

Topographical Map. 1954. [3].

Latitude: 42o

 53' 19.9" North 

Longitude: 73o 11' 20.8" West 

Ref: [3; 5; 6]

*The street address, coordinates, and contaminant locations presented in this HRS Documentation Record identify 

the general area the site is located. They represent one or more locations EPA considers to be part of the site based 

on the screening information EPA used to evaluate the site for NPL listing. EPA lists national priorities among the 

known "releases or threatened releases" of hazardous substances; thus, the focus is on the release, not precisely 

delineated boundaries. A site is defined as where a hazardous substance has been "deposited, stored, disposed, or 

placed, or has otherwise come to be located." Generally, HRS scoring and the subsequent listing of a release 

merely represent the initial determination that a certain area may need to be addressed under CERCLA. 

Accordingly, EPA contemplates that the preliminary description of facility boundaries at the time of scoring will 

be refined as more information is developed as to where the contamination has come to be located.

Scores

Air Pathway 0 

Ground Water Pathway 60.00 

Soil Exposure Pathway 0 

Surface Water Pathway 100.00 

HRS SITE SCORE 58.31 

 
Jard Company, Inc. 2 HRS Documentation Record

VTD048141741

WORKSHEET FOR COMPUTING HRS SITE SCORE

S S2

1. Ground Water Migration Pathway Score (Sgw) 

(from Table 3-1, line 13) 60.00 3,600 

2a. Surface Water Overland/Flood Migration Component 

(from Table 4-1, line 30) NS NS

2b. Ground Water to Surface Water Migration Component

(from Table 4-25, line 28) 100.00 10,000 

2c. Surface Water Migration Pathway Score (Ssw) 

Enter the larger of lines 2a and 2b as the pathway score. NS NS

3. Soil Exposure Pathway Score (Ss) 

(from Table 5-1, line 22) NS NS

4. Air Migration Pathway Score (Sa) 

(from Table 6-1, line 12) NS NS

5. Total of S 2

gw + S 2 sw + S 2s + S 2a 13,600 

6. HRS Site Score 

Divide the value on line 5 by 4 and take the square root 58.31 
Jard Company, Inc. 3 HRS Documentation Record

VTD048141741

HRS Table 3-1 – Ground Water Migration Pathway Scoresheet

Factor Categories and Factors

Maximum

Value

Value

Assigned

Likelihood of Release to an Aquifer:

1. Observed Release 550 550 

2. Potential to Release:

 2a. Containment 10 NS

 2b. Net Precipitation 10 NS

 2c. Depth to Aquifer 5 NS

 2d. Travel Time 35 NS

 2e. Potential to Release [lines 2a x (2b + 2c + 2d)] 500 NS

3. Likelihood of Release (higher of lines 1 and 2e) 550 550

Waste Characteristics:

4. Toxicity/Mobility (a) 10,000

5. Hazardous Waste Quantity (a) 10,000

6. Waste Characteristics 100 100

Targets:

7. Nearest Well 50 50

8. Population:

 8a. Level I Concentrations (b) 40

 8b. Level II Concentrations (b) 0

 8c. Potential Contamination (b) NS

 8d. Population (lines 8a + 8b + 8c) (b) 40

9. Resources 5 NS

10. Wellhead Protection Area 20 NS

11. Targets (lines 7 + 8d + 9 + 10) (b) 90

Ground Water Migration Score For An Aquifer:

12. Aquifer Score [(lines 3 x 6 x 11)/82,500]c 100 60

Ground Water Migration Pathway Score:

13. Pathway Score (Sgw), 

 (highest value from line 12 for all aquifers evaluated)c 100.00 60.00 a

Maximum value applies to waste characteristics category.

b

Maximum value not applicable.

c

Do not round to nearest integer.
Jard Company, Inc. 4 HRS Documentation Record

VTD048141741

HRS Table 4-25 – Ground Water To Surface Water Migration Component Scoresheet

Factor Categories and Factors 

Maximum 

Value

Value

Assigned

Drinking Water Threat

Likelihood of Release to an Aquifer:

1. Observed Release 550 550

2. Potential to Release:

 2a. Containment 10 NS

 2b. Net Precipitation 10 NS

 2c. Depth to Aquifer 5 NS

 2d. Travel Time 35 NS

 2e. Potential to Release (lines 2a x [2b + 2c + 2d]) 500 NS

3. Likelihood of Release (higher of lines 1 and 2e) 550 550

Waste Characteristics:

4. Toxicity/Mobility/Persistence (a) NS

5. Hazardous Waste Quantity (a) NS

6. Waste Characteristics 100 NS

Targets:

7. Nearest Intake 50 NS

8. Population:

 8a. Level I Concentrations (b) NS

 8b. Level II Concentrations (b) NS

 8c. Potential Contamination (b) NS

 8d. Population (lines 8a + 8b + 8c) (b) NS

9. Resources 5 NS

10. Targets (lines 7 + 8d + 9) (b) _

Drinking Water Threat Score:

11. Drinking Water Threat Score

([lines 3 x 6 x 10]/82,500, subject to a maximum of 100) 100 _ 

Human Food Chain Threat

Likelihood of Release:

12. Likelihood of Release (same value as line 3) 550 550

Waste Characteristics:

13. Toxicity/Mobility/Persistence/Bioaccumulation (a) 5 × 108

14. Hazardous Waste Quantity (a) 10,000
Jard Company, Inc. 5 HRS Documentation Record

VTD048141741

Factor Categories and Factors 

Maximum

Value

Value

Assigned

15. Waste Characteristics 1,000 1,000

Targets:

16. Food Chain Individual 50 20

17. Population:

 17a. Level I Concentrations (b) NS

 17b. Level II Concentrations (b) NS

 17c. Potential Human Food Chain Contamination (b) 0.000018

 17d. Population (lines 17a + 17b + 17c) (b) 0.000018

18. Targets (lines 16 + 17d) (b) 20.000018

Human Food Chain Threat Score

19. Human Food Chain Threat Score

([lines 12 x 15 x 18]/82,500, subject to a maximum of 100) 100 100 

Environmental Threat

Likelihood of Release:

20. Likelihood of Release (same value as line 3) 550 550

Waste Characteristics:

21. Ecosystem Toxicity/Mobility/

Persistence/Bioaccumulation (a) 5 × 108

22. Hazardous Waste Quantity (a) 10,000

23. Waste Characteristics 1,000 1,000

Targets:

24. Sensitive Environments:

 24a. Level I Concentrations (b) 0

 24b. Level II Concentrations (b) 25

 24c. Potential Contamination (b) NS

 24d. Sensitive Environments 

 (lines 24a + 24b + 24c) (b) 25 

25. Targets (value from 24d) (b) 25

Environmental Threat Score:

26. Environmental Threat Score

([lines 20 x 23 x 25]/82,500, subject to a maximum of 60) 60 60 

Ground Water To Surface Water Migration 

Component Score For A Watershed

27. Watershed Scorec (lines 11 + 19 + 26, subject to a 

maximum of 100) 100 100 

Ground Water To Surface Water Migration Component Score

28. Component Score (Sgw)

c

, (highest score from line 27 for all 

watersheds evaluated, subject to a maximum of 100) 100.00 100.00 a

Maximum value applies to waste characteristics category.

b

Maximum value not applicable.

c

Do not round to nearest integer. 
ACRONYMS

< Less than

1,1,1-TCA 1,1,1-Trichloroethane 

ANR Agency of Natural Resources 

bgs Below Ground Surface 

CAFI Corrective Action Feasibility Investigation

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 

1980 

CERCLIS Comprehensive Environmental Response, Compensation, and Liability 

Information System 

CFR Code of Federal Regulations 

CLP Contract Laboratory Program 

CRQL Contract Required Quantitation Limit 

DEHP Bis(2-ethylhexyl)phthalate

DNAPL Dense Non-Aqueous Phase Liquid 

DOP Di-octyl phthalate 

EPA U.S. Environmental Protection Agency 

ft2 square feet

GIS Geographic Information System 

GPS Global Positioning System 

HRS Hazard Ranking System

HWQ Hazardous Waste Quantity

ID Identification

J Value is Estimated

Jard Jard Company Inc. 

KVA kilo volt ampere

Lockheed Lockheed Martin Technology Services Group

MCL Maximum Contaminant Level 

μg/L Micrograms Per Liter

μg/Kg Micrograms Per Kilogram

msl Mean Sea Level

NHB New Hampshire Boring, Inc. 

No. Number 

NPL National Priorities List

NS Not Scored

NWI National Wetland Inventory

PA/SI Preliminary Assessment/Site Investigation

PCB Polychlorinated Biphenyl

PEM Palustrine Emergent

Phase II ESA Limited Phase II Environmental Site Assessment 

PPE Probable Point of Entry 

ppm parts per million 

PRP Potentially Responsible Party 

PSS Palustrine Scrub-Shrub 

PVC Polyvinyl Chloride

QAPP Quality Assurance Project Plan

RCRA Resource Conservation and Recovery Act

RCRIS Resource Conservation and Recovery Information System

SOW Statement of Work

SR Site Reassessment

START Superfund Technical Assessment and Response Team III

Jard Company, Inc. 6 HRS Documentation Record

VTD048141741
ACRONYMS

Stone Stone Environmental, Inc. 

SVOCs Semivolatile Organic Compounds 

SWP Surface Water Pathway

TCE Trichloroethylene

TDL Target Distance Limit

U Value was not detected

USFWS United States Fish and Wildlife Service

UST Underground storage tank

VOCs Volatile organic compounds 

VT Vermont 

VT ANR DEC Vermont Agency of Natural Resources Department of Environmental 

Conservation 

VTrans Vermont Agency of Transportation 

Wehran Wehran Engineering Corporation 

WESTON Weston Solutions, Inc. 

yd3 cubic yards 

Jard Company, Inc. 7 HRS Documentation Record

VTD048141741
Jard Company, Inc. 

Property Boundary

One Mile Radius 

from Site Sources

Source No. 1

Source No. 2

Walloomsac River

Furnace Brook

Estimated Site Boundary 

Jard Company, Inc. 

^_

Site Coordinates Location

Roaring Branch of the

Walloomsac River

0 0.25 0.5 0.75 1

Miles

Figure 1

Site Location Map

Jard Company, Inc.

259 Bowen Road

Bennington, Vermont

EPA Region I 

Superfund Technical Assessment and 

Response Team (START) III

Contract No. EP-W-05-042

TDD Number: 01-13-09-0001

Created by: S.Bitzas

Created on: 2 October 2013

Modified by: E. Mulholland

Modified on: 7 March 2014

Basemap: Bing USA Topo Maps (Microsoft) [3]. 

Parcel Data: Town of Bennington Parcels [111].

All other data: Weston START [4; 10]

Data Sources:

I

Jard Company, Inc. 8 HRS Documentation Record

VTD04814741 April 2014
Jard Company Inc Property

Former Building Footprint

Source No. 2

Bowen Road

Park Street

Roaring Branch of the 

Walloomsac River

Source No. 1

Kocher Drive

Contaminated 

Wetland

Background Wetland

Duck Pond

Greene Pond

Most Upstream Probable

Point of Entry # 1

VTrans Facility

Bowen Road

Furnace Brook

Unnamed Stream

Impacted Residential

Drinking Water Well

Most Upstream Probable

Point of Entry # 2

Approximate

Berm Location

Figure 2

Site Area Map

Jard Company, Inc.

259 Bowen Road

Bennington, Vermont

EPA Region I 

Superfund Technical Assessment and 

Response Team (START) III

Contract No. EP-W-05-042

TDD Number: 01-13-09-0001

Created by: G. Hornok

Created on: 11 January 2013

Modified by: E. Mulholland

Modified on: 7 March 2014

Legend

I

Former Building Footprint

Jard Property Boundary

Pile Base

Contaminated Soil

Waterbody

_^ PPE

Surfacewater

Wetland Type

Emergent

Forested

Scrub/Shrub

Estimated Site Boundary

0 100 200 300 400 500

Feet

Data Sources:

Imagery:Bing Maps Aerial (Microsoft) [112]

Parcel Data: VT DEC GIS [111]

All other data: Weston START [4; 10]

 Building Footprint [62; 70]

Jard Company, Inc. HRS Documentation Record 9

VTD04814741 April 2014
$

$

$

$

$

$

$

$

P020-SS-08A

P020-SS-09C

P020-SS-01A/B

P020-SS-03A

P020-SS-04A

P020-SS-10B

P020-SS-07B/C

P020-SS-15A

Bowen Road

Figure 3A

Background Soil Sample

Location Map

Jard Company, Inc.

259 Bowen Road

Bennington, Vermont

EPA Region I 

Superfund Technical Assessment and 

Response Team (START) III

Contract No. EP-W-05-042

TDD Number: 13-09-0001

Created by: G. Hornok

Created on: 22 October 2013

Modified by: E. Mulholland

Modified on: 7 March 2014

Legend

$ Soil Sample

Contaminated Soil

Former Building Footprint

Approximate Cap

Pile Top

Pile Base

0 50 10

I0 200 300

Feet

Data Sources:

Imagery: Bing Maps Aerials (Microsoft) [112]

All other data: Weston START [4; 10]

 Building Footprint [62; 70]

Jard Company, Inc. 10

VTD04814741 April 2014

HRS Documentation Record
$+

$+

$+

$+

$+

$+

!(

!(

!( !(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!( !( !(

SO-62A

SO-43A

SO-46A

SO-36A

SO-14A

SO-21A

SO-22A

SO-45A

SO-06A

SO-57A

SO-92A

SO-61A

SO-91A

SO-85C

SO-24A

SO-25B

SO-28A

SO-29A

SO-31A/B

SO-30B

SB-06B

SO-52A

SO-53A

SB-03B

SB-01C

SB-09D

SB-05B

SB-08D

Figure 3B

Source Area

Sample Location Map

Jard Company, Inc.

259 Bowen Road

Bennington, Vermont

EPA Region I 

Superfund Technical Assessment and 

Response Team (START) III

Contract No. EP-W-05-042

TDD Number: 13-09-0001

Created by: G. Hornok

Created on: 14 October 2013

Modified by: E. Mulholland

Modified on: 7 March 2014

Sample L

L

o

E

c

G

a

E

t

N

i

D

ons

$+ Soil Boring Sample

(! Soil/Source Sample

Contaminated Soil

Former Building Footprint

Approximate Cap

Pile Top

Pile Base

0 25 50 75 100

I

Feet

Data Sources:

Imagery: Bing Maps Aerial (Microsoft) [112]

All other data: Weston START [4, 10]

 Building Footprint [62, 70]

Jard Company, Inc.

VTD04814741

HRS Documentation Record

April 2014

11
!U

!U

!U

!U

!U

!U

!U

!U

!U

GW-04

MW-3

GW-05

MW-3D

GW-06

MW-6

GW-01

EPA-100

GW-08

MW-9D

GW-09

MW-11

GW-02

EPA-107

Park Street

Bowen Road

Branch Street

Roaring Branch of the 

Walloomsac River

P009 Well

P011 Well

P010 Well

P100

P011

P010

P009

Figure 4

Ground Water and Drinking 

Water Sample Location Map

Jard Company, Inc.

259 Bowen Road

Bennington, Vermont

EPA Region I 

Superfund Technical Assessment and 

Response Team (START) III

Contract No. EP-W-05-042

TDD Number: 01-13-09-0001

Created by: S. Bitzas

Created on: 14 June 2013

Modified by: E. Mulholland

Modified on: 7 March 2014

Legend

!U Drinking Water Well*

!U Ground Water Sample

Source No. 1

Source No. 2

Approximate Property Boundary

* Note, Drinking Water Well

locations are approximate.

0 50 100

I200 300 400 500

Feet

Data Sources:

Imagery: Bing Maps Aerial (Microsoft) [112]

Topos: Bennington Quadrangle [3]

Parcel Data: VT DEC GIS [111]

All other data: START [10, pp. 167-169]

Jard Company, Inc.

VTD04814741

HRS Documentation Record

April 2014

12
4 Mile Target Distance Limit

from Site Sources

Jard Company, Inc. 

Site Sources

Roaring Branch of the

Walloomsac River

0 0.5 1 2 3 4

Miles

Figure 5 Superfund Technical Assessment and 

Response Team (START) III

4 Mile Target Distance Limit Contract No. EP-W-05-042

TDD Number: 01-13-09-0001

Jard Company, Inc. Created by: S.Bitzas

259 Bowen Road Created on: 2 October 2013

Bennington, Vermont Modified by: E. Mulholland

Modified on: 7 March 2014

EPA Region I Basemap: Bing USA Topo Maps (Microsoft) [3]. 

All other data: Weston START [4; 10]

Data Sources:

I

Jard Company, Inc. HRS Documentation Record

VTD04814741 April 2014

13
")

") ")

")

SD-51A/C

SD-53A/B

SD-52C

SD-54C

P040 Bowen Road

North Branch Street

Figure 6A

Background Wetland Sediment

Sample Location Map

Jard Company, Inc.

259 Bowen Road

Bennington, Vermont

EPA Region I 

Superfund Technical Assessment and 

Response Team (START) III

Contract No. EP-W-05-042

TDD Number: 01-13-09-0001

Created by: S. Bitzas

Created on: 13 June 2013

Modified by: E. Mulholland

Modified on: 7 March 2014

Legend

") Sediment Sample 

Approx. Property Boundary

Waterbody

Wetland Type

Emergent

Forested

Scrub/Shrub

0 25 50

I 100

Feet

Data Sources:

Imagery: Bing Maps Aerials (Microsoft) [112]

All other data: Weston START [4; 10]

 Town of Bennington Parcels [111]

Jard Company, Inc.

VTD04814741

HRS Documentation Record

April 2014

14
 

 

 

") ") 

") 

") 

") 

") 

") 

") 

%

% 

%

% 

Furnace Brook 

Unnamed Stream 

Duck Pond 

Greene Pond 

SD-49A 

SD-47A 

SD-46A 

SD-41A 

SD-39A 

SD-36A 

SD-32A 

SD-31A 

Park Street 

P030 

P031 

P032 

P041 

P006 

P009 

P011 

P005 

P007 

I
 Figure 6B 

Contaminated Wetland and 

Sediment Sample Location Map 

Jard Company, Inc.

259 Bowen Road

Bennington, Vermont 

EPA Region I

Superfund Technical Assessment and 

Response Team (START) III

Contract No. EP-W-05-042

TDD Number: 13-09-0001

Created by: G. Hornok

Created on: 24 April 2013

Modified by: E. Mulholland

Modified on: 7 March 2014 

LEGEND 

") Sediment Sample 

Surface Water 

Surface Water Stream 

Piped 

Wetland Type

Emergent

Forested 

Scrub/Shrub

% 

Approx. Property Boundary 

Water Body

Culvert 

0 50 100 200
 

Feet
 

Data Sources: 

Imagery: Bing Maps Aerials (Microsoft) [112] 

All other data: Weston START [

 Town of Bennington Parce

4; 10]

ls [111]

Jard Company, Inc. 15 

VTD04814741 

HRS Documentation Record

April 2014 
Jard Company, Inc.

VTD04814741

HRS Documentation Record

April 2014

16

¡[

¡[

¡[

^_

^_

^_

^_

15-Mile Surface Water

Pathway Terminus

New York/Vermont Border

Walloomsac River

Furnace Brook

Unnamed Stream

Roaring Branch of the

Walloomsac River

Background Wetland

Probable Point of Entry No. 1

Contaminated Wetland

Furnace Brook

Duck Pond

Greene Pond

0 1 2 3

Miles

0 200 400 600 800 1,000

Feet

Probable Point of Entry No. 2

Surface Water Pathway- Branch 2

Surface Water Pathway- Branch 1

Unnamed Stream

Walloomsac River

Roaring Branch of the

Walloomsac River

Figure 7

Surface Water Pathway

Target Distance Limit

Jard Company, Inc.

259 Bowen Road

Bennington, Vermont

EPA Region I 

Superfund Technical Assessment and 

Response Team (START) III

Contract No. EP-W-05-042

TDD Number: 13-09-0001

Created by: G. Hornok

Created on: 22 October 2013

Modified by: E. Mulholland

Modified on: 7 March 2014

I

Legend

Probable Point of Entry

Documented Fishery Location

Surface Water Pathway

Surface Water

Contaminated Soil Source

Pile Source

Imagery: Bing Maps Aerials (Microsoft) [112]

Topos: USGS [3]

All other data: Weston START [4; 10]

Data Sources:

^_

¡[
REFERENCES

Ref.

No. Description of the Reference

[1] U.S. EPA (U.S. Environmental Protection Agency). 1990. Hazard Ranking System; Final Rule, 40 

CFR Part 300, A ppendix A. The complete Hazard Ranking System; Final Rule is available from 

http://www.epa.gov/superfund/sites/npl/hrsres/index.htm#HRS%20 Rule. 14 December. 140 pages.

[2] U.S. EPA (U.S. Environmental Protection Agency). 2014. Superfund Chemical Data Matrix (SCDM). 

Available from http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm. 30 January. Excerpt, 

13 pages.

[3] U.S. Geological Survey (USGS). 7.5’ Topographic Quadrangle. Bennington, Vermont. 1954. 1 page. 

[4] Weston Solutions, Inc. START (Superfund Technical Assessment and Response Team III). 2013. 

Field Logbook for the Jard Company Inc Site Reassessment. No. 01433-S. TDD No. 12-10-0008. 73 

pages.

[5] Bitzas, S. (START). 2013. Project Note, Jard Company Inc., RE: Latitude/Longitude Calculations. 

TDD No. 13-09-0001. 1 October. 2 pages. 

[6] EPA (U.S. Environmental Protection Agency). 2013. Comprehensive Environmental Response, 

Compensation, and Liability Information System (CERCLIS) Superfund Program, Region I, RE: Jard 

Company Inc. Online address: http://cumulis.epa.gov/supercpad/cursites/srchsites.cfm. Printout dated 

11 September. 4 pages. 

[7] City of Bennington, Vermont. Tax Assessor’s Property Card. Obtained by START personnel on 2 

October 2013. 3 pages.

[8] U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease Registry. 

2002. Toxicological Profile for Di(2-ehtylhexyl)phthalate. September. 336 pages. 

[9] Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2013.

Site Assessment Program Site-Specific Final Quality Assurance Project Plan for Surface and 

Subsurface Soil/Source, Ground Water and Sediment Sampling for Jard Company, Inc. Site 

Reassessment, Bennington, Vermont. TDD No. 12-10-0008. 25 February. 61 pages. 

[10] Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2013.

Site Inspection Expanded Trip Report for Jard Company, Inc. Site Reassessment, Bennington, 

Vermont. TDD No. 12-10-0008. 26 September. 258 pages. 

[11] U.S. Environmental Protection Agency (EPA). 2013. Contract Laboratory Program, All Chain of 

Custody Records for the Jard Company Inc. Site Reassessment. 18 pages.

[12] Hornok, G., Weston Solutions, Inc., (START). 2014. Memorandum, Jard Company Inc., RE: 

Wetland Delineation Memorandum. TDD No. 12-10-0008. 30 January. 50 pages. 

[13] Hornok, G. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START). 2013. Project Note, Jard Company, Inc., Contaminated Soil Source No. 1 Area (Former 

Facility Source). 13 October. 2 pages. 

Jard Company, Inc. 17 HRS Documentation Record

VTD048141741
REFERENCES

Ref.

No. Description of the Reference

Jard Company, Inc. 18 HRS Documentation Record

VTD048141741

[14] Hornok, G. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START). 2013. Project Note, Jard Company, Inc., Excavated Material Pile Size Determination and 

Documentation. 25 September. 7 pages. 

[15] Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2013. 

Soil/Source Description Field Data Sheets, Jard Company Inc., Bennington, Vermont. 134 pages. 

[16] Schiff, R. Milone & MacBroom, 2013. Email Re: Roaring Branch with attached Site Plan – Project 

Overview, Roaring Branch River and Floodplain Restoration Project Plans. 9 October. 6 pages. 

[17] Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2013. 

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[98] Reference Number Reserved.

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2013. Project Note: Top of the Stream Surface Water Elevation Calculations for SWP. 8 October. 9 

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[101] Hornok, G. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START). 2013. Project Note: 15-Mile Surface Water Pathway Target Distance Limit Description. 16 

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[102] Bitzas, S. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 

2013. Project Note: Sediment Sample Location Distance Measurements. 1 October. 7 pages. 

[103] Reference Number Reserved.

[104] Bitzas, S. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 

2013. Project Note: Hazardous Waste Sites within One mile of the Jard Company, Inc. Site Sources. 

14 October. 10 pages. 

[105] University of Minnesota. Dolomite. Online article, 

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[110] Tighe & Bond, Inc. 2006. Re: Addendum Letter Report, Environmental Site Investigation. 10 May. 

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[112] Microsoft. 2011. Bing Maps Aerial. http://arcgis.com, Internet accessed on 14 October 2013. 2 pages. 

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[114] University of Texas at Austin. What is Karst? Online article, 

http://www.esi.utexas.edu/outreach/caves/karst.php, Internet accessed 16 October 2013. 2 pages.

[115] Karst Waters Institute. What is Karst (and why is it important)?. Online article, 

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[116] Clean Water for Laymen. 2010. Groundwater sources origins, Article available at: www.clean-waterfor-laymen.com/groundwater-sources.html. Internet accessed 15 October 2013. 7 pages. 

[117] Dupree, C. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START). 2014. Project Note: Bedrock Geology Data. 28 February. 11 pages. 

[118] Mavris, G. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START). 2013. Project Note: Overburden Thickness. 16 October. 2 pages. 

[119] Robinson, K. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START). 2013. Project Note: Identification of Seeps in the Park Street Wetland Area. 16 October. 3 

pages. 

[120] Correspondence regarding Construction of well at Peck residence. 2013. Email from Joel Behrsing to 

Coppolino, P., Vermont Agency of Natural Resources (VT ANR) Department of Environmental 

Conservation (VT DEC), forwarded to Hornok, G. Weston Solutions, Inc., (START) (with 

attachment). 15 October. 4 pages. 

[121] Correspondence regarding Number of Residents at Watson household in 2010. 2013. E mail from 

Alan Watson to Coppolino, P., Vermont Agency of Natural Resources (VT ANR) Department of

Environmental Conservation (VT DEC), forwarded to Hornok, G. Weston Solutions, Inc., (START). 

7 October. 1 page. 

[122] Coppolino, P., Vermont Agency of Natural Resources (VT ANR) Department of Environmental 

Conservation (VT DEC). 2013. M emorandum Re: Watson Well, Bennington, VT. 16 October. 1 

page.

[123] Wischkaemper, H.K., Beliveau, A.F., Henderson, R.W. 2013. U.S. EPA Region 4 Technical Services 

Section Issue Paper for Polychlorinated Biphenyl Characterization at Region 4 Superfund and RCRA 

Sites. 28 February. 78 pages.

[124] U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease Registry. 

2000. Toxicological Profile for Polychlorinated Biphenyls (PCBs). November. 948 pages. 

[125] Plasan North America Product Line Information. 2013. Available from: http://www.plasansasa.com/. 

Accessed on 22 October 2013. 3 pages. 

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Floodplain Management Programs, Biennial Report to the General Assembly Pursuant to Act 110. 

January. 53 pages. 
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[127] Goswami, Neal P. and Zeke Wright (Bennington Banner). 2011. L ocal roads, cars swept away as 

rescue workers kept busy. 28 August. 3 pages. 

[128] Gomez and Sullivan Engineers, P.C. and Parish Geomorphic. 2007. P hase 2 S tream Geomorphic 

Assessment of Walloomsac River and Roaring Brank, Bennington County, Vermont Final Report. 

March. 48 pages. 

[129] Kelly, John F. (Weston Solutions, Inc. Superfund Technical Assessment and Response Team III). 

2014. Phone Conversation Record with Ms. Caroline Greene (Homeowner), Subject: Jard HRS – 

Perennial Stream Status Confirmation of Greene Pond and Unnamed Stream, Bennington, VT. TDD 

No. 13-09-0001. 20 January. 2 pages. 

[130] Vermont Department of Fish and Wildlife. 2013. New Fishing Opportunities in 2014. Article 

available at http://vermont.gov/portal/government/article.php?news=4657. Internet accessed 4 March 

2014. 2 pages. 

[131] Kelly, John F. (Weston Solutions, Inc. Superfund Technical Assessment and Response Team III). 

2014. Phone Conversation Record with Mr. Ken Cox (Fisheries Biologist). Subject: Jard HRS – Fish 

Consumption along the Walloomsac River, Bennington, VT. TDD No. 13-09-0001. 5 March. 1 page. 

[132] Kelly, John F. (Weston Solutions, Inc. Superfund Technical Assessment and Response Team III). 

2014. Phone Conversation with Mr. Chuck Kashner. Subject: Jard HRS – Fish Consumption along 

the Walloomsac River, Bennington, VT. TDD No. 13-09-0001. 3 March. 2 pages. 

[133] Kelly, John F. (Weston Solutions, Inc. Superfund Technical Assessment and Response Team III). 

2014. Phone Conversation with Mr. Gordon Whitman (Homeowner). Subject: Jard HRS – Whitman – 

Perennial Stream Status Confirmation of Greene Pond and Unnamed Stream, Bennington, VT. TDD 

No. 13-09-0001. 20 January. 2 pages. 

[134] Hornok, G. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START). 2014. Project Note: 15-Mile Surface Water Pathway Flow Rate Calculations. 4 March. 16 

pages.

[135] Hornok, G. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START). 2014. Project Note: Calculation of Angle Theta (Θ) for Dilution Weight Adjustment 

Value. 6 March. 2 pages.

[136] Bitzas, S. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 

2014. Project Note, Jard Company Inc., RE: Examination of Qualified Polychlorinated Source Data, 

Case 43392; SDG A4B24 and A4B36, TDD No. 13-09-0001; Task No. 0904-60; DC No. A-6909. 7 

March. 21 pages.

[137] U.S. Environmental Protection Agency. 1996. U sing Qualified Data to Document an Observed 

Release and Observed Contamination. November. 18 pages. 
SITE SUMMARY

The Jard Company, Inc. site (Jard site) consists of the release of polychlorinated biphenyls (PCBs) from the Jard 

operations. The site includes a contaminated soil source and a contiguous soil pile containing PCBs originating 

from the Jard facility operations, and the estimated extent of the documented release of PCBs to the overburden 

aquifer downgradient of the sources, and to the surface water pathway via ground water to surface water 

migration. The contaminated soil source (Source 1) consists of an area of contaminated soil located where the 

former Jard building stood, and around the perimeter of the former building location. The soil pile, (Source 2), 

located to the east and immediately adjacent to Source 1, originated from soils located along the southern 

boundary of the Jard property adjacent to a berm (levee) between the Jard building and the Roaring Branch of the 

Walloomsac River. In 2010, as a result of the stream restoration project along the Roaring Branch, soils were 

excavated and relocated to the present location (Source 2) for the berm to be reconstructed closer to the facility

[see Source Characterization sections]. From site sources, the Jard site extends northwest toward residential 

properties impacted by documented ground water contamination, and then continues north-northwest along the 

surface water pathway and wetland areas west of Park Street, terminating at the last point documented to contain 

source related contamination along the Unnamed Stream, just prior to Furnace Brook (see Figures 1 and 2). The 

release of PCBs has occurred to a private drinking water supply well and a sensitive environment, both located 

northwest of sources on t he Jard Company, Inc. facility property (the Jard property) (see Figure 1). Based on 

sampling conducted in April 2013 as part of an EPA Site Reassessment (SR), these sources have been 

documented to contain PCBs (analyzed as Aroclor 1242) [see Source Characterization sections]. The site has 

contributed a release of PCBs to ground water and a downgradient drinking water supply well has been 

documented [see the Ground Water Migration Pathway section of this HRS Documentation Record]. This release 

has resulted in the closure of the private drinking water supply well serving four residents [see the Ground Water 

Migration Pathway section]. In addition, a release of PCBs to the surface water pathway, via ground water flow, 

and impacts to wetland frontage have been documented [see Surface Water Migration Pathway]. Previous 

flooding events, occurring along the Roaring Branch of the Walloomsac River, including August 2011, may have 

resulted in PCB contaminants migrating from Source Nos. 1 and 2 to the Jard surface water pathway (SWP) via 

the overland flow/flood component; this possible migration route is not scored as part of this evaluation [126, p. 

28; 127, p. 1; 129; 133]. 

The Jard property is an approximately 11.26-acre parcel located at 259 Bowen Road in Bennington, Bennington 

County, Vermont (VT) (see Figure 1) [3; 5-7]. The parcel is identified by the Town of Bennington Property Map 

Number (No.) 45, a s Lot No. 01-73 [7]. The geographic coordinates of the Jard site, as measured from the 

southeast corner of the former building footprint, within the contaminated soil source, are 42o 53' 19.9" north 

latitude and 73o 11' 20.8" west longitude (see Figure 1) [3; 5]. The Jard property is bordered to the north by 

Bowen Road; to the east by a Vermont Agency of Transportation (VTrans) maintenance facility; to the south by 

the Roaring Branch of the Walloomsac River; and to the west by recreational/baseball (Little League) fields and 

residential properties along Park Street (see Figure 2) [10, p. 3]. 

The Jard Company, Inc. (Jard) operated on the property from 1969 t o 1989, producing zinc-coated capacitors 

(containing approximately 75 pounds of dielectric fluid), small non-fluid transformers [up to 75 kilo volt ampere 

(KVA)], and small motors (up to 200 watts) used in household appliances [20, p. 1; 23, pp. 1-2; 24, p. 5; 25, p. 1; 

26, p. 2; 31, pp. 5, 8]. A variety of hazardous wastes were generated at the Jard property in association with its 

manufacturing processes, including PCBs, a variety of volatile organic compounds (VOCs) [including 

trichloroethylene (TCE); 1,1,1-trichloroethane (1,1,1-TCA); and toluene], semivolatile organic compounds 

(SVOCs) [including bis-(2-ethylhexyl)phthalate (DEHP) which is also known as di-octyl phthalate (DOP)], waste 

hydraulic and lubricating oils, waste paints and varnishes, waste zinc oxide, waste-contaminated rejected 

capacitors, spent Speedi DriTM, and PCB- and phthalate-contaminated wastewater [8, p. 21; 31, p. 8; 34, p. 1]. 

According to file information, the manufacture of the oil-filled capacitors first involved foil winding [23, p. 1]. 

The windings, which were housed in metal sleeves, were then sent to an oil impregnation line, where the 

capacitors would be filled with dielectric fluids [23, pp. 1-2]. Originally, PCB oil was used as a dielectric fluid, 

but was later replaced by DOP in 1978 [23, pp. 1-2; 25, p. 4]. After the oil impregnation, the capacitors were 

Jard Company, Inc. 27 HRS Documentation Record

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SITE SUMMARY

Jard Company, Inc. 28 HRS Documentation Record

VTD048141741

degreased, tested, and painted [23, p. 1; 25, p. 4]. Known degreasing agents observed and documented on the 

property include TCE [26, pp. 42-43]. 

According to a summary of PCBs in Vermont prepared by the Agency of Environmental Conservation 

Department of Water Resources Water Quality Division in April 1976, at the time Jard was the only known PCB 

user in VT [21, p. 2]. Jard received an average of 686,500 pounds of PCBs per year (1971-1974 average) at the 

Jard property [20, p. 5]. From 1969 to 1971, Aroclor 1242 was used as an impregnating fluid, but by 1971 Jard 

replaced this with Aroclor 1016 [20, p. 5; 21, p. 2]. By 1978, and until operations ceased in 1989, DOP, which 

replaced PCBs, was used as an impregnating fluid for the foil windings of the capacitors and transformers [29, p. 

10]. Based on a letter to the U.S. EPA from Jard, the amount of Aroclor 1016 received by Jard each year from 

1971 through 1974 was 142,000 pounds, 632,000 pounds, 963,000 pounds, and 677,000 pounds, respectively [20, 

p. 5]. In addition, 332,000 pounds of Aroclor 1242 were received at the Jard property in 1971 [20, p. 5]. The letter 

produced by Jard also indicated disposal of solid and liquid PCB waste in local sanitary sewers and solid waste 

facilities [20, pp. 1 -6]. Rejected PCB-containing materials and oils were also shipped to disposal facilities for 

incineration or returned to the manufacturer [20, pp. 1-6; 22, pp. 1-2; 50, p. 3]. 

As part of the manufacturing process, Jard used non-contact cooling water, which was discharged to an 

underground storage tank (UST) south of the facility building for storage [21, p. 2; 31, pp. 47, 135; 37, p. 3; 39, 

pp. 15, 32; 50, p. 1]. Floor drains from inside the building also discharged into the UST, as well as potentially 

directly into underlying soils [39, p. 34; 50, p. 1 ]. The UST was connected to a concrete drywell, which was 

perforated by many one-inch slots and had three discharge pipes [29, pp. 7-9; 39, pp. 29, 32; 31, pp. 47, 135]. The 

drywell received overflow from the UST, and any overflow from the drywell was discharged to a drainage ditch 

in the front of the building [29, p. 7; 50, p. 2]. Overflow from the UST was also routed to a deep well which, 

along with the UST, provided cooling water for the manufacturing process [39, pp. 15, 32; 50, p. 2]. A subsequent 

interview with a former employee indicated that during the non-contact cooling process, gasket failures would 

cause the cooling waters and PCB-oils to come into contact [4, p. 27] . These potentially PCB-contaminated 

cooling waters would be discharged to the drywell system [4, p. 27]. The drywell was later removed during the 

2006-2007 EPA Removal Action [62, pp. 4, 12]. Finally, an additional trench floor drain system, which 

discharged directly to soils beneath the building slab, was located in the southern end of the building in the former 

production area and was determined to contain elevated concentrations of PCBs during site investigations [31, pp. 

31, 52; 39, pp. 15-16, 26, 30, 32, 36 ]. Releases of PCBs to the environment may have also occurred due to 

documented spills/leaks from containers and discharges to the municipal sewer system [20, pp. 2, 6]. 

Beginning with a routine industrial waste survey in October 1979, numerous inspections and investigations have 

taken place at the Jard property [23, pp. 1-3; 24, pp. 4-24; 25, pp. 2-22; 26, pp. 1-6; 29, pp. 3-28; 30, pp. 1-30; 31, 

pp. 5-58; 33, pp. 1 -2; 36, pp. 4-30; 40, pp. 2 -5; 41, pp. 1-4; 44, pp. 1 -9; 46, pp. 11-17]. These inspections and 

investigations indicated PCB contamination in soils and ground water adjacent to and beneath the former facility 

building [24, pp. 13-22, 32; 29, pp. 8, 19-26; 30, pp. 11-37, 64-152; 31, pp. 27-42, 111-154; 36, pp. 9-10, 15-29; 

39, pp. 20-68; 41, pp., 1-4; 44, pp. 3-4, 7, 9; 46, pp. 11-17, 21-26, 41-42; 59, pp. 1-3; 60, pp. 1-90; 62, pp. 24, 84-

85; 65, pp. 9-61; 67, pp. 2 -12; 68, pp. 3-4, 9-22]. To address some of the identified contamination, several EPA 

Removal Actions have been conducted at the Jard property to secure chemicals used in the manufacturing process 

which were left after the facility closed, conduct limited excavation of contaminated soils, demolish the facility 

building, remove a portion of the concrete foundation, and cap/secure PCB-contaminated soils to limit public 

exposure [37, pp. 7-8; 39, pp. 7-9; 42; 43; 62, pp. 4, 7-18, 24, 40-41]. Analytical results of soil samples collected 

from underneath the building, adjacent to the building footprint, and south of the building adjacent to the 

Walloomsac River have indicated the presence of TCE, DOP, and PCB Aroclors [24, pp. 13-19, 28-32; 29, pp. 

18-26; 30, pp. 13-37, 64-152; 31, pp. 7-36, 112-154; 36, pp. 15-18; 62, pp. 24, 83-85; 65, pp. 12-20, 43]. 

Hazardous substances detected in ground water beneath the Jard property include, but are not limited to, vinyl 

chloride, TCE, DOP, and PCB Aroclors [29, pp. 17-26; 31, pp. 21-22, 37-42; 36, pp. 19-20, 24-25; 44, pp. 3, 7; 

63, pp. 1-8; 67, pp. 1-12]. 
SITE SUMMARY

Jard Company, Inc. 29 HRS Documentation Record

VTD048141741

Recent investigations have focused on the transport of PCB Aroclors and component congeners in ground water

to the west of the Jard property and the impact on residential surface soils, wetland sediments, drinking water 

supply wells, and residential indoor air [63, pp. 1-3, 6-8; 64; 65, pp. 11-36, 42-49, 52-61; 66, pp. 22-33; 67, pp. 1-

12; 68, pp. 1-22; 69, pp. 1-3, 13-19; 80, pp. 1-3]. 
Source Characterization

Source No. 1 

2.2 SOURCE CHARACTERIZATION

2.2.1 SOURCE IDENTIFICATION

Name of source: Former Facility Source

Number of source: Source No. 1 

Source Type: Contaminated Soil 

Description and Location of Source (with reference to a map of the site): 

The Former Facility Source (Contaminated Soil – Source No. 1) is located on the Jard property (see Figures 2 and 

3B). The geographic coordinates of the Former Facility Source, as measured from its approximate center, are 42° 

53′ 21.4′′ north latitude and 73° 11′ 21.8′′ west longitude (see Figures 1 and 2) [5]. Source No. 1 constitutes the 

area around and beneath the former facility building, which was used in the manufacture of PCB-containing 

capacitors [31, pp. 5, 8; 39, p. 15 ]. Investigations on the Jard property have indicated the presence of PCBcontaminated soils in areas both around and below the former building footprint [30, pp. 14-16, 18, 20-21, 28-29, 

33, 36-37, 70-95, 119-137; 31, pp. 8-9, 14, 16-18, 31-33, 35, 112, 117-128, 142-143, 145-147; 65, pp. 12-13, 16, 

19, 43, 52]. Prior to the razing of the Former Facility Building, the topography of the Jard property was generally 

level to the east and south of the former building, level to slightly hummocky to the north of the building, and 

sloping moderately away from the building on its western side, with a small seasonal drainage swale trending 

along the northwestern portion of the property and continuing northwest along Bowen Road [30, p. 5; 31, p. 7]. In

addition, a berm of variable height, comprised of dredged river channel material, was located in the wooded area 

on the southern portion of the Jard property, along the northern bank of the Roaring Branch [31, p. 46]. This berm 

was reportedly constructed to prevent encroachment of the Roaring Branch on properties on the north side of the 

river, but also served to inhibit overland flow from the site sources from directly entering the river [31, p. 46]. 

Soil samples collected and analyzed for PCBs throughout the developed and undeveloped former facility areas, 

including beneath the facility building, around the facility building, and around the larger undeveloped wooded 

areas extending south to the Roaring Branch of the Walloomsac River and east and west to the adjacent 

properties, reveal widespread PCB contamination of the sub-slab soils, and exterior surface and deep (2.5 to 5.0 

feet bgs) soils at various locations, including the area extending south to the Roaring Branch and west to adjacent 

properties (ball fields) [31, pp. 5, 7, 43, 137 -138, 142-143, 145-147]. Removal actions have been conducted on 

the Jard property to address some areas of contaminated soil; however, areas of PCB-contaminated soil have been 

left in place [39, pp. 62-63, 66; 42, pp. 2-3; 43, pp. 1-2, 9; 62, pp. 24, 84-85]. In 2007, a permeable earthen cover 

was constructed over the former facility building footprint to limit human contact with contaminated soils; 

however, subsequent sampling has indicated that contamination is still present below the cover and in areas 

throughout the Jard property [10, p. 57-60, 72, 214-239; 62, pp. 15-18, 40-43; 65, pp. 12-20, 43, 52; 70, pp. 2-3; 

71, pp. 1-2]. After the demolition of the building superstructure and the disposal of PCB-contaminated soil “hot 

spots” beneath portions of the building slab, as part of the 2006 EPA Removal Action, EPA determined that soils 

and portions of the concrete slab that remained have lower, but actionable levels of PCB contamination [71, p. 1]. 

These areas remained on site but were covered with the permeable earthen cap designed to address the potential 

hazard of normal human and environmental contact with the contaminated materials remaining on site [71, pp. 1-

2]. 

In 2010, a stream restoration project was completed along the reach of the river adjacent the Jard facility, a 

component of which included the excavation of the berm (levee) and construction of a new berm closer to the 

facility building [65, pp. 10, 25, 52]. The berm along the Roaring Branch was previously located approximately 

90 feet north of the northern edge of the river, but the new berm was constructed closer to the Jard facility 

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Source Characterization

Source No. 1 

Jard Company, Inc. 31 HRS Documentation Record

VTD048141741

(approximately 40 feet farther north), to allow the river to access more of the historical floodplain and reduce 

future flood damage [65, p. 10] . PCB sampling results of the area extending south of the Jard facility to the 

Roaring Branch, including the area of soil material excavated during the 2010 river restoration project, indicate 

PCB contamination consistent with the release of PCBs from the Jard operations [14, pp. 1-4, 7; 16; 65, pp. 10, 

52, 145, 146]. The excavated soil material was removed from the southern portion of the facility and piled in an 

area east of the facility building, comprising Source No. 2 (discussed further below) [4, p. 2; 14, pp. 1-3]. Since 

the documentation of the specific locations of samples with elevated levels of PCB-contaminated soils collected 

during previous investigations are limited, and due to the fact that some portion of this material may have been 

relocated to Source No. 2, the boundaries of Source No. 1 are based on samples collected and analyzed as part of 

the 2013 EPA investigation, following completion of the stream restoration activities. Based on global positioning 

system (GPS) documentation of samples collected to characterize the Former Facility Source (Source No. 1), the 

estimated area of contaminated soil is 106,943 square feet (ft2

) [13].

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

- Background Concentrations: 

Source No. 1 is a contaminated soil source type; therefore, background soil samples have been presented to show 

that the soil contamination is above background levels. On 12, 15, and 18 April 2013, as part of the EPA SR and 

in accordance with the EPA-approved February 2013 Site-Specific Quality Assurance Project Plan (QAPP), 

background soil sampling activities were conducted [4, pp. 44-54, 67; 9, pp. 1, 24, 32-37; 10, pp. 33-35, 45, 78, 

206-209]. Ten background soil samples, collected from a residential property north of the Jard property, are 

presented to document the range of natural background conditions in the local vicinity of the site. The 10 

background soil samples were collected in the vicinity of the site, during the same time period, and using similar 

collection and analytical methods as the soil/source samples presented as part of the Source No. 1 characterization 

(see Figure 3A) [10, pp. 69, 78, 133, 135, 137-138, 140, 141; 11, pp. 11, 17; 15, pp. 28, 32, 41 -42, 44-46, 73-74, 

82, 116, 125-126; 19, pp. 292-293, 297, 299, 307-309, 314, 316, 322; 78]. 

Table 1 – Background Sample Description

Sample ID Sample Description Reference

P020-SS-01A 

(A4B95) 

Moist, dark brown, SILT, some organics, trace fine to coarse sand, trace 

fine gravel, trace clay. 19, p. 292

P020-SS-01B

(A4B97) 

Dark brown, SILT, little clay, trace fine to coarse sand, trace fine gravel, 

trace organics. 19, p. 293

P020-SS-03A 

(A4B91) 

Brown, SILT and fine to coarse SAND, trace fine to medium gravel, 

trace organics, trace clay. 19, p. 297 

P020-SS-04A 

(A4B90) 

Brown to dark brown, SILT, some fine to coarse sand, little fine to 

medium gravel, trace organics. 19, p. 299

P020-SS-07B 

(A4B92) 

Brown to dark brown, fine to medium SAND and SILT, little clay, trace 

organics, trace coarse sand. 19, p. 307

P020-SS-07C 

(A4B93) 

Wet, brown to dark brown, SILT, some clay, little fine sand, trace 

medium to coarse sand, trace organics, trace fine to medium gravel. 19, p. 308

P020-SS-08A

(A4B94) 

Brown, SILT and CLAY, little organics, trace fine to medium sand, trace 

fine gravel. 19, p. 309 

P020-SS-09C 

(A4B98) 

Brown, fine to medium GRAVEL and fine to medium SAND, little silt, 

trace clay, trace organics. 19, p. 314 
Source Characterization

Source No. 1 

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VTD048141741

Table 1 – Background Sample Description

P020-SS-10B 

(A4B96) 

Brown to yellow brown, SILT and fine SAND, little clay, trace medium 

to coarse sand, trace fine gravel, trace organics. 19, p. 316

P020-SS-15A 

(A4C37) 

Brown, CLAY and fine to medium SAND, some silt, trace coarse sand, 

trace fine to medium gravel, trace organics. 19, p. 322

As presented in Table 1, the 10 background soil samples contained varying compositions of naturally occurring 

native matrix materials (i.e., sand, silt, clay, gravel, and organic matter), which constituted major and/or minor 

components of the sample [19, pp. 292, 293, 297, 299, 307-309, 314, 316, 322]. Similarly, the soil/source samples 

presented as part of the Source No. 1 characterization exhibited varying compositions of the same naturally 

occurring native matrix materials (see Soil/Source Samples presented below) [78]. The analytical results of each 

Source No. 1 s oil/source sample were compared to the contaminant concentrations detected only in those 

background soil sample(s) which displayed the most similar matrix composition. 

The 10 background soil samples were submitted to a Contract Laboratory Program (CLP) laboratory (Chemtech 

Consulting Group) for analysis of low/medium Aroclor compounds following Statement of Work (SOW) 

SOM1.2, and the data were validated at the Tier II level by personnel not involved with the background/source 

sampling event and according to Region I EPA-NE Data Validation Functional Guidelines for Evaluating 

Environmental Analyses and the USEPA CLP National Functional Guidelines for Superfund Organic Method [4, 

pp. 44-54, 67; 11, pp. 11, 17; 19, pp. 292, 293, 297, 299, 307-309, 314, 316, 322; 77, pp. 1-4; 9; 79, pp. 1-4, 9-

10]. As part of this HRS Documentation Record and the evaluation of background concentrations, the following 

hazardous substance in background surface soil samples is presented: Aroclor 1242 (PCBs).

Among all 10 background soil samples, PCBs (analyzed as Aroclor 1242) were not detected above the laboratory 

reporting limits; and the highest sample-adjusted Contract Required Quantitation Limit (CRQL) was 62 

micrograms per kilogram (μg/Kg) in sample P021-SS-01A (A4B95) [79, p. 10; 87, pp. 1-2, 9, 101]. 

Table 2 - Background Concentration of Hazardous Substance

Sample ID

(CLP No.)

Sample 

Type Date

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(μg/Kg) 

SampleAdjusted 

CRQL

(μg/Kg) Reference

P020-SS-01A

(A4B95) Soil 4/12/2013 

PCBs

(Aroclor 1242) 62 U 62 

19, p. 292; 79, p. 10; 

87, pp. 1-2, 9, 101 

P020-SS-01B 

(A4B97) Soil 4/12/2013 

PCBs

(Aroclor 1242) 46 U 46 

19, p. 293; 79, p. 10; 

87, pp. 1-2, 9, 103 

P020-SS-03A 

(A4B91) Soil 4/15/2013 

PCBs

(Aroclor 1242) 42 U 42 

19, p. 297; 79, p. 9; 

87, pp. 1-2, 8, 97 

P020-SS-04A 

(A4B90) Soil 4/15/2013 

PCBs

(Aroclor 1242) 41 U 41 

19, p. 299; 79, p. 9; 

87, pp. 1-2, 8, 96 

P020-SS-07B 

(A4B92) Soil 4/15/2013 

PCBs

(Aroclor 1242) 42 U 42 

19, p. 307; 79, p. 9; 

87, pp. 1-2, 8, 98 

P020-SS-07C 

(A4B93) Soil 4/15/2013 

PCBs

(Aroclor 1242) 41 U 41 

19, p. 308; 79, p. 9; 

87, pp. 1-2, 8, 99 

P020-SS-08A 

(A4B94) Soil 4/12/2013 

PCBs

(Aroclor 1242) 52 U 52 

19, p. 309; 79, p. 9; 

87, pp. 1-2, 8, 100 
Source Characterization

Source No. 1 

Jard Company, Inc. 33 HRS Documentation Record

VTD048141741

Table 2 - Background Concentration of Hazardous Substance

P020-SS-09C 

(A4B98) Soil 4/15/2013 

PCBs

(Aroclor 1242) 38 U 38 

19, p. 314; 79, p. 10; 

87, pp. 1-2, 9, 104 

P020-SS-10B

(A4B96) Soil 4/15/2013 

PCBs

(Aroclor 1242) 42 U 42 

19, p. 316; 79, p. 10; 

87, pp. 1-2, 9, 102 

P020-SS-15A 

(A4C37) Soil 4/18/2013 

PCBs

(Aroclor 1242) 48 U 48 

19, p. 322; 77, p. 9; 

86, pp. 1-2, 8, 107 

U = The value was non-detected [77, p. 9; 79, pp. 9-10]. 

CRQL = Contract-required Quantitation Limit is the substance specific level that a Contract Laboratory Program 

(CLP) laboratory must be able to routinely and reliably detect. Used here, the CRQL has been adjusted 

per the CLP Scope of Work SOM01.2 and represents a sample specific quantitation limit [1, pp. 51585, 

51589; 77; 79; 86; 87] 

- Soil/Source Samples: 

On 1, 4, and 8 April 2013, as part of the EPA SR and in accordance with the EPA-approved February 2013 SiteSpecific QAPP, soil/source sampling activities for Source No. 1 were conducted [4, pp. 5-7, 13-18, 21-26; 9, pp. 

1, 21, 25-27; 10, pp. 13-15, 19-20, 22-25, 52-54, 72]. As part of the Source No. 1 characterization, 19 soil/source 

samples were collected from the Jard property in the area of the former building footprint (see Figure 3B) [4, pp. 

5-7, 13-18, 21-26; 10, pp. 13-15, 19-20, 22-25, 52-54, 72,133, 135, 137-138, 140-141, 148-150, 154, 156, 160-

161]. The 19 soil/source samples were collected from locations on the Jard property, during the same time period, 

and using the same collection and analytical methods as the 10 background soil samples presented as part of the 

Source No. 1 characterization [10, pp. 72, 133, 135, 137-138, 140, 141; 11, pp. 4, 6-7, 11, 17; 15, pp. 28, 32, 41-

42, 44-46, 73-74, 82, 116, 125 -126; 19, pp. 292 -293, 297, 299, 307 -309, 314, 316, 322] . Soil/source samples 

collected from Source No. 1 were of similar composition to the native materials described in the background soil 

samples presented for Source No. 1 (see Tables 1 and 3) [78]. Table 3 provides the matrix descriptions for the 

samples which define the contaminated soil source. 

Table 3 – Source No. 1 Sample Description

Sample ID Sample Description Reference

SB-01C 

(A4B17) 

Gray, fine SAND and SILT, little fine to coarse gravel. An oil staining was 

noted.

10, pp. 133, 

164

SB-03B 

(A4B18) 

Dark gray, fine to coarse SAND and SILT, some medium to coarse gravel (red 

rock fragments, possibly brick).

10, pp. 135, 

164

SB-05B 

(A4B19) 

Wet, brown to dark brown, fine SAND and SILT, trace medium to coarse sand, 

trace fine gravel.

10, pp. 137, 

165

SB-06B 

(A4B20) 

Dark brown, fine SAND and SILT, trace clay, trace fine to medium gravel, 

trace medium to coarse sand. 

10, pp. 138, 

165 

SB-08D 

(A4B21) 

Olive to gray, fine to medium GRAVEL and fine to coarse SAND, some silt, 

trace clay. A petroleum odor and visible sheen were noted.

10, pp. 140, 

166

SB-09D 

(A4B22) Wet, gray, fine to coarse SAND, some fine to coarse gravel, trace silt.

10, pp. 141, 

166

SO-24A 

(A4B45) Well-sorted, brown, fine SAND, little silt, trace organics, trace gravel. 15, p. 28 
Source Characterization

Source No. 1 

Jard Company, Inc. 34 HRS Documentation Record

VTD048141741

Table 3 – Source No. 1 Sample Description

SO-25B 

(A4B46) 

Brown, SILT, little fine to medium sand, trace clay, trace organics, trace coarse 

sand. 15, p. 32 

SO-28A 

(A4B47) Brown, fine to coarse SAND, little silt, trace fine gravel, trace organics. 15, p. 41 

SO-29A

(A4B48) 

Brown, fine to coarse SAND and SILT, little fine gravel, trace organics, trace 

clay. 15, p. 42 

SO-30B 

(A4B51) 

Brown to dark gray, SILT and fine SAND, trace medium to coarse sand, trace 

fine to medium gravel, trace organics, trace clay. 15, p. 44 

SO-31A 

(A4B49) 

Brown, fine SAND and SILT, trace medium to coarse sand, trace fine to 

medium gravel, trace organics, trace clay. 15, p. 45 

SO-31B 

(A4B50) 

Brown, SILT and fine SAND, little fine to medium gravel, trace medium to 

coarse sand, trace organics, trace clay. 15, p. 46 

SO-52A 

(A4B41) 

Wet, dark brown, CLAY and SILT, little fine to coarse sand, trace fine gravel, 

trace organics. 15, p. 73 

SO-53A

(A4B42) 

Brown, SILT and fine to coarse SAND, little fine to medium gravel, trace 

organics, trace clay. 15, p. 74 

SO-61A 

(A4B40) 

Brown, SILT, some fine to coarse sand, trace fine gravel, trace organics, trace 

clay. 15, p. 82 

SO-85C 

(A4B44) 

Brown, SILT and fine to coarse SAND, little fine to medium gravel, trace 

organics, trace clay. 15, p. 116 

SO-91A 

(A4B43) 

Brown SILT, some fine to coarse sand, trace fine gravel, trace organics, trace 

clay. 15, p. 125 

SO-92A 

(A4B39) 

Dark brown, SILT, little fine to coarse sand, little organics, trace clay, trace fine 

to medium gravel. 15, p. 126 

The 19 soil/source samples were submitted to a CLP laboratory (Chemtech Consulting Group) for analysis of 

low/medium Aroclor compounds following SOW SOM1.2, and the data were validated at the Tier II level by 

personnel not involved with the source sampling event and according to Region I EPA-NE Data Validation 

Functional Guidelines for Evaluating Environmental Analyses and the USEPA CLP National Functional 

Guidelines for Superfund Organic Methods [4, pp. 5-7, 13-18, 21-26; 10, pp. 133, 135, 137-138, 140-141; 11, pp. 

4, 6-7; 15, pp. 28, 32, 41-42, 44-46, 73-74, 82, 116, 125-126; 72, pp. 1-5, 10; 73, pp. 1-6, 10-12]. 

Among the 19 soil/source samples, PCBs (analyzed as Aroclor 1242) were detected at a maximum concentration 

of 4,800,000 μg/Kg in soil/source sample SB-03B (A4B18) (see Table 4) [72, p. 10]. Based on chemical analysis 

of soil/source samples collected during the EPA SR, Source No. 1 has been documented to contain PCBs

(analyzed as Aroclor 1242), which is defined as a hazardous substance according to the HRS [1, p. 51586]. PCBs

(analyzed as Aroclor 1242), were detected in Source No. 1 soil/source samples at concentrations significantly 

above background concentrations [72, p. 10; 73, pp. 10-12; 77, p. 9; 79, pp. 9-10]. Therefore, PCBs (analyzed as 

Aroclor 1242), are considered to be associated with Source No. 1 [1, p. 51588 (Section 2.2.2)]. 
Source Characterization

Source No. 1 

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VTD048141741

Table 4 - Concentration of Hazardous Substance Associated with Source No. 1 

Sample ID

(CLP No.)

Sample 

Type Date

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(μg/Kg) 

SampleAdjusted 

CRQL

(μg/Kg) Reference

SB-01C 

(A4B17) 

Soil/

Source 4/1/2013 

PCBs

(Aroclor 1242) 280,000* 39,000* 

10, p. 133; 72, p. 10; 81, 

pp. 1-2, 8, 72-73 

SB-03B 

(A4B18) 

Soil/

Source 4/1/2013 

PCBs

(Aroclor 1242) 4,800,000* 71,000* 

10, p. 135; 72, p. 10; 81, 

pp. 1-2, 8, 74-75 

SB-05B 

(A4B19) 

Soil/

Source 4/8/2013 

PCBs

(Aroclor 1242) 820* 73* 

10, p. 137; 72, p. 10; 81, 

pp. 1-2, 8, 76-77 

SB-06B 

(A4B20) 

Soil/

Source 4/8/2013 

PCBs

(Aroclor 1242) 1,900* 360* 

10, p. 138; 72, p. 10; 81, 

pp. 1-2, 8, 78-79 

SB-08D 

(A4B21) 

Soil/

Source 4/8/2013 

PCBs

(Aroclor 1242) 730,000* 72,000* 

10, p. 140; 72, p. 10; 81, 

pp. 1-2, 8, 80-81 

SB-09D 

(A4B22) 

Soil/

Source 4/8/2013 

PCBs

(Aroclor 1242) 40,000* 3,600* 

10, p. 141; 72, p. 10; 81, 

pp. 1-2, 8, 82-83 

SO-24A 

(A4B45) 

Soil/

Source 4/4/2013 

PCBs

(Aroclor 1242) 1,100* 360* 

15, p. 28; 73, p. 11; 82, 

pp. 1-2, 8, 87-88 

SO-25B 

(A4B46) 

Soil/

Source 4/4/2013 

PCBs

(Aroclor 1242) 2,000* 390* 

15, p. 32; 73, p. 11; 82, 

pp. 1-2, 8, 89-90 

SO-28A 

(A4B47) 

Soil/

Source 4/4/2013 

PCBs

(Aroclor 1242) 1,000* J 360* 

15, p. 41; 73, p. 11; 82, 

pp. 1-2, 8, 91-92 

SO-29A 

(A4B48) 

Soil/

Source 4/4/2013 

PCBs

(Aroclor 1242) 1,800* 360* 

15, p. 42; 73, p. 11; 82, 

pp. 1-2, 8, 93-94 

SO-30B 

(A4B51) 

Soil/

Source 4/4/2013 

PCBs

(Aroclor 1242) 7,300* 3,800* 

15, p. 44; 73, p. 12; 82, 

pp. 1-2, 9, 99-100 

SO-31A 

(A4B49) 

Soil/

Source 4/4/2013 

PCBs

(Aroclor 1242) 1,100* 180* 

15, p. 45; 73, p. 11; 82, 

pp. 1-2, 8, 95-96 

SO-31B 

(A4B50) 

Soil/

Source 4/4/2013 

PCBs

(Aroclor 1242) 3,500* 390* 

15, p. 46; 73, p. 12; 82, 

pp. 1-2, 9, 97-98 

SO-52A 

(A4B41) 

Soil/

Source 4/4/2013 

PCBs

(Aroclor 1242) 630* J 480* 

15, p. 73; 73, p. 10; 82, 

pp. 1-2, 7, 80-81 

SO-53A 

(A4B42) 

Soil/

Source 4/4/2013 

PCBs

(Aroclor 1242) 700* J 370* 

15, p. 74; 73, p. 10; 82, 

pp. 1-2, 7, 82-83 

SO-61A 

(A4B40) 

Soil/

Source 4/4/2013 

PCBs

(Aroclor 1242) 1,200* 200* 

15, p. 82; 73, p. 10; 82, 

pp. 1-2, 7, 78-79 

SO-85C 

(A4B44) 

Soil/

Source 4/8/2013 

PCBs

(Aroclor 1242) 1,200* 200* 

15, p. 116; 73, p. 11; 82, 

pp. 1-2, 8, 85-86 

SO-91A 

(A4B43) 

Soil/

Source 4/8/2013 

PCBs

(Aroclor 1242) 110 38 

15, p. 125; 73, p. 11; 82, 

pp. 1-2, 8, 84 

SO-92A 

(A4B39) 

Soil/

Source 4/8/2013 

PCBs

(Aroclor 1242) 1,100* 420* 

15, p. 126; 73, p. 10; 82, 

pp. 1-2, 7, 76-77 
Source Characterization

Source No. 1 

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J = The value is estimated [72, p. 10; 73, pp. 10 -12]. The qualified data are estimated due to elevated 

percent difference between the gas chromatograph columns, which represents an unknown bias [136]. 

For this reason, EPA has evaluated the possible impact of this bias on the association of the “J” 

qualified substances, using the EPA fact sheet, Using Qualified Data to Document an Observed Release 

and Observed Contamination [136; 137]. While this fact sheet was not developed for adjusting 

qualified source data, if the “J” qualified source data were adjusted per this EPA guidance to reflect the 

possible impact of the bias on the contaminant concentration, as a check to ensure the substance was 

present at a concentration above that in the native soil, three samples would no longer qualify as source 

samples[136, 137]. However, omission of the three “J” qualified samples presented above would only 

slightly change the size of the contaminated soil, Source No. 1, and the number of hazardous substances 

associated with the source would not be reduced. 

* = Reported value is from a diluted analysis. [72, p. 10; 73, pp. 10-12]. 

CRQL = Contract-Required Quantitation Limit is the substance-specific level that a Contract Laboratory Program 

(CLP) laboratory must be able to routinely and reliably detect. Used here, the CRQL has been adjusted 

per the CLP Scope of Work SOM01.2 and represents a sample-specific quantitation limit [1, pp. 51585, 

51589; 72; 73]. 

List of Hazardous Substances Associated with Source

PCBs (analyzed as Aroclor 1242) 

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Observations indicated that no portion of Source No. 1 has a maintained engineered cover or complete run-on 

and run-off control management systems [4, p. 24; 10, pp. 133, 135, 137-138, 140, 142; 15, pp. 28, 32, 41-42, 44-

46, 73-74, 82, 116, 125 -126]. An earthen cover was installed over the former building footprint in 2007 to limit 

human contact; however, this cap was not constructed to be impermeable [70, pp. 2-3; 71, pp. 1-2]. In addition, 

portions of the contaminated soil source are outside of the capped area and remain uncovered (see Figure 3B) [70, 

pp. 2-3; 71, pp. 1-2]. No report of a natural or man-made liner was documented during source sampling activities 

[4, p. 24; 10, pp. 133, 135, 137-138, 140, 142; 15, pp. 28, 32, 41 -42, 44-46, 73-74, 82, 116, 125-126]. Therefore, 

Source No. 1 does not have full containment, and the source yields a containment value of 10 [1, p. 51596 (Table 

3-2)].

Table 5 - Hazardous Substances Available to Ground Water Pathway and Ground Water to Surface 

Water Component of Surface Water Pathway

Containment Description Containment Factor References

Release to ground water: Based on the lack of a liner, a 

maintained engineered cover, and any complete run-on 

and run-off control management systems, a Containment 

Factor Value of 10 has been assigned for release to the 

Ground Water Migration Pathway and Surface Water 

Migration Pathway (Ground Water to Surface Water 

component) for Source No. 1. 

10 4, p. 24; 10, pp. 133, 135, 

137-138, 140, 142; 15, pp. 

28, 32, 41-42, 44-46, 73-

74, 82, 116, 125-126 
Source Characterization

Source No. 1 

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2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1 Hazardous Waste Quantity

The Hazardous Waste Quantity for Source No. 1 was assigned based on the Area Factor Value of a “contaminated 

soil” source type [1, p. 51591 (Table 2-5, Section 2.4.2.1.4)]. The Hazardous Constituent Quantity, Hazardous 

Wastestream Quantity, and Volume values were not evaluated for Source No. 1 because insufficient information 

was available, as described in the sections below [1, pp. 51590-51591 (Sections 2.4.2.1.1, 2.4.2.1.2, and 2.4.2.1.3, 

Table 2-5)].

2.4.2.1.1 Hazardous Constituent Quantity

Description

The Hazardous Constituent Quantity for Source No. 1 could not be adequately determined according to the HRS 

requirements; that is, the total mass of all Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA) hazardous substances in the source and releases from the source is not known and cannot be 

estimated with reasonable confidence [1, pp. 51590-51591 (Section 2.4.2.1.1)]. Insufficient historical and current 

data [manifests, potentially responsible party (PRP) records, State records, permits, waste concentration data, etc.] 

are available to adequately calculate the total mass of all CERCLA hazardous substances in the source and the 

associated releases from the source. Therefore, there is insufficient information to calculate the total Hazardous 

Constituent Quantity for Source No. 1 with reasonable confidence.

Hazardous Constituent Quantity Assigned Value: Not Scored

2.4.2.1.2 Hazardous Wastestream Quantity

Description

The Hazardous Wastestream Quantity for Source No. 1 could not be adequately determined according to the HRS 

requirements; that is, the total mass of all hazardous wastestreams and CERCLA pollutants and contaminants for 

the source and releases from the source is not known and cannot be estimated with reasonable confidence [1, p. 

51591 (Section 2.4.2.1.2)]. Insufficient historical and current data (manifests, PRP records, State records, permits, 

waste concentration data, annual reports, etc.) are available to adequately calculate the total mass of all hazardous 

wastestreams and CERCLA pollutants and contaminants for the source and the associated releases from the 

source. Therefore, there is insufficient information to adequately calculate or extrapolate the total or a partial 

Hazardous Wastestream Quantity for Source No. 1 with reasonable confidence. 

Sum of Wastestream Quantity/5,000 [1, p. 51591 (Table 2-5)]: Not Scored 

Hazardous Wastestream Quantity Assigned Value: Not Scored

2.4.2.1.3 Volume

Description

The volume for Source No. 1 could not be adequately determined according to the HRS requirements because 

insufficient historical and current waste sampling data are available to adequately calculate the volume of the 

source with reasonable confidence [1, p. 51591 ( Section 2.4.2.1.3)]. Insufficient historical or current sampling 
Source Characterization

Source No. 1 

Jard Company, Inc. 38 HRS Documentation Record

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data are available to adequately estimate the depth of waste material within the source. Therefore, there is 

insufficient information to adequately calculate or estimate the volume for Source No. 1. 

Volume Assigned Value: 0 

2.4.2.1.4 Area

Description

Based on sampling results and observations of the contaminated soil material contained within Source No. 1, the 

areal extent of the source was documented using GPS and by connecting the sample locations presented in Table 

4 (see Figure 3B) [4, p. 6; 13, p. 1]. Based on the information recorded as part of the EPA SR, the area of the 

Former Facility Source (Source No. 1) was determined to be approximately 106,943 ft2 (see Figure 3B) [4, p. 6; 

13, p. 1]. 

Table 6 - Area

Source Type Units (ft2) References

Contaminated Soil 106,943 4, p. 6; 13 

Sum (ft2

): 106,943 

Equation for Assigning Value [1, p. 51591 (Table 2-5)]: Area/34,000 = 106,943/34,000 

Area Assigned Value: 3.14 

2.4.2.1.5 Source Hazardous Waste Quantity Value

Highest assigned value assigned [1, p. 51591 (Table 2-5)]: 3.14 
Source Characterization

Source No. 2 

2.2 SOURCE CHARACTERIZATION

2.2.1 SOURCE IDENTIFICATION

Name of source: Excavated Material Pile

Number of source: Source No. 2 

Source Type: Pile

Description and Location of Source (with reference to a map of the site): 

The Excavated Material Pile (Pile – Source No. 2) is located on the Jard property (see Figures 2 and 3B). The 

geographic coordinates of the Excavated Material Pile, as measured from its approximate center, are 42° 53′ 20.3′′ 

north latitude and 73° 11′ 18.0′′ west longitude (see Figures 1 and 2) [5]. Source No. 2 comprises the material 

which was excavated from the southern portion of the Jard property during a 2010 river restoration project [14, 

pp. 1-4, 7; 16; 65, pp. 10, 52]. Prior to the razing of the Former Facility Building, the topography of the Jard 

property was generally level to the east and south of the former building, level to slightly hummocky to the north 

of the building, and sloping moderately away from the building on its western side, with a small seasonal drainage 

swale trending along the northwestern portion of the property and continuing northwest along Bowen Road [30, p. 

5; 31, p. 7]. In addition, a berm of variable height, comprised of dredged river channel material, was located in the 

wooded area on the southern portion of the Jard property, along the northern bank of the Roaring Branch [31, p. 

46]. This berm was reportedly constructed to prevent encroachment of the Roaring Branch on properties on the 

north side of the river, but also served to inhibit overland flow from the “pile” from directly entering the river [31, 

p. 46]. During investigations prior to the 2010 river restoration project, soil samples collected and analyzed for 

PCBs throughout the developed and undeveloped former facility areas revealed widespread PCB contamination of 

the sub-slab soils, and exterior surface and deep (2.5 to 5.0 feet bgs) soils at various locations, including the area 

extending south to the Roaring Branch [31, pp. 5, 7, 43, 52, 135, 137-138, 142-143, 145-147]. The 2010 stream 

restoration project was completed along the reach of the river adjacent to the Jard facility, a component of which 

included the excavation of the berm (levee) and construction of a new berm closer to the facility building [65, pp. 

10, 25, 52] . The berm along the Roaring Branch was previously located approximately 90 f eet north of the 

northern edge of the river, but the new berm was constructed closer to the Jard facility (approximately 40 feet 

farther north), as part of a floodplain restoration project to allow the river to access more of the historical 

floodplain and to reduce future flood damage [65, p. 10]. PCB sampling results of the area extending south of the 

Jard facility to the Roaring Branch, including the area of soil material excavated during the 2010 river restoration 

project, indicate PCB contamination consistent with the release of PCBs from the Jard operations and that the 

PCB contamination in this area was previously contiguous with Source No. 1 [14, pp. 1-4, 7; 16; 65, pp. 10, 52, 

145, 146]. The excavated soil material was removed from the southern portion of the facility and piled in an area 

east of the facility building, comprising Source No. 2 [4, p. 2; 14, pp. 1-3]. Based on i nformation from the 

Vermont Agency of Natural Resources Department of Environmental Conservation (VT ANR DEC), the 

engineers responsible for the work stockpiled the soils from the southern boundary of the Jard property on the 

eastern portion of the Jard property [4, p. 2; 14, pp. 1-3]. Approximately 33,250 cubic yards (yd3

) of material 

originating from the southern portion of the Jard property are staged in the Excavated Material Pile [14, pp. 1-4]. 

Jard Company, Inc. 39 HRS Documentation Record

VTD048141741
Source Characterization

Source No. 2 

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2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

- Source Samples:

On 3 and 4 April 2013, as part of the EPA SR and in accordance with the EPA-approved February 2013 SiteSpecific QAPP, source sampling activities for Source No. 2 were conducted [4, pp. 11-18; 9, pp. 1, 21, 25-27; 10, 

pp. 18-19, 52-54, 72; 15, pp. 6, 16, 25-26, 51, 53, 65-66, 78, 83]. As part of the Source No. 2 characterization, 10 

source samples are presented which were collected from various locations throughout the pile (see Figure 3B) [4, 

pp. 11-18; 10, pp. 18 -19, 52-54, 72, 144, 146 -147, 151, 153, 155 -156]. Table 7 provides the matrix descriptions 

for the samples which define the pile source. 

Table 7 – Source No. 2 Sample Description

Sample ID Sample Description Reference

SO-06A 

(A4B23) 

Brown, SILT, some fine to coarse sand, little fine gravel, trace organics, trace 

clay. 15, p. 6 

SO-14A 

(A4B25) 

Brown, SILT and fine to coarse SAND, little fine to coarse gravel, trace 

organics. 15, p. 16 

SO-21A 

(A4B27) 

Brown, fine SAND and SILT, little fine to medium gravel, trace organics, trace 

medium to coarse sand. 15, p. 25 

SO-22A 

(A4B28) 

Olive brown, SILT and fine to coarse SAND, little clay, little fine to medium 

gravel, trace organics (rootlets). 15, p. 26 

SO-34A 

(A4B30) 

Brown, fine to coarse SAND and SILT, little fine to medium gravel, trace clay, 

trace organics. 15, p. 51 

SO-36A 

(A4B31) 

Brown, fine to coarse SAND and SILT, trace fine to medium gravel, trace clay, 

trace organics. 15, p. 53 

SO-45A 

(A4B36) 

Brown, fine to coarse SAND and SILT, trace fine to medium gravel, trace 

organics. 15, p. 65 

SO-46A 

(A4B32) 

Dark brown, SILT and fine to coarse SAND, trace fine to medium gravel, trace 

organics. 15, p. 66 

SO-57A 

(A4B38) 

Dark brown, SILT, little organics, trace fine to coarse sand, trace fine to 

medium gravel, trace clay. 15, p. 78 

SO-62A 

(A4B33) 

Brown, fine to coarse SAND and SILT, little fine to medium gravel, trace 

organics, trace clay. 15, p. 83 

The 10 source samples were submitted to a CLP laboratory (Chemtech Consulting Group) for analysis of 

low/medium Aroclor compounds following SOW SOM1.2, and the data were validated at the Tier II level by 

personnel not involved with the source sampling event and according to Region I EPA-NE Data Validation 

Functional Guidelines for Evaluating Environmental Analyses and the USEPA CLP National Functional 

Guidelines for Superfund Organic Methods [4, pp. 11-18; 11, pp. 4-5, 7; 15, pp. 6, 16, 25 -26, 51, 53, 65-66, 78, 

83; 72, pp. 1-5, 9, 11; 73, pp. 1-6, 10]. 

Among the 10 source samples, PCBs (analyzed as Aroclor 1242) were detected at a maximum concentration of 

1,600 μg/Kg in source sample SO-36A (A4B31) (see Table 8) [72, p. 1 1]. Based on chemical analysis of 

soil/source samples collected during the EPA SR, Source No. 2 has been documented to contain PCBs (analyzed 

as Aroclor 1242), which is defined as a hazardous substance according to the HRS [1, p. 51586]. Therefore, the 
Source Characterization

Source No. 2 

Jard Company, Inc. 41 HRS Documentation Record

VTD048141741

hazardous substance PCBs (analyzed as Aroclor 1242) is considered to be associated with Source No. 2 [1, p. 

51588 (Section 2.2.2)]. 

Table 8 - Concentration of Hazardous Substance Associated with Source No. 2 

Sample 

ID

Sample 

Type Date

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(μg/Kg) 

SampleAdjusted 

CRQL

(μg/Kg) Reference

SO-06A 

(A4B23) Source 4/3/2013 

PCBs

(Aroclor 1242) 150 J 39 

15, p. 6; 72, p. 11; 81, 

pp. 1-2, 9, 84 

SO-14A 

(A4B25) Source 4/3/2013 

PCBs

(Aroclor 1242) 120 37 

15, p. 16; 72, p. 9; 81, 

pp. 1-2, 7, 86 

SO-21A 

(A4B27) Source 4/3/2013 

PCBs

(Aroclor 1242) 110 J 36 

15, p. 25; 72, p. 9; 81, 

pp. 1-2, 7, 88 

SO-22A 

(A4B28) Source 4/3/2013 

PCBs

(Aroclor 1242) 140 36 

15, p. 26; 72, p. 9; 81, 

pp. 1-2, 7, 89 

SO-34A

(A4B30) Source 4/4/2013 

PCBs

(Aroclor 1242) 320 37 

15, p. 51; 72, p. 11; 

81, pp. 1-2, 9, 91 

SO-36A 

(A4B31) Source 4/4/2013 

PCBs

(Aroclor 1242) 1,600* 390* 

15, p. 53; 72, p. 11; 

81, pp. 1-2, 9, 92-93 

SO-45A 

(A4B36) Source 4/4/2013 

PCBs

(Aroclor 1242) 350 J 38 

15, p. 65; 73, p. 10; 

82, pp. 1-2, 7, 73 

SO-46A

(A4B32) Source 4/4/2013 

PCBs

(Aroclor 1242) 1,200* 370* 

15, p. 66; 72, p. 11; 

81, pp. 1-2, 9, 94-95 

SO-57A 

(A4B38) Source 4/4/2013 

PCBs

(Aroclor 1242) 250 45 

15, p. 78; 73, p. 10; 

82, pp. 1-2, 7, 75 

SO-62A 

(A4B33) Source 4/4/2013 

PCBs

(Aroclor 1242) 180 38 

15, p. 83; 72, p. 9; 81, 

pp. 1-2, 7, 96 

J = The value is estimated [72, pp. 9, 11; 73, p. 10] . The qualified data are estimated due to elevated 

percent difference between the gas chromatograph columns and field duplicate precision, which 

represents an unknown bias; however, this quantification does not impact the identification of the 

presence of PCBs [136]. 

* = Reported value is from diluted analysis [72, p. 11]. 

CRQL = Contract-Required Quantitation Limit is the substance-specific level that a Contract Laboratory Program 

(CLP) laboratory must be able to routinely and reliably detect. Used here, the CRQL has been adjusted 

per the CLP Scope of Work SOM01.2 and represents a sample-specific quantitation limit [1, pp. 51585, 

51589; 74]. 

List of Hazardous Substances Associated with Source

PCBs (analyzed as Aroclor 1242) 
Source Characterization

Source No. 2 

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2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Observations indicated that no portion of Source No. 2 has a maintained engineered cover or complete run-on and 

run-off control management systems [4, p. 19]. No report of a natural or man-made liner was documented during 

source sampling activities or through communications with the engineering firm responsible for the river 

restoration [4, p. 19; 15, pp. 6, 16, 25-26, 51, 53, 65-66, 78, 83; 16, p. 1]. Therefore, Source No. 2 does not have 

full containment, and the source yields a containment value of 10 [1, p. 51596 (Table 3-2)].

Table 9 - Hazardous Substances Available to Ground Water Pathway and Ground Water to Surface 

Water Component of the Surface Water Pathway 

Containment Description Containment Factor References

Release to ground water: Based on the lack of a liner, a 

maintained engineered cover, and any complete run-on 

and run-off control management systems, a Containment 

Factor Value of 10 has been assigned for release to the 

Ground Water Migration Pathway and Surface Water 

Migration Pathway (Ground Water to Surface Water 

component) for Source No. 2. 

10 

4, p. 19; 15, pp. 6, 16, 25-

26, 51, 53, 65-66, 78, 83; 

16, p. 1 

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1 Hazardous Waste Quantity

The Hazardous Waste Quantity for Source No. 2 was assigned based on the Volume Assigned Value of a “pile” 

source type [1, p. 5159 1, Table 2-5, Section 2.4.2.1.3]. The Hazardous Constituent Quantity and Hazardous 

Wastestream Quantity Values were not evaluated for Source No. 2 because insufficient information was available, 

as described in the sections below [1, pp. 51590-51591 (Sections 2.4.2.1.1 and 2.4.2.1.2, Table 2-5)] 

2.4.2.1.1 Hazardous Constituent Quantity

Description

The Hazardous Constituent Quantity for Source No. 2 could not be adequately determined according to the HRS 

requirements; that is, the total mass of all CERCLA hazardous substances in the source and releases from the 

source is not known and cannot be estimated with reasonable confidence [1, pp. 51590-51591 (Section 2.4.2.1.1)]. 

Insufficient historical and current data (manifests, PRP records, State records, permits, waste concentration data, 

etc.) are available to adequately calculate the total mass of all CERCLA hazardous substances in the source and 

the associated releases from the source. Therefore, there is insufficient information to calculate the total 

Hazardous Constituent Quantity for Source No. 2 with reasonable confidence. 

Hazardous Constituent Quantity Assigned Value: Not Scored

2.4.2.1.2 Hazardous Wastestream Quantity

Description 

The Hazardous Wastestream Quantity for Source No. 2 could not be adequately determined according to the HRS 

requirements; that is, the total mass of all hazardous wastestreams and CERCLA pollutants and contaminants for 
Source Characterization

Source No. 2 

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VTD048141741

the source and releases from the source is not known and cannot be estimated with reasonable confidence [1, p. 

51591 (Section 2.4.2.1.2)]. Insufficient historical and current data (manifests, PRP records, State records, permits, 

waste concentration data, annual reports, etc.) are available to adequately calculate the total mass of all hazardous 

wastestreams and CERCLA pollutants and contaminants for the source and the associated releases from the 

source. Therefore, there is insufficient information to adequately calculate or extrapolate the total or a partial 

Hazardous Wastestream Quantity for Source No. 2 with reasonable confidence. 

Sum of Wastestream Quantity/5,000 [1, p. 51591 (Table 2-5)]: Not Scored 

Hazardous Wastestream Quantity Assigned Value: Not Scored

2.4.2.1.3 Volume

Description

An estimated volume calculation was determined for Source No. 2 based on observations, as well as height 

measurements and perimeter area GPS data obtained in the field [4, p. 3 ; 14, pp. 1,7] . Based on he ight 

measurements and perimeter area GPS data obtained in the field, a volume estimate of 37,981 yd3 was calculated 

[14, pp. 1,7]. Information provided by the engineers responsible for oversight during the river restoration and 

creation of the pile indicated an estimated volume for Source No. 2 of approximately 33,250 yd3 [14, pp. 1-4]. 

Therefore, the volume estimate of 33,250 yd3 used for this HRS Documentation Record and presented below is a 

minimal estimate.

Table 10 - Volume

Source Type

Description

(# drums or dimensions)

Units

(yd3

) References

Pile Volume 33,250 4, p. 3; 14, pp. 1-7 

Sum (yd3

): 33,250 

Equation for Assigning Value [1, p. 51591 (Table 2-5)]: Volume/2.5 = 33,250/2.5 

Volume Assigned Value: 13,300

2.4.2.1.4 Area

Description

Based on the HRS, if the volume of a source can be determined, the area measure of that source should not be 

evaluated and the area value assigned should be 0 [1, p. 51591 (Section 2.4.2.1.3)]. 

Area Assigned Value: 0

2.4.2.1.5 Source Hazardous Waste Quantity Value

Highest assigned value assigned [1, p. 51591 (Table 2-5)]: 13,300
Source Characterization

Summary of Source Descriptions/Other Possible Sources

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SUMMARY OF SOURCE DESCRIPTIONS

Table 11 – Summary of Source Descriptions

Source 

No.

Source 

HWQ

Value

Source 

Hazardous 

Constituent 

Quantity 

Complete? 

(Y/N)

Containment Factor Value by Pathway

Ground 

Water 

(GW)

(Ref. 1, 

Table 3-2) 

Surface Water (SW) Air

Overland/ 

flood 

(Ref. 1, 

Table 4-2) 

GW to 

SW

(Ref. 1, 

Table 3-

2) 

Gas

(Ref. 1, 

Table 6-

3) 

Particulate

(Ref. 1, 

Table 6-9) 

1 3.14 N 10 NS 10 NS NS

2 13,300 N 10 NS 10 NS NS

HWQ = Hazardous Waste Quantity

NS = Not Scored

Total Source Hazardous Waste Quantity Value: 13,303.14 

Description of Other Possible Sources: 

No other possible sources have been documented on the Jard site.
Ground Water Migration Pathway 

Overburden Aquifer - General

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3.0 GROUND WATER MIGRATION PATHWAY

3.0.1 GENERAL CONSIDERATIONS

Ground Water Migration Pathway Description

The ground water migration pathway discussed in this documentation record features the generally east to west 

flow of PCB-contaminated ground water within the glacio-fluvial/glacio-lacustrine overburden aquifer beneath 

and downgradient of the Jard property. Overburden ground water monitoring wells installed on and around the 

Jard site indicate an aquifer comprised of glacial deposits (see below). Investigations on the Jard property and 

locations west of the property have documented the release of PCBs from sources to ground water and to surface 

water, impacting a downgradient private drinking water supply well and wetland frontage. 

The Jard site is located in the Hudson-Hoosic River Watershed located between the Walloomsac River and 

Furnace Brook (see Figures 1 and 2) [101]. Surface topography in the vicinity of the Jard site is slight, and slopes 

down to the west-northwest from the Jard property to Park Street and then to Route 7 (see Figure 1) [3; 65, pp. 51, 

54-55]. Regional surface topography increases steeply to the east and southwest of the Jard property, and 

moderately to the northwest and north [3; 96]. Investigations of the local overburden aquifer, indicate ground 

water from the Jard property generally flows to the northwest, parallel to the Roaring Branch of the Walloomsac 

River [54, pp. 2, 23-24; 65, pp. 28, 44, 57-58; 67, pp. 1, 5, 1 1; 68, pp. 3, 7, 19-20]. Investigations have further 

noted that the Roaring Branch of the Walloomsac River has been classified as a losing stream with temporal and 

locational exceptions [65, pp. 28, 35] . Ground water to surface water flow has also been documented 

downgradient of the Jard property based on piezometric data and field observations (see Surface Water Migration 

Pathway). 

Regional and Site Geology

Bedrock Geology:

The Jard site is located in the Vermont Valley Physiographic subdivision of Vermont, between the Green 

Mountains to the east and the Taconic Mountains to the west [91, p. 18]. The Vermont Valley is a long, narrow 

lowland approximately 1 to 5 miles wide and 85 m iles long, which is underlain by Cambro-Ordovician 

marble, dolomitic marble, quartzite, and phyllite [90, p. 7; 91, p. 22; 92]. The fabric of the topography and 

the rocks is generally north-south [91, p. 21]. 

The most conspicuous topographic feature in the Bennington area is the western margin of the Green 

Mountains, which rises abruptly 1,800 f eet from the Vermont Valley to the west [90, p. 9 ]. The Taconic 

Range, which comprises the western margin of the Vermont Valley, also forms an abrupt topographic high 

[90, p. 10]. In general, the topography of the region reflects the structure and lithology of the bedrock, with 

the low valleys underlain by carbonate rocks and the major uplands (Green Mountains and Taconic Range) 

underlain by pre-Cambrian crystalline complex or younger phyllites and schists [90, p. 10]. 

The bedrock geology of the Bennington and Jard site area consists of an unknown thickness of PreCambrian gneisses and schist overlain by approximately 10,000 f eet of younger sediments consisting of 

Lower Cambrian to Middle or Upper Ordovician [90, p. 7] . Bedrock beneath the Jard site area has been 

mapped as the Winooski Dolostone of Middle Cambrian age [92, p. 2]. The Winooski Dolostone is 

described as a well-bedded dolostone weathering beige, cream, buff, with green, red, or gray phyllite, 

siliceous partings, and thin beds of blue-quartz-pebble conglomerate and quartzite [92, p. 3]. Other major 

bedrock units within 1 radial mile of the Jard site include the Upper Cambrian Clarendon Springs Formation 

(calcitic dolostone), Lower Ordovician Shelburne Marble, Lower and Middle Ordovician Bascam 
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Formation, Lower Cambrian Monkton Quartzite, Lower Cambrian Dunham Dolostone, Lower Cambrian 

Cheshire Quartzite, and Neoproterozoic Mettawee Slate Facies (mainly phyllites) [92, pp. 2 -3]. The 

dolostones (rocks that are primarily composed of the carbonate mineral dolomite) underlying the site are 

soluble, and are susceptible to dissolution [31, p. 44; 92, pp. 2-3; 95, p. 1; 105, pp. 2-3; 114, p. 1; 115, p. 1]. 

Dissolution of the dolostones by a weak carbonic acid solution (acidic rainwater) may create a network of 

interconnected karst or karst-like features, including fissures, fractures, conduits or voids, as rainwater [95, p. 1; 

105, p. 2; 114, pp.1-2]. A study conducted in the 1980s on the Morgan Spring, a public drinking water supply 

source located approximately 0.57 miles southeast of the Jard site, concluded that the Morgan Spring sources are 

likely to be of karst or cavernous limestone origin and may have a lateral extent of 3 to 5 square miles [55; 56, pp. 

14-17]. 

Major deformation in southwestern Vermont resulted from thrust faulting and folding during the Taconic 

Orogeny in the Ordovician [90, pp. 7 -8, 12, 36] . The Jard site area is situated between two major thrust 

faults: the Green Mountain Frontal Thrust is located to the west, and a major unnamed thrust is located to 

the east [92, p. 3; 117]. In addition to these two major thrust faults, smaller thrust faults are present in this 

area, and at least one high-angle normal fault is also documented [90, p. 8; 92]. This normal fault occurred 

following the thrusting and folding, and may indicate crustal relaxation or upwarping following orogenic 

activity [90, p. 8]. The thrust faulting in southwestern Vermont is believed to be of two major types: deepseated thrusts extending into the pre-Cambrian basement rocks, and surficial flat-lying thrusts affecting 

only Paleozoic rocks [90, p. 8] . Other major structural features in the area include the North Bennington 

anticline, the West Mountain and Mount Anthony synclines, the Maple Hill thrust and syncline, the North 

Pownal overthrust, the structural and stratigraphic complex of the Pownal Upland, and the Reservoir Brook 

fault [90, pp. 41 -49]. Review of previous investigations conducted in the area of the local overburden 

aquifer, located north and northwest of the Jard property, did not specify the presence of any faults [92, p. 2]. 

Bedrock monitoring wells have not been installed during any investigations conducted in the Jard site area; 

therefore, bedrock types and descriptions were referenced using published bedrock maps and reports, and no 

definitive statement regarding hydraulic connection between the overburden and bedrock aquifers can be made. 

Surficial Geology: 

The general north-south orientation of the topography and rock fabric in the Vermont Valley had a major 

influence on the advancing and retreating ice from both the northeast and northwest [91, p. 21]. Glaciolacustrine sediment is most common in the stream valleys and the lowlands of Vermont [91, p. 33]. Drainage was 

restricted in the Vermont Valley during the final melting of stagnant ice, and as a result many small lakes were 

formed [91, p. 33]. The steep gradients and high velocities of mountain streams carried a wide range of different 

sizes of fragments, including large boulders, into lowland areas (valleys) [91, p. 36]. As further described below, 

this has been documented during boring activities in the overburden deposits in the site area, where a layer of 

cobble, gravel, and sand deposits was found [57; 65, pp. 17-18, 52, 54-55; 88, pp. 145-165; 108, p. 15]. Based on 

interpretation of previous boring logs and field notes taken during the advancement and installation of monitoring 

wells in the site area, it appears that the bedrock is overlain by a basal or lodgement till, followed by glaciolacustrine fine sands, silts, and clay [57; 65, pp. 17 -18; 88, pp. 145 -165]. The glacio-lacustrine sediments are 

overlain by outwash deposits consisting of gravel, cobbles, and boulders with minor amounts of sand [57; 65, pp. 

66-80; 88, pp. 145-165]. 

The earliest glaciation of Vermont (early Wisconsin Stage), known as the Bennington Glacial Stade, was the 

advancement of glacial ice (Bennington Glacier) across the region from the northwest, which covered all of 

Vermont [91, p. 61]. Till deposited by the Bennington Glacier has been identified throughout Vermont, except in 

the northwestern part of the state [91, p. 61]. The Bennington till has been described as dense basal or lodgement 

till which has been overridden by subsequent glaciation except in small areas where it forms surface till [91, p. 
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62]. As the Bennington Glacier retreated from the Bennington area, Lake Bascom (previously Lake Hoosic) 

formed in the Hoosic River Valley [91, pp. 68-69; 94, p. 2]. The lake was damned by ice in the Hudson River 

Valley and drained southward through Massachusetts [91, pp. 68-70]. 

Glaciation during the Shelburne Glacial Stade, which followed the Bennington Glacial Stade, covered all of 

Vermont except for the extreme southern part of the state [91, pp. 56-57]. The Bennington area was, however, 

affected by ice-marginal lakes in the Vermont Valley [91, p. 57]. When the margin of the Shelburne ice stood at 

or near its terminal position in the Bennington area, a large lake (Lake Shaftsbury) developed in essentially the 

same area as that of Lake Bascom [91, pp. 95-97]. Therefore, the Jard site area was occupied by a lake during two 

separate Pleistocene glaciations [91, pp. 56-57, 69, 96]. 

Surficial soils in the vicinity of the Jard property are characterized as Hero gravelly fine sandy loam, 0 to 3% 

slopes [58, p. 563; 93]. The thickness of the surficial soils in the Jard site area ranges from 0 to approximately 4 

feet [65, pp. 66-80; 88, pp. 145-165]. The surficial glacial deposits in the Jard site area are mapped as outwash 

deposits consisting of poorly sorted glacio-fluvial gravel, cobbles, and boulders [94]. Subsurface data obtained 

during boring advancement and monitoring well installation in the Jard site area reveal that the overburden 

thickness is greater than 42 feet, based on the documentation that the deepest boring was advanced 42 feet below 

ground surface (bgs) and bedrock was not encountered at this location [88, pp. 145-165]. 

The outwash deposits in the Jard site area are underlain by glacio-lacustrine bottom sediments [57; 65, pp. 66-80; 

88, pp. 145 -165]. The glacio-lacustrine bottom sediments encountered during boring advancement directly 

underlie the mapped outwash deposits, indicating that the sediments were most likely deposited during the last 

glacial stade during the waning of the Shelburne ice [57]. The outwash deposits, including the soil developed on 

them, range in thickness from 11 to 33 f eet [65, pp. 66-80; 88, p p. 145-165]. The maximum thickness of the 

glacio-lacustrine bottom sediments encountered was 23 f eet in boring EPA-105; however, all of the borings 

except one (EPA-107), advanced by Weston Solutions, Inc., bottomed out in these sediments [57; 88, pp. 145-

165]. Therefore, the maximum thickness could not be determined. The outwash deposits encountered consisted of 

poorly sorted gravel, cobbles, and boulders (white, pink, tan, buff, and black quartzite and metamorphic rock 

fragments), fine-to-coarse sand, and silt [57; 88, pp. 145-165]. The coarse outwash deposits thicken from west to 

east, suggesting a provenance area to the east [57; 118]. The glacio-lacustrine bottom sediments consisted mainly 

of brown and gray silt, brown very fine sand, and brown and gray clay [57, p. 3; 88, pp. 145-165]. The sands and 

silts comprising the glacio-lacustrine bottom deposits are well-sorted and lack any structure such as cross 

laminations [57, p. 3; 88, pp. 145-165]. Basal or lodgement till, consisting of hard, light brown and gray, silt, 

coarse-to-fine gravel, and clay, was found in one boring (EPA-107), in which the fines were plastered on the 

coarser (gravel) fragments [57, p. 3; 88, pp. 145-165]. The till appeared dry when broken, suggesting that in this 

location it may form a confining layer on the bedrock surface [57, p. 3; 116, p. 2]. 

Aquifer Interconnection:

Bedrock monitoring wells were not installed in the Jard site area, and therefore no definitive statement regarding 

hydraulic connection between the overburden and bedrock aquifers can be made. Impacts to the overburden 

aquifer only are presented in this documentation record. The bedrock aquifer is not being scored as part of this 

HRS Documentation Record, and aquifer interconnections have therefore not been investigated further. 

Aquifer Discontinuity: 

Two major thrust faults, the Green Mountain Frontal Thrust and a major unnamed thrust, are located within 

the 4-mile target distance limit (TDL) [92, p. 3; 117]. In addition to these two major thrust faults, smaller 

thrust faults and at least one normal fault are present in this area [90, p. 8; 92]. The fabric of the topography 

and the rocks is generally north-south; however, the thrust faults are oriented northeast-southwest [91, p. 21; 
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92]. Topography and the thickness of the overburden aquifer within the 4-mile TDL varies greatly and may 

present a discontinuity; however, there are no known discontinuities between sources on the Jard property, 

background ground water sample locations, the wetland area west of Park Street, and the private residential supply 

well constructed in the overburden aquifer, and scored as Actual Contamination Targets in this documentation 

record. 

Jard Overburden Aquifer Attributes

Ground water beneath the Jard site, and in the local overburden aquifer, generally flows to the northwest, parallel 

to the Roaring Branch of the Walloomsac River; however, there appears to be evidence of a smaller component of 

direction flow to the southwest, toward the Roaring Branch of the Walloomsac River [65, pp. 28, 44, 57-59; 67, 

pp. 1, 5, 11; 68, pp. 3, 7, 19-20]. Based on interpreted ground water contour maps, and verified by an evaluation 

of ground water elevation data obtained between August 2010 and March 2013, the horizontal hydraulic gradient 

of the ground water in the Jard site area is approximately 0.02 feet/foot and to the northwest [27; 31, pp. 37, 150; 

65, p. 28; 68, p. 3]. Data collected from piezometers indicate that the Roaring Branch of the Walloomsac River 

exhibits characteristics of both a gaining stream and losing stream along various segments of the river; and in one 

location, data collected indicated that the river had gone from a losing reach to a gaining reach over a one-month 

period [31, pp. 22-23, 37, 150; 65, pp. 27-28]. For the time period of the study, piezometric data indicated that 

ground water does not discharge to the Roaring Branch of the Walloomsac River along the reach adjacent to the 

Jard property [31, pp. 22-23, 37, 56, 150; 65, p. 28]. The point at which ground water begins discharging to the 

Roaring Branch of the Walloomsac River has been documented at different locations west of the Jard property 

during various studies [31, pp. 37, 150; 68, pp. 2-3, 8, 19]. Ground water to surface water discharge has been 

documented by piezometer data collected from surface water bodies located northwest of the Jard property (Duck 

Pond and Greene Pond) which indicated that these surface water bodies were gaining [65, pp. 28, 45, 52 54]. 

Evidence of ground water to surface water discharge in this area is further supported by the observation of ground 

water seeps near the base of the slope above Duck Pond and within the wetland area west of Park Street [65, p. 

28; 119]. A second area of ground water to surface water discharge has been identified along surface water 

features northwest of the Jard property, near the Plasan facility along Bowen Road [68, pp. 8, 19]. 

Vertical hydraulic gradients measured in July and August 2010 between four paired wells (couplets) in the Jard 

site area by The Johnson Company were indicative of downward ground water flow (recharge) [65, pp. 28, 54-

55]. Ground water elevation data collected on 27 March 2013 from seven couplet ground water monitoring wells 

showed slight downward (recharge) and upward (discharge) ground water flow [28]. 

Table 12 - Summary of Aquifers Being Evaluated

Aquifer

No. Aquifer Name

Is Aquifer Interconnected with 

Upper Aquifer within 2 miles?

(Y/N/NA)

Is Aquifer

Continuous within

4-mile TDL? (Y/N)

Is Aquifer 

Karst? (Y/N)

1

Jard Local Overburden 

Aquifer N/A Y N
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3.1 LIKELIHOOD OF RELEASE

3.1.1 OBSERVED RELEASE

Aquifer Being Evaluated: Jard Local Overburden Aquifer 

This documentation record presents data from selected background and contaminated overburden ground water 

monitoring wells to document an observed release, via chemical analysis, of PCBs to the Jard Overburden 

Aquifer. This record also documents a release of PCBs above benchmark concentrations to one downgradient 

private drinking water supply well which was closed due to contamination at least partially attributable to the 

sources presented in this documentation record (see below). Based on the results of ground water elevation data 

recorded in April 2012, October 2012, and March 2013, ground water in the overburden generally flows from 

sources on the Jard property toward the northwest, parallel to the Roaring Branch of the Walloomsac River [54, 

pp. 2, 23-24; 67, pp. 1, 5, 11; 68, pp. 3, 7, 19-20]. 

Chemical Analysis – Ground Water 

Numerous studies have included investigations into ground water contamination associated with the Jard 

property. Some of these more recent studies (prior to the 2013 EPA SR) involved ground water sampling 

conducted during the following events: a ground water investigation by Lockheed Martin Technology Services 

Group (Lockheed) on behalf of EPA (May 2000); a Corrective Action Feasibility Investigation (CAFI) 

conducted by Stone Environmental, Inc. (Stone) for VT ANR DEC (December 2005); a Limited Phase II 

Environmental Site Assessment (Phase II ESA) conducted by The Johnson Company on be half of VT ANR 

DEC (December 2010); and two site investigations conducted by The Johnson Company for VT ANR DEC 

(April 2012 and October 2012) [31, pp. 1, 21, 36; 44, p. 1; 65, pp. 1, 21 -22; 67, p. 1; 68, pp. 1 -2]. Analytical 

results of ground water samples collected during these investigations consistently indicated the presence of a 

PCB-contaminated overburden ground water plume trending downgradient from the Jard facility building to the 

northwest [31, pp. 1, 36-37, 152; 44, pp. 2-3, 9; 65, pp. 11-12, 31-32, 34, 60; 67, pp. 1-2, 12; 68, pp. 3, 21-22]. 

The most recent investigation, which included ground water sampling from a large network of ground water 

monitoring wells and which achieved low laboratory analytical detection limits, documented the PCB ground 

water plume to extend approximately 2,000 feet downgradient (northwest) of the apparent primary source area 

near the southern portion of the former facility building [68, pp. 3, 21-22]. Ground water samples from a 

selected number of ground water monitoring and former drinking water supply wells have been presented below 

to document an observed release, via chemical analysis, of PCBs to the Jard Overburden Aquifer and Level I 

targets. 

- Background Concentrations: 

Between 13 and 30 August 2012, as part of an EPA Removal Program Preliminary Assessment/Site 

Investigation (PA/SI) for the Park Street site, New Hampshire Boring, Inc. (NHB) conducted monitoring well 

installation activities at locations north and northwest of the Jard property [88, pp. 1-8, 16, 22]. The Park Street 

PA/SI was conducted to investigate potential impacts, due to contamination associated with the Jard site, to the 

downgradient baseball fields, residential properties, and wetlands [88, p. 2]. As part of the Park Street PA/SI, 

ground water monitoring wells EPA-100 and EPA-107 were installed and screened within the overburden 

aquifer, at locations upgradient/crossgradient of sources on t he Jard property based on g round water flow 

evaluations (see Figure 4) [67, p. 11; 68, pp. 19-20; 88, pp. 3, 7-8, 22, 145-146, 161-162]. 

In December 2010, The Johnson Company completed the Phase II ESA on behalf of VT ANR DEC [65, pp. 1, 

4]. Objectives of the Phase II ESA included evaluating the off-site horizontal extent of PCB transport in ground 

water by installing and sampling “shallow” and “deep” ground water monitoring wells [65, pp. 11-12, 21-22]. 
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On 4 August 2010, The Johnson Company installed ground water monitoring well MW-11 along the northeast 

edge of the Little League property as part of an effort to determine the northerly extent of any off-site PCB 

plume in shallow ground water [65, pp. 21, 52-53, 69]. Ground water monitoring well MW-11 was installed and 

screened within the overburden aquifer, at a location crossgradient of sources on t he Jard property based on 

ground water flow evaluations (see Figure 4) [65, pp. 14, 23, 52-53, 69; 67, p. 11; 68, pp. 19-20]. 

The depths of the screened intervals of the ground water monitoring wells presented below for background 

comparison were determined based on e levation survey data and documentation provided in well 

installation/boring logs [52, pp. 2-3; 53, p. 1; 54, pp. 1-2; 65, pp. 44, 69; 68, p. 7; 88, pp. 146, 162]. 

Table 13 - Background Ground Water Monitoring Well Details

Monitoring 

Well ID

Sample ID Location 

Installation 

Date

Screened 

Interval 

(amsl)

Screened Interval 

Geology References

EPA-100 

GW-01 

North of the Jard 

property and Bowen 

Road. 8/28/2012 

653.33 to 

648.33 

Gravel, cobbles, and 

boulders, and sand, and 

silt.

4, p. 9; 54, pp. 

1-2; 88, pp. 7, 

22, 145-146 

EPA-107 

GW-02 

Northwest of the Jard 

property, on a 

residential property. 8/29/2012 

637.99 to 

627.99 

Gravel, cobbles, and 

boulders, and sand, and 

silt; extending into silt 

and gravel with trace 

clay.

4, p. 8; 10, p. 

167; 54, pp. 1-

2; 88, pp. 7-8, 

22, 161-162 

MW-11 

GW-09 

Northwest of the Jard 

property, along 

northeast edge of 

adjacent property to 

the west containing 

ball fields. 8/4/2010 

665.96 to 

655.96 

Cobbles with gravelly 

sand. 

4, p. 9; 10, pp. 

73, 169; 54, 

pp. 1-2; 65, pp. 

14, 52, 69 

amsl = above mean sea level

On 2 April 2013, as part of the EPA SR, Superfund Technical Assessment and Response Team III (START) 

collected ground water samples GW-01, GW-02, and GW-09 from ground water monitoring wells EPA-100, 

EPA-107, and MW-11, respectively [4, pp. 4, 8-9, 63; 17, pp. 2-4, 14-15]. The three background ground water 

samples were collected in accordance with the EPA-approved February 2013 Site-Specific QAPP using lowflow sampling techniques and following the stabilization of ground water quality parameters [4, pp. 8-9; 9, pp. 

1, 28; 17, pp. 2-4, 14-15]. The three background samples were collected from the screened well intervals which 

were within the overburden aquifer [17, pp. 2-4, 14-15; 65, p. 69; 88, pp. 145-146, 161-162]. The three 

background samples were submitted to a CLP laboratory (Chemtech Consulting Group) for analysis of 

low/medium Aroclor compounds following SOW SOM1.2, and the data were validated at the Tier II level by 

personnel not involved with the ground water sampling event and according to Region I EPA-NE Data 

Validation Functional Guidelines for Evaluating Environmental Analyses and the USEPA CLP National 

Functional Guidelines for Superfund Organic Methods [4, p. 13; 11, p. 2; 74, pp. 1-5, 9-10]. 

Laboratory analytical results of PCBs in ground water samples GW-01, GW-02, and GW-09 indicated nondetect levels (U qualifier) at the sample-adjusted CRQL [1.0 U micrograms per liter (μg/L) for all reported 

Aroclors, including Aroclor 1242, presented below] [74, p. 9-10; 83, pp. 1-2, 7-8, 75-76, 79]. Therefore, an 
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observed release via chemical analysis for PCBs (analyzed as Aroclor 1242) is established when the sample 

measurement equals or exceeds the sample-adjusted CRQL of 1.0 μg/L [1, p. 51589 (Table 2-3)].

Table 14 - Hazardous Substances Associated with Background Ground Water Samples

Monitoring 

Well ID

Sample ID

Sample 

No.

Sample 

Date

Hazardous -

Substance

Concentratio

n 

(μg/L) 

SampleAdjusted 

CRQL 

(μg/L) References 

EPA-100 

GW-01 A4A90 4/2/2013 

PCBs

(Aroclor 1242) 1.0 U 1.0 

4, p. 9; 17, pp. 2-3; 

74, p. 9; 83, pp. 1-2, 

7, 75 

EPA-107 

GW-02 A4A91 4/2/2013 

PCBs

(Aroclor 1242) 1.0 U 1.0 

4, p. 8; 17, p. 4; 74, 

p. 9; 83, pp. 1-2, 7, 

76 

MW-11 

GW-09 A4A98 4/2/2013 

PCBs

(Aroclor 1242) 1.0 U 1.0 

4, p. 9; 17, pp. 14-15; 

74, p. 10; 83, pp. 1-2, 

8, 79 

U = Value is Non-Detected [74, pp. 9-10]. 

CRQL = Contract-Required Quantitation Limit is the substance-specific level that a Contract Laboratory 

Program (CLP) laboratory must be able to routinely and reliably detect. Used here, the CRQL has 

been adjusted per the CLP Scope of Work SOM01.2 and represents a sample-specific quantitation 

limit [1, pp. 51585, 51589; 74; 83] 

Ground water sampling events, including the 2013 EPA SR, have defined a plume of PCB-contaminated ground 

water, within the overburden aquifer, beginning on the Jard property and extending west-northwest toward Park 

Street [10, pp. 59, 70, 167-169, 240-241; 31, pp. 130, 150, 152; 65, pp. 32, 46-48, 60; 67, pp. 3, 6-10, 12; 88, pp. 

10, 22, 47, 84, 1 07]. During these sampling events, the PCB-contaminated ground water plume within the 

cobble/sand overburden aquifer has been bounded to the north, northeast, and west by sampling that has 

indicated non-detect concentrations at the laboratory reporting limit or quantitation limit [10, pp. 59, 70, 167-

169, 240-241; 31, pp. 130, 150, 152; 65, pp. 32, 46-48, 60; 67, pp. 3, 6 -10, 12; 88, pp. 10, 22, 47, 84, 107 ]. In 

addition, PCBs are a group of commercially produced synthetic organic chemicals for which there are no known 

natural sources in the environment [124, pp. 25-26]. As explained later, the potential non-site sources of PCBs 

to the environment around the Jard property have been accounted for; and a release from the Jard facility has 

accounted for the PCB-contaminated ground water (see Attribution portion of the Ground Water Pathway 

Migration section). Therefore, irrespective of appropriate background sample collection, background 

concentrations of PCBs in ground water within the local overburden aquifer are expected to be non-detect at 

laboratory reporting limit or quantitation limit for all samples located outside of the PCB-contaminated ground 

water plume associated with a release for the Jard property. 

- Contaminated Samples: 

In February 1991, Wehran Engineering Corporation (Wehran) completed a Phase II ESA for the Jard facility, 

which was prepared for Laurence Levy, Inc. Trustee and reviewed by VT ANR DEC [36, pp. 1, 9]. Objectives 

of the Phase II ESA included excavating and sampling test pits near known or suspected areas of contamination 

around the Jard facility building, and installing and sampling five ground water monitoring wells adjacent to the 

test pits to provide initial data on the extent of ground water contamination and to define ground water flow 

direction in the area [36, pp. 9-10, 15-20]. These ground water monitoring wells included MW-WE-3 and MW-
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WE-6, which were installed by Clean Harbors, Inc. on 17 September 1990 [36, pp. 19, 41, 43]. Note that these 

wells are referred to as MW-3 and MW-6 elsewhere in the Phase II ESA report and in subsequent reports, and 

are therefore referred to as MW-3 and MW-6 within this documentation record [36, p. 21; 65, p. 14]. Ground 

water monitoring wells MW-3 and MW-6 were screened in the overburden at depths between 2.5 and 8.5 feet 

bgs and 6.8 and 11.8 feet bgs, respectively [36, pp. 19-20, 41, 43]. Lithologic descriptions were not recorded 

specifically for the wells, but were presented in data logs for the adjacent test pits [36, p. 19]. According to the 

Phase II ESA report, the surficial soils encountered at each well consisted of sand, gravel, and occasional 

cobbles and boulders [36, p. 19]. The material encountered in the test pit adjacent to MW-3 (Test Pit 3) was 

described down to 3.5 f eet bgs as some fill overlying sand and cobbles [36, pp. 17, 19, 34] . The material 

encountered in the test pit adjacent to MW-6 (Test Pit 6) was described down to 8 feet bgs as fill, sand and 

gravel, with boulders [36, pp. 17, 19-20, 37]. Because the data logs for the test pits adjacent to monitoring wells 

MW-3 and MW-6 do not fully characterize the entire depth intervals of the monitoring wells, monitoring well 

installation/boring logs from adjacent wells MW-3D and MW-6D (discussed below) have also been presented 

for characterization purposes and to document monitoring well completion within the overburden aquifer. 

Between 29 July and 5 August 2010, as part of the Phase II ESA completed by The Johnson Company on behalf 

of VT ANR DEC, ground water monitoring wells MW-3D, MW-6D, and MW-9D were installed on and 

downgradient of the Jard property to evaluate the potential presence of dense non-aqueous phase liquids 

(DNAPLs) in ground water [65, pp. 14, 22, 52]. Monitoring wells MW-3D and MW-6D were installed on the 

Jard property and paired with the existing monitoring wells MW-3 and MW-6 installed by Wehran [36, pp. 19-

21; 65, pp. 14, 20]. Monitoring wells MW-3D and MW-6D were installed adjacent to wells MW-3 and MW-6 

based on G PS data collected as part of the 2013 EPA SR [10, pp. 73, 167 -168]. MW-9D was installed 

downgradient of the Jard property, along the western edge of the Little League property, to investigate the 

presence of DNAPLs and to determine if a confining layer exists that may interrupt their downward migration 

[65, pp. 14, 20 ]. Ground water monitoring wells MW-3D, MW-6D, and MW-9D were installed and screened 

within the overburden aquifer [65, pp. 23-24, 72, 74, 78]. 

Based on ground water flow evaluations, ground water monitoring wells MW-3, MW-3D, MW-6, and MW-9D 

are located downgradient of source areas on the Jard property (see Figure 4) [67, pp. 1, 5, 11; 68, pp. 3, 19-20]. 

The seven wells (EPA-100, EPA-107, MW-11, MW-3, MW-3D, MW-6, and MW-9D) presented for 

background and contaminated (release) samples were all installed for the same usage (ground water monitoring 

wells), and with similar well constructions [e.g., 2-inch-diameter polyvinyl chloride (PVC) pipe with number 

10-slotted (0.010-inch) 5- or 10-foot screens, surrounded by filter sand, and finished with bentonite, cement, and 

grout) [36, pp. 19-20, 41, 43; 65, pp. 23-24, 69, 72, 78; 88, pp. 145-146, 161-162]. The background and release 

wells were all screened at similar depths [between approximately 2.5 and 32 feet bgs [681.05 to 627.99 above 

mean sea level (msl)], and within similar overburden materials (generally cobbles, gravel, and sand) within the 

Jard Overburden Aquifer [36, pp. 41, 43; 54, pp. 1-2; 65, pp. 69, 72, 78; 88, pp. 145-146, 161-162]. 

 

The depths of the screened intervals presented below for contaminated ground water monitoring wells were 

determined based on elevation survey data and documentation provided in well installation/boring logs [36, pp. 

41, 43; 53, p. 1; 54, pp. 1-2; 65, pp. 44, 54, 72, 78; 68, p. 7]. 
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Table 15 - Contaminated Ground Water Monitoring Well Details 

Monitoring 

Well ID

Sample ID Location 

Installation 

Date

Screened 

Interval 

(amsl)

Screened 

Interval 

Geology References

MW-3 

GW-04 

Immediately south of the 

southern edge of the former 

building footprint on the Jard 

property. 9/17/1990 

681.05 to 

675.05 

Cobbles, some 

sand and gravel, 

little boulders 

and gravel (fill). 1

4, p. 10; 36, 

pp. 16, 19, 

34, 41; 54, 

pp. 1-2 

MW-3D 

GW-05 

Immediately south of the 

southern edge of the former 

building footprint on the Jard 

property. 8/2/2010 

660.55 to 

655.55 

Sand, cobbles 

with sand. 

4, p. 10; 65, 

pp. 14, 23, 

52, 72; 54, 

pp. 1-2 

MW-6 

GW-06 

Immediately west of the 

western edge of the former 

building footprint on the Jard 

property. 9/17/1990 

673.34 to 

668.34 

Sand, some 

gravel, boulders, 

and cobbles, little 

silt. 2

4, p. 10; 36, 

pp. 16, 19-

20, 37, 43; 

54, pp. 1-2 

MW-9D 

GW-08 

Western edge of the Little 

League property, west of the 

Jard property. 8/5/2010 

647.62 to 

642.62 Sand, cobbles. 

4, p. 9; 54, 

pp. 1-2; 65, 

pp. 14, 24, 

52, 78 

amsl = above mean sea level.

1 The description provided is based on adjacent Test Pit 3, which only characterized part of the depth interval in 

which MW-3 was screened. Characterization of the approximate depth interval in which MW-3 was screened 

was logged for monitoring well MW-3D, which was installed to be collocated with MW-3, and was generally 

described as cobbles, with a thin layer of sand [65, pp. 14, 22, 54, 72]. 

2 The description provided is based on adjacent Test Pit 6, which only characterized part of the depth interval in 

which MW-6 was screened. Characterization of the approximate depth interval in which MW-6 was screened 

was logged for monitoring well MW-6D, which was installed to be collocated with MW-6, and was generally 

described as rock and gravelly sand [65, pp. 14, 22, 54, 74]. 

On 2 April 2013, as part of the EPA SR, the following ground water samples were collected (monitoring well 

location in parentheses): GW-04 (MW-3), GW-05 (MW-3D), GW-06 (MW-6), and GW-08 (MW-9D) [4, pp. 9-

10; 17, pp. 6-9, 12-13]. These four contaminated ground water samples were collected during the same sampling 

event and on the same day as the three samples presented above for background comparison [4, pp. 8-10]. In 

accordance with the EPA-approved Site-Specific QAPP, the four contaminated ground water samples were 

collected using similar ground water sampling equipment (bladder pumps or peristaltic pumps) and 

methodologies (i.e. using low-flow sampling techniques and following the stabilization of ground water quality 

parameters) as the background samples [9, p. 28; 17, pp. 2 -4, 6-9, 12-15]. The contaminated ground water 

samples, along with the background samples, were collected from the screened well intervals which were within 

the overburden aquifer [17, pp. 2-4, 6-9, 12-15; 36, pp. 34, 37, 41, 43; 65, pp. 69, 72, 78; 88, pp. 145-146, 161-

162]. Like the background samples, the four contaminated ground water samples were submitted to a C LP 

laboratory (Chemtech Consulting Group) for analysis of low/medium Aroclor compounds following SOW 

SOM1.2, and the analytical data were validated at the Tier II level by personnel not involved with the ground 

water sampling event according to Region I EPA-NE Data Validation Functional Guidelines for Evaluating 

Environmental Analyses and the USEPA CLP National Functional Guidelines for Superfund Organic Methods 

[4, p. 13; 11, pp. 1-2; 17, pp. 6-9, 12-13; 74, pp. 1-5, 9-10]. 
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PCBs (analyzed as Aroclor 1242) were detected in ground water samples GW-04, GW-05, GW-06, and GW-08 

at concentrations above each sample-adjusted CRQL, and above the background concentration established by 

analytical results of background samples GW-01, GW-02, and GW-09; thereby establishing, via chemical 

analysis, an observed release of PCBs (analyzed as Aroclor 1242) to ground water [1, p. 51589 (Table 2-3); 74, 

pp. 9-10; 83, pp. 1-2, 7-8, 75-76, 78-79, 82-87].

Table 16 –Hazardous Substances Associated with Contaminated Ground Water Samples 

Monitoring 

Well ID

Sample ID

Sample 

No.

Sample 

Date

Hazardous 

Substance

Concentration 

(μg/L) 

SampleAdjusted 

CRQL 

(μg/L) References 

MW-3 

GW-04 A4A93 4/2/2013 

PCBs

(Aroclor 1242) 93* 20** 

17, p. 6; 74, p. 9; 

83, pp. 1-2, 7, 82-

83 

MW-3D 

GW-05 A4A94 4/2/2013 

PCBs

(Aroclor 1242) 180* 20** 

17, pp. 7-8; 74, p. 9; 

83, pp. 1-2, 7, 84-

85 

MW-6 

GW-06 A4A95 4/2/2013 

PCBs

(Aroclor 1242) 98* 20** 

17, p. 9; 74, p. 9; 

83, pp. 1-2, 7, 86-

87 

MW-9D 

GW-08 A4A97 4/2/2013 

PCBs

(Aroclor 1242) 9.0 1.0 

17, pp. 12-13; 74, p. 

10; 83, pp. 1-2, 8, 

78 

* = Reported value is from diluted analysis [74, p. 9]. 

** = Reported value is from diluted analysis [83, p. 7]. 

CRQL = Contract-Required Quantitation Limit is the substance-specific level that a Contract Laboratory 

Program (CLP) laboratory must be able to routinely and reliably detect. Used here, the CRQL has 

been adjusted per the CLP Scope of Work SOM01.2 and represents a sample specific-quantitation 

limit [1, pp. 51585, 51589; 74; 83]. 

Chemical Analysis – Drinking Water

Several residential properties along Park Street, located west of documented sources on the Jard property, 

contained active or formerly used private drinking water supply wells during ground water investigations 

conducted by VT ANR DEC and The Johnson Company in 2010 and 2012 [51, pp. 2, 16; 32, p. 1; 65, pp. 21-

22]. Based on evaluations of ground water elevation data obtained from nearby ground water monitoring wells 

in the area, many of the residential properties along Park Street are located downgradient of source areas on the 

Jard site [67, pp. 1, 5, 11; 68, pp. 3, 19-20]. Based on chemical analysis of drinking water samples collected on 

behalf of VT ANR DEC from residential supply wells, PCB concentrations exceeding drinking water 

benchmarks have been documented in an active residential drinking water supply well, resulting in the closure 

of the well (see below).

- Background Concentrations: 

As noted earlier, background concentrations of PCBs in ground water within the local overburden aquifer are 

expected to be non-detect at laboratory reporting limit or quantitation limit for all samples located outside of the 

PCB-contaminated ground water plume (see Chemical Analysis – Ground Water Samples section). Previous 
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VTD048141741

ground water samples, from the local overburden aquifer located north and northwest of the Jard property, 

indicate non-detect concentrations of site-related hazardous substances [10, pp. 59, 70, 167-169, 240-241; 31, 

pp. 130, 150, 152; 65, pp. 32, 46-48, 60; 67, pp. 3, 6-10, 12; 88, pp. 10, 22, 47, 84, 107]. Former drinking water 

supply wells located west of the Jard property are completed within the overburden aquifer based on 

observations by field personnel [4, p. 27; 65, pp. 21-24; 120, pp. 1, 4]. Contaminated drinking water samples 

presented below were collected within the PCB-contaminated local overburden ground water plume [65, p. 60]. 

- Contaminated Samples 

Based on information provided in The Johnson Company Phase II ESA report and by VT ANR DEC, a 

residential property along Park Street (referred to as property P009) was served by a private drinking water 

supply well during September 2010 [9, p. 32; 65, pp. 21-23, 61; 89, p. 1]. According to the Phase II ESA report, 

the well serving the residence at property P009 was located in the basement, and was estimated to be 

approximately 4 feet deep [9, p. 32; 65, pp. 22 -23]. During reconnaissance and sampling events conducted as 

part of the EPA SR, START personnel discussed previous drinking water sampling activities at property P009 

with the VT ANR DEC representative, and observed the drinking water supply well [4, pp. 2-3, 27; 9, p. 32]. On 

9 April 2013, START observed the private drinking water supply well in the basement of the residence to be a 

dug well, constructed with a 2.0-foot-diameter terra cotta pipe extending approximately 3.0 feet below the 

ground surface of the basement and containing a gravel base [4, p. 27]. 

During the Phase II ESA, a property owner at another residential property along Park Street (referred to as 

property P011) informed The Johnson Company of an unused shallow well in the basement of the residence [9, 

p. 32; 65, pp. 21-22]. This well was a dug well constructed of stone, and was approximately 3 feet in diameter 

and 6.5 feet deep (presumably below the basement surface) [65, p. 22]. 

Based on evaluations of ground water elevation data collected from monitoring wells in the area, the private 

drinking water wells at residential properties P009 and P011 are located downgradient of source areas on the 

Jard property [9, p. 32; 67, pp. 1-2, 5, 11; 68, pp. 3, 19-20]. 

The two wells (at properties P009and P011 along Park Street) presented for contaminated samples were all 

installed for the same usage (i.e., private drinking water supply wells, although the well at property P011 was 

not in use at the time of sampling) [9, p. 32; 32, p. 1; 35, p. 2; 65, pp. 22 -23]. The three wells exhibit similar 

well constructions (i.e., shallow dug wells to depths ranging from 3 to 6.5 feet below the basement surfaces), 

and all draw from the Jard Overburden Aquifer [4, p. 27; 65, pp. 21-23; 120, p. 4]. 

Table 17 - Contaminated Private Drinking Water Supply Well Details

Monitoring Well 

ID

Sample ID Location 

Installation 

Date Well Construction References

Private Well

“Watson”

Basement of residential 

property P009 along Park 

Street. Unknown 

Well dug to approximately 

3 to 4 feet. 

4, p. 27; 9, p. 

32; 65, pp. 21-

23 

Private Well*

“Greene Well”

Basement of residential 

property P011 along Park 

Street. Unknown 

Well dug to approximately 

6.5 feet. 

9, p. 32; 65, pp. 

21-22 

* Note that this well is a former drinking water supply well which was not in use at the time of the investigations 

[35, p. 2; 65, pp. 21-22]. This well is presented to show evidence of additional contamination in the area at the 

time of the investigation of the well at property P009. 
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On 30 A ugust 2010, The Johnson Company, in consultation with VT ANR DEC, collected a ground water 

sample (“Greene Well”) from the dug well in the basement of the residence at property P011 [9, p. 32; 65, p. 

27]. The sample was collected using low-flow procedures [65, pp. 26-27, 223]. On 20 S eptember 2010, VT 

ANR DEC collected a d rinking water sample (“Watson”) from an active drinking water supply well at the 

residential property referred to as P009 [9, p. 32; 65, pp. 22-23, 27, 61, 175; 89, p. 1]. The sample “Watson” was 

collected from a spigot located before the pressure tank in the plumbing system, with an upstairs tap running for 

10 minutes prior to sample collection [65, p. 27]. Drinking water sample “Watson” and ground water sample 

“Greene Well” were submitted to Eastern Analytical Inc. laboratory for PCB analysis according to EPA Method 

8082 [32, p. 7; 65, pp. 113, 244]. 

PCBs (analyzed as Aroclor 1016) were detected in drinking water sample “Watson” and ground water sample 

“Greene Well” at concentrations above their respective reporting limits, and above the background 

concentration established by analytical results of background sample “Peck Pre-Connection” [32, pp. 1-4; 65, 

pp. 100, 105, 112, 170, 172, 174]. Therefore, the concentration of PCBs in drinking water sample “Watson”, 

which was collected from an active drinking water supply well, meets the criteria for observed release and 

documentation of actual contamination [1, pp. 51589 (Table 2-3), 51592 (Section 2.5)]. As discussed below, 

PCBs (analyzed as Aroclor 1016 and Aroclor 1242) were used at the Jard property for similar processes as part 

of historical operations, and these two Aroclor compounds are very similar in chemical composition and 

chromatographic expression (see Attribution section below). In addition, an observed release to ground water 

monitoring and drinking water supply wells in the vicinity of the Jard property should be interpreted in the 

context of known Aroclors used at the facility, namely Aroclors 1016 and 1242 [65, pp. 29-30]. 

Table 18 –Hazardous Substances Associated with Current and Former Drinking Water Supplies

Monitoring 

Well ID

Sample ID

Sample 

Date

Hazardous 

Substance

Concentration 

(μg/L) 

Reporting 

Limit

(μg/L) References

Private Well

“Watson” 9/20/2010 

PCBs

(Aroclor 1016) 1.8 0.3 65, pp. 172-174 

Private Well

“Greene Well”* 8/30/2010 

PCBs

(Aroclor 1016) 1.3 0.5 

65, pp. 100-101, 

105, 112 

Reporting Limit = Reporting Limit record from Analytical Laboratory Report [65, 170-175] 

* Note that this sample was collected from a former residential drinking water supply well which was not in use 

at the time of sample collection [35, p. 2 ; 65, pp. 21-22]. This sample is presented to show evidence of 

additional observed release contamination in the area during the same time frame as t he collection of the 

“Watson” sample.

Attribution:

The hazardous substances (PCBs) used to establish an observed release are associated with the Jard site, and the 

site has contributed at least in part to the significant increase in hazardous substance concentrations, as described 

below. Other possible sources of the observed release hazardous substances were investigated through review of 

file information and observations made during field activities (see Other Possible Sites section below).

Jard operated on the property from 1969 to 1989, producing zinc-coated capacitors (containing approximately 

75 pounds of dielectric fluid), small non-fluid transformers, and small motors used in household appliances [20, 

p. 1; 23, pp. 1-2; 24, p. 5; 25, p. 1; 26, p. 2; 31, pp. 5, 8]. According to file information, the manufacture of the 

PCB-containing oil-filled capacitors was conducted on the Jard property [23, pp. 1-2; 25, p. 4]. According to a 
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summary of PCBs in Vermont prepared by the Agency of Environmental Conservation Department of Water 

Resources Water Quality Division in April 1976, at the time Jard was the only known PCB user in Vermont [21, 

pp. 1-2]. Jard received an average of 686,500 pounds of PCBs per year (1971-1974 average) [20, p. 5]. From 

1969 to 1971, PCB Aroclor 1242 was used as an impregnating fluid, but by 1971 Jard replaced Aroclor 1242 

with Aroclor 1016 [20, p. 5; 21, p. 2]. The Aroclors used at the Jard property constituted a marketed mixture of 

PCBs, which were manufactured and are not naturally occurring [123, p. 4; 124, pp. 467-468]. Aroclor 1016, 

which exhibits similar chemical properties and chlorine content as Aroclor 1242, was produced from a vacuum 

distillation of Aroclor 1242 and was used in similar capacitor applications [65, p. 30; 123, pp. 10, 18; 124, pp. 

469, 477]. By 1978 a nd until operations ceased, DOP, which replaced the use of PCBs, was used as an 

impregnating fluid for the capacitors and transformers at Jard [29, p. 10]. 

As part of the manufacturing process, Jard used non-contact cooling water which was discharged to a UST and a 

perforated concrete drywell south of the facility building [21, p. 2; 29, pp. 7-9; 31, pp. 47, 135; 37, p. 3; 39, pp. 

15, 29, 32; 50, p. 1]. Floor drains from inside the building also discharged into the UST [50, p. 1]. Process area 

trench drains, which were observed to discharge directly into the soils beneath the foundation, contained 

elevated concentrations of PCBs during an investigation of the facility [31, pp. 31, 52; 39, pp. 15-16, 26, 32, 36]. 

A subsequent interview with a former employee indicated that during the non-contact cooling, gasket failures 

would cause the cooling waters and PCB-oils to come into contact [4, p. 27]. These cooling waters would be 

discharged to the drywell system [4, p. 27]. In addition, analytical results of the contents of an approximately 

1,700-gallon tank outside the southern portion of the facility building investigated during an EPA Removal 

Action indicated PCB concentrations of 47 parts per million (ppm) [39, pp. 14-17, 29, 32-33, 36, 56]. 

Beginning with a routine industrial waste survey in October 1979, numerous inspections and investigations have 

taken place at the Jard property which have indicated PCB contamination in soils and ground water adjacent to 

and beneath the former facility building [10, pp. 72-73, 215-219, 233-241; 23, pp. 1-3; 24, pp. 4-24; 25, pp. 2-

22; 26, pp. 1-6; 29, pp. 3-28; 30, pp. 1-37, 64-152; 31, pp. 5-58, 111-154; 33, pp. 1-2; 36, pp. 4-30; 39, pp. 20-

66; 40, pp. 2-5; 41, pp. 1-4; 44, pp. 1-9; 46, pp. 11-17, 21-26, 41-42; 59, pp. 1-3; 60, pp. 1-90; 62, pp. 24, 84-85; 

65, pp. 9-61; 67, pp. 2-12; 68, pp. 3-4, 9-22]. To address some of the identified contamination, several EPA 

Removal Actions have been conducted at the Jard property to secure chemicals used in the manufacturing 

process which were left after the facility closed, conduct limited excavation of contaminated soils, demolish the 

facility building, remove a portion of the concrete foundation, and cap/secure PCB-contaminated soils to limit 

public exposure [37, pp. 7-8; 39, pp. 7-9; 42; 43; 62]. Following the 2007 EPA Removal Action, which was the 

last removal action conducted at the Jard property, additional site investigations have documented the continued 

presence of PCB Aroclors in site soils and ground water [10, p. 72-73, 215-219, 233-241; 31, pp. 7-36, 112-154; 

62, pp. 24, 83-85]. 

Recent investigations by The Johnson Company, conducted for Vermont ANR DEC, have indicated the 

presence of Aroclors (Aroclor 1016, Aroclor 1221, Aroclor 1232, a nd Aroclor 1242) in ground water both 

beneath and downgradient of the Jard property [65, pp. 46-48, 52; 68, pp. 9-16, 21]. The Johnson Company 

noted that the congener profile of PCBs in the environment may be modified by various weathering processes 

[65, p. 30]. Weathering may alter the chromatographic pattern of the Aroclor, making identification difficult and 

resulting in differing interpretations among laboratories and analysts; therefore, analytical results should be 

interpreted in the context of known Aroclors used at the Jard property (Aroclor 1016 and Aroclor 1242) [65, p. 

30]. In addition, surficial soil conditions may cause heavier components of the Aroclor to adsorb to the soil 

while lighter components continue to travel within the ground water [65, pp. 30-31; 123, pp. 12, 14 -15]. The 

Johnson Company concluded that even in the absence of severe weathering, it can be difficult to distinguish 

between Aroclors and as a result, different laboratories or analysts may not agree on the determination of the 

assumed Aroclor mix used in the quantification of the PCB concentration in the sample analysis; therefore, 

laboratory PCB results of environmental samples should be interpreted in the context of the known PCB use at 

the Jard property over its history, which consists of Aroclor 1242 and Aroclor 1016[65, p. 30].
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Based on the results of ground water elevation data recorded in April 2012, October 2012, and March 2013, 

ground water in the overburden generally flows from the Jard property toward the northwest [54, pp. 2, 23-24; 

67, pp. 1, 5, 11; 68, pp. 3 , 19-20]. Ground water flow has been documented to be generally parallel to the 

Roaring Branch of the Walloomsac River, and piezometric data have indicated that ground water does not 

discharge to the Walloomsac River along the reach adjacent to the Jard property [31, pp. 22-23, 37, 56; 65, p. 

28]. Analytical results of ground water samples collected as part of numerous previous investigations 

consistently indicated that in general, the highest concentrations of PCB contamination were detected in 

overburden ground water samples collected in close proximity to the Jard facility building, with lower 

concentrations detected downgradient (west and northwest) of the building, and relatively very low to nondetect levels of PCBs detected in wells upgradient (east and north) of the building [31, pp. 1, 36-37, 152; 44, pp. 

2-3, 9; 65, pp. 12, 31-32, 34, 60; 67, pp. 1-2, 12; 68, pp. 3-4, 21-22]. In addition, PCB contamination has not 

been detected above laboratory reporting limits in samples collected from piezometers installed at locations 

south of sources on the Jard property along the Roaring Branch of the Walloomsac River [31, pp. 23, 130, 152; 

65, pp. 21-22, 48, 60]. Therefore, the plume of PCB contamination in the overburden ground water aquifer has 

generally been documented to originate on the Jard property, to be approximately 500 feet in width, and extend 

to approximately 2,000 feet downgradient (to the northwest), bounded to the south by ground water monitoring 

wells and the Roaring Branch of the Walloomsac River, and to the north by ground water monitoring wells on 

the northern portions of the property adjacent/west of the Jard property (P031) and Bowen Road [10, pp. 70-71; 

65, pp. 32, 34, 60 ; 67, pp. 2, 12; 68, pp. 3, 2 1-22]. Based on ground water analytical sample results indicating 

detectable levels of PCBs, the impacted ground water plume extends at least as far west as monitoring wells 

EPA-104S and EPA-104D; no known ground water samples have been collected from monitoring wells beyond 

this point [68, pp. 9, 21-22]. 

The documented trends exhibited by the overburden ground water contamination plume have been interpreted 

during previous investigations to be indicative of a source of PCBs located south of the former facility building, 

potentially associated with the former storage of PCB oil product in tanks in this area, releases from floor trench 

drains to subsurface soils, and releases to facility drywells [31, pp. 51-52, 135; 39, pp. 14-17, 32-33, 36, 56]. 

Recent analytical sampling results have confirmed the ongoing presence of significant levels of PCBs within 

contaminated soil and pile sources, available to the ground water pathway due to the lack of containment 

features associated with the sources, which supports at least partial attribution of the hazardous substances to 

releases from the site (see Source Evaluation section) [1, p. 51588, Section 2.2.2]. 

Some investigations have noted one apparent anomaly to the documented PCB ground water plume, located 

northwest and cross-gradient of sources on the Jard property and based on slightly elevated concentrations of 

PCBs in a ground water monitoring well (MW-12) west of the Plasan facility (formerly US Tsubaki) [65, pp. 25, 

47, 60; 67, pp. 9, 12; 68, pp. 14, 21]. However, the levels of PCBs detected in ground water samples collected 

from monitoring well MW-12 during various investigations have consistently been lower than concentrations 

detected in other ground water monitoring wells located within the documented plume; most significantly, PCB 

concentrations detected in MW-12 have been at least 2 to 3 orders of magnitude lower than concentrations 

detected in well MW-3, located immediately south of the former facility building footprint [65, pp. 46-47; 67, 

pp. 7-9, 12; 68, pp. 3-4, 14, 21]. In addition, previous investigations of the US Tsubaki facility have indicated 

that PCBs were not used as part of operations and have not been detected in ground water and soil samples 

collected from the property (see Other Possible Sites section below) [109, pp. 47, 183 -190; 110, pp. 8-9]. 

Current operations at the Plasan facility (adjacent to monitoring well MW-12) include the manufacture of body 

armor and armored vehicles for civilian and military personnel [125]. The Plasan facility has not been identified 

via Resource Conservation and Recovery Information System (RCRIS) or Comprehensive Environmental 

Response, Compensation, and Liability Information System (CERCLIS) searches to be involved in the storage 

or use of PCBs [113, pp. 38-39]. 
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Other Possible Sites: 

A review of the EPA CERCLIS and RCRIS databases identified seven CERCLIS and 142 R esource 

Conservation and Recovery Act (RCRA) sites in Bennington, VT, including the Jard site [113]. The seven sites 

identified in the CERCLIS database search include the Kocher Drive Dump and Park Street sites located north 

of the Roaring Branch of the Walloomsac River and within 0.73 miles the Jard site [113, pp. 1-5]. Activities at 

the Park Street site, located downgradient of the Jard property, have included assessment and removal of PCB 

contamination from the Jard property sources [61, p. 4; 66, p. 2; 88, p. 2]. A search of the VT ANR DEC Waste 

Management Hazardous Site List was performed for the Town of Bennington and within one radial mile of the 

Jard site, to identify sites with similar operational activities, or with manifests for substances similar to or the 

same as the contaminants of concern at the Jard property [104]. The search listed a total of 158 site locations 

within Bennington [104]. Of the 158 sites, two sites were identified within one radial mile, and as where PCBs 

have been a contaminant of concern [104]. These two sites (Kocher Drive Dump and Vermont Composites), and 

one additional site [US Tsubaki (currently Plasan)] located in close proximity to the Jard property, are 

summarized below. 

Kocher Drive Dump: 

The Kocher Drive Dump site is located approximately 0.6 miles northwest of the Jard property [104]. The site 

operated as a town-owned landfill between 1955 and 1969, and accepted municipal and industrial wastes, 

including battery wastes, electrical oils, capacitors, solvents, dyes, and cellulose nitrate [106, p. 3]. Sampling 

conducted as part of the EPA Removal PA/SI indicated the presence of PCBs in sediments and soils on the 

Kocher Drive Dump property [107, pp. 32-36, 110-124]. However, no PCBs were detected in ground water and 

surface water samples collected as part of the investigation [107, p. 21]. In addition, elevation data from ground 

water monitoring wells between the Kocher Drive Dump site and the Jard site, located on the Vermont 

Composites site, do not support the migration of PCBs from this area to the south-southeast (see Vermont 

Composites summary below). 

Vermont Composites: 

The Vermont Composites site is located approximately 0.45 miles northwest of the Jard property [104]. PCBs 

have been detected in site soils in one sample, at levels below an EPA Regional Screening Level, in an area on 

the northeastern portion of the facility which contained a transformer [108, pp. 12, 21, 28, 36, 39, 80]. As part of 

a Site Investigation, The Johnson Company concluded that the source of the PCB (Aroclor 1254) contamination 

was a m inor release during replacement of the historical transformer, which was unlikely to migrate farther 

(there were no detections in ground water) [108, pp. 12, 28, 36, 39]. Ground water monitoring wells installed on 

the facility indicate that ground water flow direction is to the west, cross-gradient to the Jard site [108, pp. 16, 

38]. 

US Tsubaki:

The former US Tsubaki site is located directly adjacent to (north of) the Jard site and was the former location of 

a sprocket manufacturer [104]. Hazardous waste streams produced on the property included waste hydraulic oil, 

water soluble coolants, metal scraps, filter media, coolant fluid, corrosive wastes, and paint sludge [109, pp. 13-

14]. Based on the Tighe & Bond Phase I Site Assessment Update and Environmental Site Investigation Report, 

soil and ground water sampling on the property has not indicated the presence of PCBs in these media [109, pp. 

47, 183-190; 110, pp. 8-9]. 
Ground Water Migration Pathway 

Overburden Aquifer – Likelihood of Release

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Hazardous Substances Released

PCBs (Aroclors 1242 and 1016) 

Ground Water Observed Release Factor Value: 550 

3.1.2 POTENTIAL TO RELEASE

Potential to Release Factor Value: Not Evaluated
Ground Water Migration Pathway 

Waste Characteristics

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3.2 WASTE CHARACTERISTICS

3.2.1 TOXICITY/MOBILITY

Table 19 - Toxicity/Mobility Factor Value

Hazardous 

Substance

Source No. 

(and/or 

Observed 

Release)

Toxicity 

Factor 

Value

Mobility 

Factor 

Value

Does Haz. Substance 

Meet Observed Release 

by Chemical Analysis? 

(Y/N)

Toxicity/

Mobility 

(Ref. 1, 

Table 3-9) References

PCBs 1, 2 10,000 1* Y 10,000 

1, pp. 51601 

(Section 3.2.1.2), 

51602 (Table 3-9); 

2, p. A-296 

* For any hazardous substance that meets the criteria for an observed release by chemical analysis to one 

or more aquifers underlying the sources at the site, regardless of the aquifer being evaluated, assign a 

mobility factor value of 1 [1, p. 51601 (Section 3.2.1.2)]. 

Toxicity/Mobility Factor Value [1, p. 51602 (Table 3-9)]: 10,000 

3.2.2 HAZARDOUS WASTE QUANTITY

Table 20 - Hazardous Waste Quantity

Source No. Source Type

Source Hazardous 

Waste Quantity 

Source Hazardous Constituent 

Quantity Complete? 

1 Contaminated Soil 3.14 N 

2 Pile 13,300 N 

Sum of Values: 13,303 

Based on HRS Section 2.4.2.2, if the Hazardous Constituent Quantity is not adequately determined for one or 

more sources, and if any target for the ground water pathway is subject to Level I or Level II concentrations, a 

factor value is assigned from Table 2-6 or a value of 100, whichever is greater, as the Hazardous Waste Quantity 

Factor Value for that pathway [1, pp. 51591-51592 (Section 2.4.2.2)]. 

Hazardous Waste Quantity Factor Value [1, p. 51591 (Table 2-6)]: 10,000 

3.2.3 WASTE CHARACTERISTICS FACTOR CATEGORY VALUE

The Toxicity Factor Value (10,000) and the Mobility Factor Value (1.0) for PCBs are multiplied in order to 

determine the Toxicity/Mobility Factor Value (10,000) [1, p. 51602 (Section 3.2.1.3, Table 3-9)]. The

Toxicity/Mobility Factor Value is multiplied by the Hazardous Waste Quantity Factor Value to determine the 

Waste Characteristics Factor Category Value, subject to a maximum value of 1 × 108 [1, pp. 51592 ( Section 

2.4.3.1), 51602 (Section 3.2.3)]. Based on this Waste Characteristic product, a Waste Characteristic Factor 

Category Value of 100 is assigned [1, p. 51592 (Table 2-7)].
Ground Water Migration Pathway 

Targets

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Toxicity/Mobility Factor Value: 10,000

Hazardous Waste Quantity Factor Value: 10,000 

Toxicity/Mobility Factor Value × Hazardous Waste Quantity Factor Value: 1 × 108 

Waste Characteristics Factor Category Value [1, p. 51592 (Table 2-7)]: 100 

3.3 TARGETS

Level I Concentrations 

Based on chemical analysis, PCBs (analyzed as Aroclor 1016) were detected in a private residential drinking 

water supply well at a concentration meeting the criteria for actual contamination and exceeding the EPA 

Maximum Contaminant Level (MCL), thereby establishing a Level I concentration [1, pp. 51592-51593 

(Sections 2.5, 2.5.1, 2.5.2)]. 

Table 21 - Level I Concentrations

Sample 

ID

Hazardous 

Substance

Hazardous Substance 

Concentration (μg/L) 

Benchmark 

Concentration (μg/L) Benchmark

References for 

Benchmark

Watson

Aroclor 1016

(PCBs) 1.8 0.5 MCL

2, p. A-296; 65, 

p. 48 

PCBs (analyzed as Aroclor 1016) were detected above the MCL in a drinking water source supplying four 

residents [121]. The sample was collected on 20 S eptember 2010 [ 65, pp. 22 -23, 27, 61; 89, p. 1] . On 28 

September 2010, due to the levels of contamination exceeding the MCL and State action levels, VT ANR DEC 

recommended to the residents to discontinue drinking water supplied by the private drinking water well, and the 

well was reportedly abandoned [4, p. 27; 122]. Between 28 and 29 October 2010, due to the documented levels 

of PCB contamination, the impacted residential property was connected to the municipal water supply in 

Bennington, VT [4, pp. 2-3; 38, p. 1; 122]. 

3.3.1 NEAREST WELL

Due to a documented drinking water supply well subject to Level I concentrations, a Nearest Well Factor Value 

of 50 is assigned [1, pp. 51602-51603 (Section 3.3.1)]. The closest drinking water supply well containing Level 

I concentrations of the target compounds (PCBs) is the well located on property P009, located between 828 and 

1,244 feet west-northwest of the sources presented in this HRS Documentation Record (see Figure 4) [48]. 

Well ID: Private residential well at property P009

Level of Contamination (I, II, or potential): I

If potential contamination, distance from source in miles: 

Nearest Well Factor Value [1, p. 51603 (Table 3-11)]: 50 
Ground Water Migration Pathway 

Targets

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3.3.2 POPULATION

3.3.2.1 Level of Contamination

3.3.2.2 Level I Concentrations 

Based on information provided by the resident at P009 to VT ANR DEC, the drinking water supply well 

documented with Level I concentrations served four residents at the time of documented contamination [121].

Previous estimates indicated by VT ANR DEC personnel, of six to seven residents, were revised based on 

information from the residents using the well during its closure [4, p. 27; 121]. 

Level I Population Targets 

Table 22 - Level I Population Targets 

Level I Well Aquifer No. Population References

P009 drinking water supply well 1 4 121 

 Sum of Population Served by Level I Wells: 4 

 Sum of Population Served by Level I Wells x 10: 40 

Level I Concentrations Factor Value [1, p. 51603 (Section 3.3.2.2)]: 40 

3.3.2.3 Level II Concentrations 

Level II Population Targets 

No Level II Population Targets have been identified. 

Level II Concentrations Factor Value 1, p. 51603 (Section 3.3.2.3)]: 0 

3.3.2.4 Potential Contamination

Potential Population Targets

The potential population relying on ground water supply sources within 4 radial miles of sources on the Jard 

property was evaluated but not scored as part of this HRS Documentation Record [56]. 

Potential Contamination Factor Value: Not Scored

3.3.3 RESOURCES

No Resources were evaluated as part of this HRS Documentation Record.

Resources Factor Value: Not Scored

3.3.4 WELLHEAD PROTECTION AREA

No Wellhead Protection Areas were evaluated as part of this HRS Documentation Record.

Wellhead Protection Area Factor Value: Not Scored
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

General Considerations 

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4.0 SURFACE WATER MIGRATION PATHWAY

4.0.1 GENERAL CONSIDERATIONS

Although migration of contaminants via overland flow/flood component to the Jard Surface Water Pathway has 

likely occurred, especially during flood events, limited data is available to support the overland flow/flood 

component to the Jard Surface Water Pathway. As noted below (see Section 4.2), the migration of contaminants 

from on-site sources to the Jard SWP via the ground water to surface water component has been documented. 

Therefore, the migration of PCB contaminants to the Jard Surface Water Pathway via the overland flow/flood 

component will not be evaluated, and the migration of PCB contaminants to the Surface Water Pathway via the 

ground water to surface water component is presented in this documentation record. 

Localized overland flow to drainage swales and ditches and previous flooding events occurring along the 

Roaring Branch of the Walloomsac River may have resulted in PCB contaminants migrating from Source Nos. 1 

and 2 to the Jard surface water pathway (SWP) via the overland flow/flood component [126, p. 28; 127, p. 1; 

129; 133]. Investigations on the Jard property have indicated the presence of PCB-contaminated soils in areas 

both around and below the former building footprint [30, pp. 14-16, 18, 20-21, 28-29, 33, 36-37, 70-95, 119-

137; 31, pp. 8-9, 14, 16-18, 31-33, 35, 112, 117-128, 142-143, 145-147; 65, pp. 12-13, 16, 19, 43, 52]. Soil 

samples collected and analyzed for PCBs throughout the developed and undeveloped former facility areas, 

including beneath the facility building, around the facility building, and around the larger undeveloped wooded 

areas extending south to the Roaring Branch of the Walloomsac River, revealed widespread PCB contamination, 

including the area extending south to the Roaring Branch [31, pp. 5, 7, 43, 137-138, 142-143, 145-147]. 

Prior to the razing of the Former Facility Building, the topography of the Jard property was generally level to the 

east and south of the former building, level to slightly hummocky to the north of the building, and sloping 

moderately away from the building on its western side, with a small seasonal drainage swale trending along the 

northwestern portion of the property and continuing northwest along Bowen Road [30, p. 5; 31, p. 7]. In 

addition, a berm of variable height, comprised of dredged river channel material, was located in the wooded area 

of the property along the northern bank of the Roaring Branch [31, p. 46]. This berm was reportedly constructed 

to prevent encroachment of the Roaring Branch on properties on the north side of the river, but also serves to 

inhibit overland flow from the Jard property from directly entering the river [31, p. 46]. In 2010, a stream 

restoration project was completed along the reach of the river adjacent to the Jard property, a component of 

which included the excavation of the berm and construction of a new berm closer to the facility building [65, pp. 

10, 25, 5 2]. The berm along the Roaring Branch was previously located approximately 90 feet north of the 

northern edge of the river, but the new berm was constructed closer to the Jard facility building (approximately 

40 feet farther north), as part of a floodplain restoration project to allow the river to access more of the historical 

floodplain and to reduce future flood damage [65, p. 10]. PCB sampling results of the area extending south on 

the Jard property to the Roaring Branch, including the area of soil material excavated during the 2010 river 

restoration project, indicate PCB contamination consistent with the release of PCBs from the Jard operations

[14, pp. 1-4, 7; 16; 65, pp. 10, 52, 57,145, 146]. 

On 28 August 2011, the partially completed floodplain restoration project was severely tested by Tropical Storm 

Irene, resulting in heavy, sustained rains in Southern Vermont which caused the Roaring Branch of the 

Walloomsac to overspill its banks [126, p. 28; 127, p. 1]. Flooding of the Roaring Branch caused a partial breach 

of the new armored berm at the transition point where the floodplain narrows from the newly restored section to 

the upstream approach to the Park Street Bridge [126, p. 28]. This damaged area is located along the 

southwestern portion of the former Jard facility and resulted in flood waters flowing across a portion of the 

former Jard facility before flooding areas to the west, including areas along Park Street [4, p. 2; 129, p. 1; 133, 

pp. 1-2].
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

General Considerations 

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4.1 OVERLAND/FLOOD MIGRATION COMPONENT

4.1.1 GENERAL CONSIDERATIONS

As noted above, previous flooding events occurring along the Roaring Branch of the Walloomsac River have 

likely resulted in PCB contaminants migrating from Source Nos. 1 and 2 to the Jard Surface Water Pathway via 

the overland flow and via groundwater to surface water components. Although migration of contaminants via 

overland flow to the SWP has likely occurred, especially during flooding events, based on the available 

supporting data, this documentation record will evaluate the Jard SWP via the ground water to surface water 

component. 

4.2 GROUND WATER TO SURFACE WATER COMPONENT

4.2.1 GENERAL CONSIDERATIONS

This documentation record presents data from selected background and contaminated sediment samples to 

document an observed release of PCBs, via chemical analysis, to the Jard surface water pathway (SWP) via the 

ground water to surface water component. This record documents an observed release of PCBs by chemical 

analysis, both to the Jard local overburden aquifer and to an Unnamed Stream, with some portion of the 

significant increase attributable to sources at the Jard facility, and documents an actual contamination at Level II 

concentrations to an Environmental Threat Target (HRS-eligible wetland frontage) located within 1 mile of 

sources (see below). Based on the results of ground water elevation data recorded in April 2012, October 2012, 

and March 2013, ground water in the overburden aquifer generally flows from sources on t he Jard property, 

without any discontinuities (as noted above in Section 3.0.1), toward the northwest, parallel to the Roaring 

Branch of the Walloomsac River, and discharges to the downgradient surface water bodies (Greene and Duck 

Ponds) [54, pp. 2 , 23-24; 67, pp. 1 , 5, 1 1; 68, pp. 3, 19-20]. Available data substantiate that the top of the 

overburden aquifer is at or above the bottom of the surface water at Greene and Duck Ponds (see below). 

Investigations completed by The Johnson Company in 2010 and 2013 presented the results of piezometer 

measurements which were used to assess the discharges of ground water to Greene Pond and Duck Pond, 

located at and near the headwaters of the Unnamed Stream, west of the Jard property (see Figures 2 and 6B) [4, 

p. 68; 65, pp. 20, 52; 68, pp. 1-3, 7, 8; 101, p. 1, 3]. As further explained below, water levels in the piezometers 

installed in Greene Pond and Duck Pond indicated an upward vertical gradient, indicating gaining conditions 

within these surface water bodies via ground water to surface water flow [65, pp. 28, 44, 45; 68 pp. 3, 7, 8, 19]. 

The Johnson Company 2010 Limited Phase II ESA Report noted that the conclusion of gaining conditions at 

these surface water bodies was further supported by the presence of seeps near the base of the slope above Duck 

Pond [65, p. 28]. 

In addition, the Phase II ESA Report presented data for six piezometers installed in the Roaring Branch of the 

Walloomsac River [65, pp. 21, 44 -45, 52, 59 ]. In general, measured water levels indicated that the Roaring 

Branch was a losing stream, with some temporal or location-specific exceptions [65, pp. 28, 44-45, 52, 59]. 

Piezometer location PZ-04, located west of and downgradient of the Jard property, was the only location where 

the Roaring Branch was consistently gaining, possibly as a result of its placement immediately below a drop in 

streambed elevation [65, pp. 21, 27, 44-45, 52-54, 57-59]. Water level differences between the stream and 

piezometer were relatively small at PZ-04 [65, pp. 21, 44-45, 59]. Interpretation of the data may indicate that the 

ground water to surface water component potentially intersects with the Roaring Branch of the Walloomsac 

River at this location. 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

General Considerations 

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The migration of PCB contaminants to the Jard SWP via the ground water to surface water component has likely 

occurred along two separate branches of the SWP, including the Roaring Branch of the Walloomsac River

located to the south and west of the Jard property, and the Unnamed Stream, with the probable point of entry 

(PPE) located at Greene Pond. Available data supports the migration of PCB contaminants to the Jard SWP via 

the ground water to surface water component along the Unnamed Stream west of the Jard property, which is 

therefore presented in this documentation record. 

4.2.1.2 Definition of Hazardous Substance Migration Path for Ground Water to Surface Water Migration 

Component

The ground water to surface water migration pathway at this site extends from the site sources into the Jard local 

overburden aquifer to both an Unnamed Stream and the Roaring Branch of the Walloomsac River. This 

overburden aquifer and the observed release of PCBs to it are described in sections 3.0.1 and 3.1.1 of this HRS 

documentation record.

For this pathway component, HRS-eligible surface waters are those for which surface water is within 1 mile of 

one or more sources with containment factor values greater than 0, there is no aquifer discontinuity between the 

source and the surface water that is within one mile, and the “top of the uppermost aquifer is at or above the 

bottom of the surface water” [1, p. 51626 (Section 4.2.1.1)].On 30 August 2010, T he Johnson Company 

measured the elevation of the top of the Uppermost Aquifer, within piezometer PZ-14 at Greene Pond (the 

surface water PPE), to be 658.56 feet above msl [65, pp. 28, 44, 45, 52; 100, pp.1-3]. 

As described below, the elevation of the bottom of the surface water body at the intersection of the Jard local 

overburden aquifer and HRS-eligible surface water at the PPE t o the in-water segment of the surface water 

pathway is less than 658.12 feet above msl. 

Based on investigations, conducted by The Johnson Company using piezometers, ground water discharges to 

local surface water bodies in the area of the Jard property were examined [65, pp. 4, 11-12, 20, 28, 44 -45, 52; 

68, pp. 3, 7-8; 100, pp. 1-9]. During July and August 2010, as part of The Johnson Control Phase II ESA, nine 

piezometers were installed in the vicinity of the Jard property, two of which were used to assess potential 

discharges of ground water to Duck Pond and Greene Pond [65, pp. 20, 22, 26]. Piezometer PZ-13 was installed 

in Duck Pond, approximately 30 feet west of MW-13; while piezometer PZ-14 was installed in Greene Pond, 

located on a residential property along Park Street, west of the Little League fields [65, p. 22 ]. Based on 

piezometer data, the top of the Uppermost Aquifer was determined to be above the bottom of the surface water 

bodies at Greene and Duck Ponds.

On 6 and 30 August 2010, The Johnson Company measured the depths to water inside and outside the installed 

piezometers [65, pp. 2 6-27, 44, 45 ]. By comparing water levels inside and outside the piezometer, a 

determination was made as to whether the surface water body in which the piezometers were installed was 

gaining (receiving ground water) or losing (discharging to ground water) [65, p. 20]. The elevation of the top of 

the ground water table (Jard local overburden aquifer) at Greene Pond (PZ-14) and Duck Pond (PZ-13) was 

measured at 658.56 and 656.19 feet above msl, respectively [65, pp. 44, 45, 53, 54]. The elevation of the top of 

the surface water at Greene Pond (PZ-14) and Duck Pond (PZ-13) was determined to be 658.12 and 655.56 feet 

above msl, respectively [65, pp. 26, 44, 45; 100, pp. 1-3]. Water levels in the piezometers installed in Duck 

Pond and Greene Pond indicated that these surface water bodies were gaining [65, pp. 28, 44, 45]. Although the 

elevation of the bottom of the surface water body at the PPE (Greene Pond) was not measured directly, based on 

the elevation measurement of the top of the surface water level at the PPE in Greene Pond, the bottom elevation 

of the surface water body must be below 658.12 feet above msl [100, pp. 1-3]. The Johnson Company report 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

General Considerations 

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noted that this conclusion of gaining conditions within Greene and Duck Ponds was further supported by the 

presence of seeps near the base of the slope above Duck Pond [65, p. 28]. 

Surface Water Probable Point of Entry and In-water Segment Description

Branch 1 of the in-water component of the Surface Water Pathway for the Jard site is located in the HudsonHoosic Watershed and includes the following surface water bodies: an Unnamed Stream (including Greene and 

Duck Ponds) (0.33 miles), Furnace Brook (1.91 miles), and the Walloomsac River (12.76 miles) (see Figure 7) 

[101, pp. 1 -3]. The most upstream PPE to the Unnamed Stream is located within the small drainage pond, 

referred to as Greene Pond, where ground water discharge to surface water has been documented [4, pp. 68, 71; 

65, pp. 22, 28, 58; 101, p. 1]. The PPE is located 0.13 miles from Source No. 1 (Contaminated Soil) and 0.20 

miles from Source No. 2 (Pile), both of which have a containment factor value greater that zero for a release to 

ground water (see Source Characterization Section) [102, pp. 2, 7 ]. Sediment samples SD-30 and SD-31, 

collected as part of the 2013 EPA SR, were located in Greene Pond at the headwaters of the Unnamed Stream 

[4, pp. 68, 71; 101, p. 1; 102, p. 1]. Surface water flow exits Greene Pond and flows north along the Unnamed 

Stream, through a culvert under the entrance to the Little League fields, and discharges to Duck Pond [4, p. 71; 

101, p. 1-3]. Exiting Duck Pond, flow continues northward along the Unnamed Stream, entering a culvert and 

continuing northwest beneath Park Street for approximately 45 feet [4, p. 71; 101, p. 1-3]. The 2013 EPA SR 

documented the continuous and perennial flow of the Unnamed Stream from Greene Pond to Duck Pond and 

downstream of Duck Pond through observations and confirmation by local residents along Park Street [4, pp. 

68, 71; 129, p.1; 133, p.1]. The Surface Water Pathway continues northwestward above ground, traversing 

residential properties and then an undeveloped property before converging with Furnace Brook [4, p. 71; 101, p. 

1-3]. The Surface Water Pathway continues along Furnace Book, in a northwest direction, for 1.91 miles, prior 

to converging with the Walloomsac River [101, p. 1-3]. Surface water flow continues along the Walloomsac 

River west-northwestward for approximately 5.51 miles to the New York State Border [101, p. 1 -3]. Flow 

continues along the Walloomsac River westward for the remaining 7.25 miles to the terminus of the downstream 

Surface Water Pathway, near North Hoosick, New York [101, p. 1-3]. 

A second branch of the in-water component of the Surface Water Pathway for the Jard site was evaluated and 

includes the following surface water bodies: Roaring Branch of the Walloomsac River (0.70 miles) and the 

Walloomsac River (14.3 miles) (see Figure 7) [134, pp. 1]. The most upstream PPE to this branch of the inwater component of the Jard Surface Water Pathway is represented by the shortest straight-line distance to the 

Roaring Branch of the Walloomsac River, located south of Source Nos. 1 and 2 where the discharge of ground 

water to surface water occurs [1, p. 51626 (Section 4.2.1.2); 102, pp. 1-2, 7; 134, pp. 1, 6]. The PPE is located 

approximate 0.04 miles from Source No. 1 (Contaminated Soil) and 0.1 miles from Source No. 2 (Pile), both of 

which have a co ntainment factor value greater that zero for a r elease to ground water (see Source 

Characterization Section) [102, pp. 1, 2, 7]. Surface water flow continues along the Roaring Branch of the 

Walloomsac River west-northwestward for approximately 0.70 miles to the Northside Drive Bridge, where it 

joins the Walloomsac River [101, pp. 1-4; 128, pp. 13, 18, 20] . Flow continues along the Branch 2 for 1.53 

miles, where Furnace Brook (Branch 1) discharges into the Walloomsac River [101, p. 4; 134, p. 1]. Surface 

water flow continues along the Walloomsac River west-northwestward for approximately 7.2 miles to the New 

York State Border [101, p. 1-3]. Flow continues along the Walloomsac River westward for the remaining 7.25 

miles to the terminus of the downstream Surface Water Pathway, near North Hoosick, New York [101, p. 1-3]. 

Contamination has been documented to the surface water migration pathway via the ground water to surface 

water component from the PPE at Greene Pond, along a 0.33-mile in-water segment of the Surface Water 

Pathway (see below). A release of contamination at least partially attributable to sources on the Jard property 

has been documented, via chemical analysis, for eight sediment samples collected along the Unnamed Stream 

(SD-31A, SD-32A, SD-36A, SD-39A, SD-41, SD-46A, SD-47A, and SD-49A) (see below). The most-upstream 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Likelihood of Release

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PPE for both Source No. 1 (Former Facility Source) and Source No. 2 (Excavated Material Pile) for this branch 

of the Surface Water Pathway is the headwaters for the Unnamed Stream (Greene Pond), which is the location 

of EPA SR sediment sample locations SD-30 and SD-31. 

4.2.1.3 Observed Release of a Specific Hazardous Substance to Surface Water In-Water Segment

Observed Release to Surface Water by Chemical Analysis

An observed release of hazardous substances (PCBs, analyzed as Aroclor 1242) to surface water, via a PPE at 

Greene Pond (see section 4.2.1.2 of this HRS documentation record), associated with sources on the Jard 

property, is documented via chemical analysis by comparing similar background and contaminated sediment 

samples, as described below. Previous investigations have documented PCB contamination within the wetland 

area located west of Park Street and have suggested the potential may exist for liquid phase PCBs in ground 

water to impact the neighboring surface water pathway, to the west of the Jard property (Duck Pond, the 

Unnamed Stream, and wetlands west of Park Street) [65, pp. 9-10, 28, 33-35, 60; 66, pp. 10, 22, 27, 29-30, 32-

33; 88, pp. 3, 9, 17 -18, 26-27, 29-32]. In addition, the EPA SR also documented several PCB-contaminated 

sediment samples (on property P030) within the wetland areas west of Park Street and south of the wetland 

frontage bordering the Unnamed Stream evaluated in this Documentation Record below [10, pp. 34-38, 56, 59, 

74, 170-172, 220, 242-243; 12, pp. 3, 14]. 

- Background Concentrations: 

On 16 April 2013, as part of the EPA SR and in accordance with the EPA-approved February 2013 Site-Specific 

QAPP, background sediment sampling activities were conducted [4, pp. 54-56; 9, pp. 1, 29 -32, 39]. Five 

background sediment samples (SD-51A, SD-51C, SD-52C, SD-53A, and SD-54C) were collected from a 

wetland area on a n undeveloped parcel located north-northeast of the Jard property to document natural 

background conditions in the local vicinity of the site (see Figures 2 and 6A) [4, pp. 55-56; 7; 12, pp. 2, 9 -10, 

12, 13; 18, pp. 52, 54, 57, 58, 63]. The background sediment sample results and references reviewed support that 

PCBs are neither naturally occurring nor ubiquitous in the local environment and that there is no other known 

source(s) of PCBs in the area (see below) [124, pp. 25-26].

In addition to the five background sediment samples, eight contaminated sediment samples (SD-31A, SD-32A, 

SD-36A, SD-39A, SD-41A, SD-46A, SD-47A, and SD-49A) were collected on 16 April 2013, as part of the 

EPA SR, from the wetland and stream area located west of the Jard property (see Figure 6B) [4, pp. 56-59; 18, 

pp. 25, 27, 31, 35, 37, 43 -44, 48, 52, 54, 57, 58, 6 3]. Background sediment samples were collected in the 

vicinity of the site from a si milar wetland environment as the contaminated sediment samples presented to 

document an observed release (see Contaminated Samples section below) [4, pp. 54-59; 12, p. 2; 18, pp. 25, 27, 

31, 35, 37, 43-44, 48, 52, 54, 57, 58, 63; 78]. The five background sediment samples were collected from the 

same depth interval (0 to 2 feet), during the same time period, and utilizing the same collection and analytical 

methods as the eight contaminated sediment samples [4, pp. 54-60; 12, pp. 2, 10, 35-38; 11, pp. 13-14, 16; 18, p. 

25, 27, 31, 35, 37, 43, 44, 48, 52, 54, 57, 58, 63; 78]. 

Table 23 – Background Sediment Sample Location Descriptions

Sample 

ID

Sample 

Medium Sample Location 

Depth* 

(inches) Date References

SD-51A 

(A4C22) 

Wetland 

Sediment 

Sediment located north of the 

Jard property, east of Bowen 

Road. 0-6 4/16/2013 

4, pp. 55, 64; 10, pp. 75, 

177; 18, p. 52 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Likelihood of Release

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Table 23 – Background Sediment Sample Location Descriptions

SD-51C 

(A4C24) 

Wetland 

Sediment 

Sediment located north of the 

Jard property, east of Bowen 

Road. 12-24 4/16/2013 

4, pp.55, 64; 10, pp. 75, 

177; 18, p. 54 

SD-52C 

(A4C27) 

Wetland 

Sediment 

Sediment located north of the 

Jard property, east of Bowen 

Road. 12-24 4/16/2013 

4, pp. 55, 64; 10, pp. 75, 

177; 18, p. 57 

SD-53A 

(A4C29) 

Wetland 

Sediment 

Sediment located north of the 

Jard property, east of Bowen 

Road. 0-6 4/16/2013 

4, pp. 55, 64; 10, pp. 75, 

177; 18, p. 58 

SD-54C 

(A4C26) 

Wetland 

Sediment 

Sediment located north of the 

Jard property, east of Bowen 

Road. 12-24 4/16/2013 

4, pp. 56, 64; 10, pp. 75, 

178; 18, p. 63 

* Depth below water/sediment interface

As presented in Table 26, the five background sediment samples collected as part of the EPA SR contained 

varying compositions of naturally occurring native matrix materials (i.e., sand, silt, clay, gravel, and organic 

matter) [18, pp. 52, 54, 57 , 58, 63]. Similarly, the contaminated sediment samples presented below exhibited 

varying compositions of the same naturally occurring native matrix materials (see Contaminated Samples 

section below) [18, pp. 25, 27, 31, 35, 37, 43, 44, 48, 52, 54, 5 7, 58, 63; 78]. The analytical results of each 

contaminated sediment sample were compared to the contaminant concentrations detected only in those 

background sediment samples which displayed the most similar matrix composition [78]. 

Table 24 – Background Sample Matrix Description

Sample ID Sample Description Reference

SD-51A 

(A4C22) 

Saturated dark brown-to-black, ORGANICS and SILT, little clay, trace fine to 

coarse sand. 18, p. 52

SD-51C 

(A4C24) 

Saturated, dark brown, SILT, some clay, trace organics, trace fine to coarse 

sand, trace fine to medium gravel. 18, p. 54 

SD-52C 

(A4C27) 

Saturated, brown, fine-to-medium SAND and fine-to-medium GRAVEL, little 

coarse sand, little silt, trace clay, trace organics. 18, p. 57

SD-53A 

(A4C29) Wet, dark brown, SILT, little clay, little organics, trace fine to coarse sand. 18, p. 58

SD-54C 

(A4C26) 

Moist, brown to dark brown, fine to medium SAND and SILT, some clay, 

trace coarse sand, trace organics. 18, p. 63

The five background sediment samples were submitted to a CLP laboratory (Chemtech Consulting Group) for 

analysis of low/medium Aroclor compounds following SOW SOM1.2, and the data were validated at the Tier II 

level by personnel not involved with the sediment sampling event and according to Region I EPA-NE Data 

Validation Functional Guidelines for Evaluating Environmental Analyses and the USEPA CLP National 

Functional Guidelines for Superfund Organic Method [4, pp. 55, 56, 61, 64; 11, p. 16; 76, pp. 1-4, 8; 77, pp. 1-4, 

8-9]. As part of this HRS Documentation Record and the evaluation of background concentrations, the 

following hazardous substance in background sediment samples is presented: Aroclor 1242 (PCBs). 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Likelihood of Release

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Laboratory analytical results of PCBs (analyzed as Aroclor 1242) in sediment samples SD-51A, SD-51C, SD52C, SD-53A, and SD-54C indicated non-detect levels at the sample-adjusted CRQLs (ranging from 45 μg/Kg

to 71 μg/Kg for Aroclor 1242) [76. p. 8; 85, pp. 1-2, 4-5, 47; 77, pp. 8-9; 86, pp. 1-2, 4-5, 7-8, 93, 95-96, 98]. 

An observed release via chemical analysis of PCBs (analyzed as Aroclor 1242) is established when the sample 

measurement equals or exceeds the sample-adjusted CRQL of the representative/similar background sample [1, 

p. 51589 (Table 2-3)]. Among the five background sediment samples, PCBs (analyzed as Aroclor 1242) were 

not detected, with the highest sample-adjusted CRQL at 71 μg/Kg in samples SD-51A (A4C22) and SD-53A 

(A4C29) [76. p. 8; 77, pp. 8-9; 85, p. 5; 86, pp. 7-8]. 

Table 25 – Hazardous Substances Associated with Background Sediment Samples

Sample ID

Hazardous 

Substance

Concentration

(μg/Kg) 

Sample-Adjusted CRQL

(μg/Kg) References

SD-51A 

(A4C22) 

PCBs

(Aroclor 1242) 71 U 71 

18, p. 52; 76, p. 8; 85, pp. 

1-2, 5, 47 

SD-51C 

(A4C24) 

PCBs

(Aroclor 1242) 53 U 53 

18, p. 54; 77, p. 8; 86, pp. 

1-2, 7, 93 

SD-52C

(A4C27) 

PCBs

(Aroclor 1242) 45 U 45 

18, p. 57; 77, p. 8; 86, pp. 

1-2, 7, 96 

SD-53A 

(A4C29) 

PCBs

(Aroclor 1242) 71 U 71 

18, p. 58; 77, p. 9; 86, pp. 

1-2, 8, 98 

SD-54C 

(A4C26) 

PCBs

(Aroclor 1242) 45 U 45 

18, p. 63; 77, p. 8; 86, pp. 

1-2. 7, 95 

U = Value is non-detected [76, p. 8; 77, pp. 8-9]. 

CRQL = Contract-required Quantitation Limit is the substance specific level that a Contract Laboratory 

Program (CLP) laboratory must be able to routinely and reliably detect. Used here, the CRQL has 

been adjusted per the CLP Scope of Work SOM01.2 and represents a sample specific quantitation 

limit [1, pp. 51585, 51589; 76; 77; 85; 86] 

The background sediment samples were used to establish background conditions and chemical compositions of 

the sediment materials within the vicinity of the Jard property, and to establish the range of concentrations for 

PCBs (analyzed as Aroclor 1242) in local sediments for the ground water to surface water component of the Jard 

SWP. Analytical results of the background sediment samples are presented to establish representative 

background concentrations for PCBs (analyzed as Aroclor 1242), which are used to demonstrate that significant 

concentrations of these hazardous substances have been detected in the eight contaminated sediment samples 

collected from the wetland located west of the Jard property.

- Contaminated Samples:

On 16 April 2013, as part of the EPA SR and in accordance with the EPA-approved February 2013 Site-Specific 

QAPP, sediment sampling activities were conducted along the SWP and within the HRS-eligible wetland 

located west-northwest of the Jard property [4, pp. 54-61, 63-64; 9, pp. 1, 29-32, 39; 10, pp. 35-38, 46-47, 54-

55, 57-58, 74, 75; 12, pp. 2-4, 14]. Eight contaminated sediment samples (SD-31A, SD-32A, SD-36A, SD-39A, 

SD-41A, SD-46A, SD-47A, and SD-49A) were collected, at depths down to 1 foot below the water/sediment 

interface, from the Unnamed Stream and associated wetlands (see Figure 6B) [4, pp. 56-58; 18, pp. 25, 2 7, 31, 

35, 37, 43, 44, 48]. 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Likelihood of Release

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Table 26 – Contaminated Sediment Sample Location Descriptions

Sample 

ID

Sample 

Medium Sample Location 

Distance 

from PPE

(feet)

Depth* 

(inches) Date References

SD-31A 

(A4C08) Sediment 

Sediment / PPE sample located on 

northwestern corner of residential 

property P011 at headwaters of 

“Unnamed Stream”. 12.1 0 to 12 4/16/2013 

4, pp. 58, 63, 

71-72; 10, p. 

69, 74; 18, p. 

25; 102, p.3 

SD-32A 

(A4C07) Sediment 

Sediment located along “Unnamed 

Stream” on northwestern corner of 

residential property P011. 41.2 0 to 12 4/16/2013 

4, pp. 58, 63; 

10, p. 69, 74; 

18, p. 27; 

102, p.3 

SD-36A 

(A4C06) Sediment 

Sediment located along “Unnamed 

Stream” on residential property 

P006. 531.7 0 to 12 4/16/2013 

4, pp. 57, 63; 

10, p. 69, 74; 

18, p. 31; 

102, p.3 

SD-39A 

(A4C05) Sediment 

Sediment located along “Unnamed 

Stream” on property P041. 760.3 0 to 8 4/16/2013 

4, pp. 57, 64; 

10, p. 69, 74; 

18, p. 35; 

102, p.3 

SD-41A 

(A4C04) 

Wetland 

Sediment 

Sediment located along “Unnamed 

Stream” in east-central portion of 

property P030, west of Park Street 

and property P041. 1005.8 0 to 12 4/16/2013 

4, pp. 57, 64; 

10, p. 69, 74; 

18, p. 37; 

102, p.3 

SD-46A 

(A4C10) 

Wetland 

Sediment 

Sediment located along “Unnamed 

Stream” in north-central portion of 

property P030, west of Park Street. 1374.4 0 to 12 4/16/2013 

4, pp. 56, 64; 

10, pp. 69, 

74; 18, p. 43; 

102, p.3 

SD-47A 

(A4C09) 

Wetland 

Sediment 

Sediment located along “Unnamed 

Stream” in north-central portion of 

property P030, west of Park Street. 1492.7 0 to 12 4/16/2013 

4, pp. 56, 64; 

10, p. 69, 74; 

18, p. 44; 

102, p.3 

SD-49A 

(A4C01) 

Wetland 

Sediment 

Sediment located along “Unnamed 

Stream” in northwestern portion of 

property P030, west of Park Street. 1626.2 0 to 12 4/16/2013 

4, pp. 56, 64; 

10, p. 69, 74; 

18, p. 48; 

102, p.3 

* Depth below water/sediment interface

The eight contaminated sediment samples collected as part of the EPA SR contained varying compositions of 

naturally occurring native matrix materials which were similar to the five background sediment samples 

presented earlier (see Tables 26 and 29) [4, pp. 54-61, 63-64; 18, pp. 25, 27, 31, 35, 37, 43, 44, 48, 52, 54, 57, 

58, 63; 78]. The eight contaminated sediment samples were collected from the SWP, during the same time 

period and from similar depths, and using the same collection and analytical methods as the five background 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Likelihood of Release

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sediment samples presented above [4, pp. 54-61, 63-64, 71-72; 11, pp. 13-14, 16; 18, p. 25, 27 , 31, 35, 37, 43, 

44, 48, 52, 54, 57, 58, 63; 75, pp. 1-5;76, pp. 1-4; 77, pp. 1-4]. 

Table 27 – Contaminated Sediment Sample Matrix Description

Sample ID Sample Description Reference

SD-31A 

(A4C08) 

Saturated, brown, fine to medium SAND, some silt, some fine to medium 

gravel, trace coarse sand, trace organics, trace clay. 18, p. 25 

SD-32A 

(A4C07) 

Saturated, dark brown, SILT, some organics, little fine to coarse sand, trace 

clay, trace fine gravel. 18, p. 27 

SD-36A 

(A4C06) 

Saturated, dark brown, SILT, some organics, trace clay, trace fine to coarse 

sand. 18, p. 31 

SD-39A 

(A4C05) 

Saturated, dark brown, SILT, little fine to medium gravel, little organic debris 

(pine needles, bark, and wood chips), trace clay, trace fine to coarse sand. 18, p. 35 

SD-41A 

(A4C04) 

Saturated, dark brown, fine to coarse SAND and SILT, little fine to medium 

gravel, trace clay, trace organics. 18, p. 37 

SD-46A 

(A4C10) 

Moist, brown, fine to coarse SAND, some fine to medium gravel, trace silt, 

trace debris (plastic sheeting), trace organics, trace clay. 18, p. 43 

SD-47A 

(A4C09) 

Moist, dark brown, SILT, some clay, some fine to medium sand, trace coarse 

sand, trace fine gravel, trace organics. 18, p. 44 

SD-49A 

(A4C01) Wet, dark brown, SILT, some organics, trace clay, trace fine to coarse sand. 18, p. 48 

The eight contaminated sediment samples were submitted to a CLP laboratory (Chemtech Consulting Group) for 

analysis of low/medium Aroclor compounds following SOW SOM1.2, and the data were validated at the Tier II 

level by personnel not involved with the sediment sampling event and according to Region I EPA-NE Data 

Validation Functional Guidelines for Evaluating Environmental Analyses and the USEPA CLP National 

Functional Guidelines for Superfund Organic Method [4, pp. 56-58, 61, 63-64; 11, pp. 13-14; 18, pp. 25, 27, 31, 

35, 37, 43, 44, 48; 75. pp. 1-5, 9,10]. 

Aroclor 1242 was detected in contaminated sediment samples at concentrations above each sample-adjusted 

CRQL, and above the background concentrations established by analytical results of background samples, 

thereby establishing observed release of Aroclor 1242 (PCBs) to the SWP via chemical analysis [1, p. 51589 

(Table 2-3); 75, pp. 9-10; 76, p. 8; 77, pp. 8-9; 84, pp. 8-9, 76, 79-85; 85, p. 5; 86, pp. 7-8].

Table 28 - Hazardous Substances Associated with Contaminated Sediment Samples

Sample 

ID

Hazardous 

Substance

Concentration 

(μg/Kg) 

Sample-Adjusted 

CRQL

(μg/Kg) References

SD-31A 

(A4C08) 

PCBs

(Aroclor 1242) 230 42 

18, p. 25; 75, p. 10; 84, pp. 1-2, 9, 

83 

SD-32A

(A4C07) 

PCBs

(Aroclor 1242) 470 50 18, p. 27; 75, p. 9; 84, pp. 1-2, 8, 82 

SD-36A 

(A4C06) 

PCBs

(Aroclor 1242) 100 58 18, p. 31; 75, p. 9; 84, pp. 1-2, 8, 81 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Likelihood of Release

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Table 28 - Hazardous Substances Associated with Contaminated Sediment Samples

SD-39A

(A4C05) 

PCBs

(Aroclor 1242) 98 88 18, p. 35; 75, p. 9; 84, pp. 1-2, 8, 80 

SD-41A 

(A4C04) 

PCBs

(Aroclor 1242) 250 42 18, p. 37; 75, p. 9; 84, pp. 1-2, 8, 79 

SD-46A 

(A4C10) 

PCBs

(Aroclor 1242) 220 40 

18, p. 43; 75, p. 10; 84, pp. 1-2, 9, 

85 

SD-47A

(A4C09) 

PCBs

(Aroclor 1242) 87 47

18, p. 44; 75, p. 10; 84, pp. 1-2, 9, 

84 

SD-49A

(A4C01) 

PCBs

(Aroclor 1242) 320 54 18, p. 48; 75, p. 9; 84, pp. 1-2, 8, 76 

CRQL = Contract-required Quantitation Limit is the substance specific level that a Contract Laboratory 

Program (CLP) laboratory must be able to routinely and reliably detect. Used here, the CRQL has 

been adjusted per the CLP Scope of Work SOM01.2 and represents a sample specific quantitation 

limit [1, pp. 51585, 51589; 75; 84] 

Attribution:

The operational and investigative history of the Jard property has documented use and release of PCBs into the 

environment (see Site Summary Section). Chemical analysis of samples collected from Source Nos. 1 and 2 has 

documented the presence of the hazardous substances (see Source Characterization Sections). Chemical analysis 

of ground water samples collected from monitoring wells and piezometers as part of numerous investigations 

has indicated the presence of PCB contamination in the overburden aquifer in proximity to the Jard property as 

discussed in the Ground Water Migration Pathway section of this documentation record (see Section 3.1.1). 

Investigations completed by The Johnson Company in 2010 a nd 2012 i ndicated that water levels in the 

piezometers installed in Greene Pond (PPE for the Jard SWP) and Duck Pond (downstream of PPE) indicated an 

upward vertical gradient, indicating gaining (receiving ground water) conditions within these surface water 

bodies via ground water to surface water flow [65, pp. 28, 44, 45; 68 pp. 3, 7, 8, 19; 101, pp. 1-3]. The Johnson 

Company 2010 Limited Phase II ESA Report noted that the conclusion of gaining conditions at these surface 

water bodies was further supported by the presence of seeps near the base of the slope above Duck Pond [65, p. 

28]. 

Chemical analysis of eight sediment samples (SD-31A, SD-32A, SD-36A, SD-39A, SD-41A, SD-46A, SD-47A, 

and SD-49A) establish an observed release of PCBs (analyzed as Aroclor 1242) to the SWP along the Unnamed 

Stream from the PPE to SD-49, located 0.308 miles downstream of the PPE [1, p. 51589 (Table 2-3); 75, pp. 9-

10; 76, p. 8; 77, pp. 8-9; 84, pp. 8 -9, 76, 79-85; 85, p. 5; 86, pp. 7-8; 102, p. 3]. Chemical analysis of four 

sediment samples (SD-41A, SD-46A, SD-47A, and SD-49A), collected from the HRS-eligible wetland along 

the Unnamed Stream west-northwest of the Jard property, meet the criteria for observed release and 

documentation of actual contamination of PCBs (analyzed as Aroclor 1242) to an Environmental Threat Target 

[4, pp. 56-57, 61, 64; 18, pp. 37, 43, 44, 48; 12, pp. 3-4, 14; 102, p. 5] . The presence of PCBs (analyzed as 

Aroclor 1242) at elevated concentrations in Source Nos. 1 and 2, and the documentation via chemical analysis 

of an observed release of these substances to the wetland along the Unnamed Stream west-northwest of the Jard 

property, support at least partial attribution of the hazardous substances to releases from the Jard site [1, p. 

51588 (Section 2.2.2)]. The hazardous substances used to establish an observed release (PCBs) are associated 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Likelihood of Release

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with the Jard site, and the site has contributed at least in part to the significant increase in hazardous substance 

concentrations. 

START personnel did not observe any additional possible sources of observed releases of hazardous substances 

along the Unnamed Stream segment (from the SWP PPE to the confluence with Furnace Brook) evaluated as 

part of this HRS Documentation Record [4, p. 71]. The stream segment evaluated as part of the documentation 

record generally flows adjacent to or though residential or undeveloped properties [4, p. 71]. Observations and 

Discussions with residents during the EPA SR, along with documentation from The Johnson Company Phase II 

ESA indicate that ground water occasionally infiltrates residential foundations/basements through seeps [4, p. 

28, 35, 43, 46, 51, 69, 68; 65, p. 22, 35]. Infiltrated ground water from basements drains connected to sump 

pumps direct the water to ground surface areas and potentially into the Unnamed Stream and wetlands west of 

Park Street [4, p. 68-69; 61, pp. 4-5; 65, p. 22, 35]. Other possible sources of releases were investigated through 

review of file information and observations made during field activities (see Section 3.1.1 – Attribution – Other 

Possible Sites).

Specific Hazardous Substances Meeting Criteria for Observed Release to Surface Water In-water Segment: 

PCBs (analyzed as Aroclor 1242) 

4.2.2.1.1 Observed Release

A ground water observed release of PCBs has been documented in section 3.1.1 of this HRS documentation 

record. Therefore, according to Section 4.2.2.1.1 of the HRS, a 550 is assigned on line 1 of Table 4-25 (the HRS 

Ground Water to Surface Water Migration Component Scoresheet). 

Hazardous Substances Meeting Criteria for Observed Release to Ground Water: 

PCBs (analyzed as Aroclor 1242) 

Observed Release Factor Value: 550

4.2.2.1.2 Potential to Release

An observed release to ground water was documented through chemical analysis; therefore, potential to release 

was not evaluated. 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Human Food Chain Threat - Waste Characteristics

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4.2.2.2 Drinking Water Threat Waste Characteristics 

Drinking Water Threat Targets have not been identified for the ground water to surface water flow component 

for the Surface Water Pathway; therefore, the Drinking Water Threat has not been evaluated as part of this HRS 

Documentation Record. 

4.2.3.2 Human Food Chain Threat Waste Characteristics

A Human Food Chain Threat Target, fishery, has been identified and documented for the surface water 

migration pathway ground water to surface water flow component, evaluated below as part of this HRS 

documentation record. 

4.2.3.2.1 Toxicity/Mobility/Persistence/Bioaccumulation 

Listed below are the hazardous substances for which an observed release to surface water via ground water to 

surface water component has been documented (see Section 4.2.1.3 of this Evaluation) and are associated with 

sources having a ground water containment factor value greater than 0 (see Sections 2.2.2, 2.2.3 and 3.1.1 of this 

Evaluation). 

The Toxicity Factor Value, the Persistence Factor Value, and the Bioaccumulation Factor Value are assigned to 

the hazardous substances associated with the sources and releases at the Jard site [2, pp. 1 -2]. Since the 

downstream hazardous substance migration pathway is comprised of fresh water riverine environments, the 

toxicity and bioaccumulation factor values for fresh water, and the persistence values for rivers are used. 

Table 29 – Ecosystem Toxicity/Mobility/Persistence/Bioaccumulation

Hazardous 

Substance

Source 

No.

Toxicity 

Factor 

Value

Mobility 

Factor 

Value*

Toxicity/

Mobility 

Factor Value 

[1, Table 3-9] 

Persistence 

Factor 

Value** 

Toxicity/

Mobility/

Persistence

Factor Value 

[1, Table 4-26] References

PCBs, 

(analyzed as 

Aroclors 

1016 and 

1242) 1, 2 10,000 1 10,000 1 10,000 

1, pp. 51602

(Table 3-9), 

51630 

(Table 4-26); 

2, pp. 1-2 

* For any hazardous substance that meets the criteria for an observed release by chemical analysis to one 

or more aquifers underlying the sources at the site, regardless of the aquifer being evaluated, assign a 

mobility factor value of 1 [1, pp. 51601 (Section 3.2.1.2), 51629 (Section 4.2.2.2.1.2)]. 

** Persistence value for Rivers.

From HRS Table 4-26, a Toxicity/Mobility Factor Value of 10,000 and a Persistence Factor Value of 1 for 

PCBs results in an Toxicity/Mobility/Persistence Factor Value of 10,000 [1, p. 51630; 2, pp. 1-2]. 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Human Food Chain Threat - Waste Characteristics

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Table 30 - Toxicity/Mobility/Persistence/Ecosystem Bioaccumulation Factor Value

Hazardous 

Substance

Ecosystem 

Toxicity/

Mobility/

Persistence

Factor Value 

Bioaccumulation 

Factor Value* 

Toxicity/

Mobility/Persistence/

Bioaccumulation 

Factor Value 

[1, Table 4-28] References

PCBs 

(Aroclor 1242) 10,000 50,000 5 × 108

1, p. 51633; 2, 

pp. 1-2 

* Bioaccumulation Factor value for fresh water

From HRS Table 4-28, a Toxicity/Mobility/Persistence Factor Value of 10,000 and a Bioaccumulation Factor 

Value of 50,000 for PCBs results in an Toxicity/Mobility/Persistence/ Bioaccumulation Factor Value of 5 × 108 

[1, p. 51633; 2, pp. 1-2]. 

Toxicity/Mobility/Persistence/ Ecosystem Bioaccumulation Factor Value: 5 × 108

4.2.3.2.2 Hazardous Waste Quantity

Table 31 – Hazardous Waste Quantity

Source No. Source Type Source Hazardous Waste Quantity

1 Contaminated Soil 3.14 

2 Pile 13,300 

Sum of Values: 13,303.14 

Based on HRS Section 2.4.2.2, if the Hazardous Constituent Quantity is not adequately determined for one or 

more sources and if any target for the SWP is subject to Level I or Level II concentrations, a factor value is 

assigned from Table 2-6, or a value of 100, whichever is greater, as the Hazardous Waste Quantity Factor Value 

for that pathway [1, pp. 51591-51592 (Section 2.4.2.2)]. 

Hazardous Waste Quantity Factor Value [1, Table 2-6]: 10,000 

4.2.3.2.3 Waste Characteristics Factor Category Value

The Toxicity Factor Value (10,000) and Mobility Factor Value (1.0) for PCBs are multiplied in order to 

determine the Toxicity/Mobility Factor Value (10,000) [1, p. 51602 (Section 3.2.1.3, Table 3-9)]. The 

Toxicity/Mobility Factor Value (10,000) and the Persistence Factor Value (1.0) for PCBs are multiplied in order 

to determine the Toxicity/Mobility/Persistence Factor Value (10,000) [1, pp. 51629- (Section 4.2.2.2.1.4), 51630 

(Table 4-26)]. The Toxicity/Mobility/Persistence Factor Value for the watershed (10,000) is multiplied by the 

Hazardous Waste Quantity Factor Value for the watershed (10,000) in order to determine the Waste 

Characteristics Product, subject to a maximum value of 1 × 108 [1, pp. 51590 (Section 2.4.1.2), 51591 (Section 

2.4.2.2), 51592 (Section 2.4.3.2), 51624 (Section 4.1.4.2.3)]. 10,000 × 10,000 = 1 × 108

. 

Toxicity/Mobility/Persistence Factor Value: 10,000

Hazardous Waste Quantity Factor Value: 10,000 

Toxicity/Mobility/Persistence Factor Value x Hazardous Waste Quantity Factor Value: 1 × 108 

Bioaccumulation Potential Factor Value: 50,000
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Human Food Chain Threat - Targets

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The product of the Toxicity/Mobility/Persistence Factor Value and the Hazardous Waste Quantity Factor Value 

(equal to 1 × 108

) is multiplied by the Bioaccumulation Potential Factor Value (50,000) for PCBs in order to 

determine the Waste Characteristics Factor Category Value, subject to a maximum product of 1 × 1012 [1, pp. 

51638 (Section 4.2.4.2.1.5), 51592 (Section 2.4.3.2, Table 2-7)]. 1 × 108 × 50,000 = 5 × 1012. However, since 

the value exceeds maximum product value, the value of 1 × 1012 is assigned.

(Toxicity/Mobility/Persistence Factor Value × Hazardous Waste Quantity Factor Value) × Bioaccumulation 

Potential Factor Value: 1 × 1012

Based on the Waste Characteristics Factor Category Value (1 × 1012) and HRS Table 2-7, the Waste 

Characteristics Factor Category for the Watershed is 1,000 [1, p. 51592 (Section 2.4.3.2, Table 2-7)]. 

Waste Characteristics Factor Category Value [1, Table 2-7]: 1,000 

4.2.3.3 Human Food Chain Threat Targets 

An interview with a local professional fishing guide, catering to fly-, spin-, and ice-anglers in Vermont, 

confirmed the presence of a recreational fishery occurring in the Walloomsac River in Bennington, Vermont 

[132, p. 1 ]. According to the interviewed fishing guide, trout are harvested from the Walloomsac River and 

consumed by people living in the local area [132, p. 1]. The fishing guide observed fish being taken from access 

points at the Hunt Street Bridge, behind the McDonald’s Restaurant; the Silk Street Covered Bridge; and the 

Henry Covered Bridges [132, p. 1]. In addition, according to a Vermont Fish and Wildlife Fisheries Biologist, it 

is highly likely that people consume fish caught in the Walloomsac River [131, p.1]. Furthermore, according to 

a Vermont Fish & Wildlife Department News Release; a section of the Walloomsac River extending from the 

Vermont/New York border in Bennington, upstream to the top of the former Vermont Tissue Plant Dam 

(downstream of Murphy Road) in Bennington, has been added to the trophy trout streams stocked with two-year 

old brown or rainbow trout with a daily limit of two trout per day [130, p. 1]. The new release notes that this 

section of the Walloomsac River is open to trout fishing year round according to the following rules: only 

artificial flies or lures may be used, except during the open season for trout (2nd Saturday in April to October

31); catch and release only (trout must be immediately released where caught), except during the open season 

for trout; and during open season for trout, follow normal size restrictions, daily limits and possession limits 

[130, p.1]. The annual harvest information for the above species was not found in available file information, but 

is greater than zero (> 0) pounds based on the documentation of the interviewed local professional fishing guide 

observing people harvesting fish from the fishery.

4.2.3.3.1 Food Chain Individual

Data is not available to support that the Walloomsac River fishery is subject to actual contamination, Level I or 

Level II concentrations; however, there is an observed release of hazardous substances (PCBs), having a 

Bioaccumulation Factor Value of 500 or greater to the in-water segment for the watershed; and there is a fishery 

present within the TDL (See Section 4.2.1.3 and Section 4.2.3.3 of this Evaluation). Therefore, the fishery in 

Walloomsac River is evaluated as subject to potential human food chain contamination [1, p. 51638 (Section 

4.2.3.3)]. As a result, a Food Chain Individual Factor Value of 20 is assigned [1, p. 51638 (Section 4.2.3.3.1)]. 

Sample ID: SD-32 (A4C07) 

Level I/Level II/or Potential Contamination: Potential Contamination

Hazardous Substance: PCBs (analyzed as Aroclor 1242)

Bioaccumulation Potential: 50,000

Food Chain Individual Factor Value: 20 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Human Food Chain Threat - Targets

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4.2.3.3.2 Population

4.2.3.3.2.3 Potential Human Food Chain Contamination 

An interview with a local professional fishing guide confirmed the presence of a trout fishery occurring in the 

Walloomsac River in Bennington, Vermont [130, p. 1; 132, p. 1]. 

Potential Population Targets

The annual harvest information for the Walloomsac River fishery was not found in available file information, 

but is greater than zero (> 0) pounds based on the documentation of the interviewed local professional fishing 

guide observing people harvesting fish from the fishery. Based on the drainage basin area, the Walloomsac 

River has an estimated flow rate, in the reach documented as a fishery, of greater than 100 cubic feet per second 

[134]. Based on these estimated calculations, the Walloomsac River is classified as a moderate to large stream 

and is assigned a dilution weight of 0.01 [1, p. 51613 (Table 4-13); 134]. A Dilution Weight Adjustment Value 

was assigned based on the theta angle (212 degrees) from site sources to the intersection of the surface water 

body within 1 radial-mile [1, p. 51631 (Section 4.2.2.3.1 and Table 4-27); 135]. Therefore, the potential food 

chain contamination factor value for the potential population is 0.000018. 

Table 32 - Potential Food Chain Contamination Factor Value

Identity of 

Fishery

Annual 

Production 

(pounds)

Type of 

Surface

Water Body

Average 

Annual

Flow

(cfs) References

Population 

Value (Pi) 

[1, Table 

4-18]

Dilution

Weight 

(Di) [1, 

Table 4-

13]

Dilution 

Weight 

Adjustment

Value (A) [1, 

Table 4-27]

Pi x 

(Di x A)

Walloomsac 

River > 0

Moderate to 

Large 

Stream

> 100 to 

288 

130, p. 1; 

132, p. 1; 

134; 135 0.03 0.01 0.6 0.00018 

Sum of Pi x (Di x A): 0.00018 

(Sum of Pi x [Di x A])/10: 0.000018 [1, p. 51621 (Section 4.1.3.3.2.3)] 

Potential Human Food Chain Contamination Factor Value: 0.000018 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Environmental Threat – Waste Characteristics

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4.2.4.2 Environmental Threat Waste Characteristics

An Environmental Threat Target, HRS-eligible wetland frontage, has been identified and documented for the 

surface water migration pathway ground water to surface water flow component, evaluated below as part of this 

HRS Documentation Record. 

4.2.4.2.1 Ecosystem Toxicity/Mobility/Persistence/Bioaccumulation

Table 33 – Ecosystem Toxicity/Mobility/Persistence/Bioaccumulation

Hazardous 

Substance

Source 

No.

Ecosystem 

Toxicity 

Factor 

Value

Mobility 

Factor 

Value*

Ecosystem

Toxicity/

Mobility 

Factor Value 

[1, Table 3-9] 

Persistence 

Factor 

Value** 

Ecosystem

Toxicity/

Mobility/

Persistence

Factor Value 

[1, Table 4-29] References

PCBs 

(Aroclor 

1242) 1, 2 10,000 1 10,000 1 10,000 

1, pp. 51602, 

51639; 2, pp. 

1-2 

* For any hazardous substance that meets the criteria for an observed release by chemical analysis to one 

or more aquifers underlying the sources at the site, regardless of the aquifer being evaluated, assign a 

mobility factor value of 1 [1, pp. 51601 (Section 3.2.1.2), 51629 (Section 4.2.2.2.1.2)]. 

** Persistence value for Rivers.

From HRS Table 4-29, an Ecosystem Toxicity/Mobility Factor Value of 10,000 and a Persistence Factor Value 

of 1 for PCBs results in an Ecosystem Toxicity/Mobility/Persistence Factor Value of 10,000 [1, p. 51639; 2, pp. 

1-2]. 

Table 34 - Ecosystem Toxicity/Mobility/Persistence/Ecosystem Bioaccumulation Factor Value

Hazardous 

Substance

Ecosystem 

Toxicity/

Mobility/

Persistence

Factor Value 

Ecosystem

Bioaccumulation 

Factor Value* 

Ecosystem Toxicity/ 

Mobility/Persistence/

Ecosystem Bioaccumulation

Factor Value 

[1, Table 4-30] References

PCBs 

(Aroclor 1242) 10,000 50,000 5 × 108

1, pp. 51639-

51640; 2, pp. 1-2 

* Ecosystem Bioaccumulation Factor value for fresh water

From HRS Table 4-30, an Ecosystem Toxicity/Mobility/Persistence Factor Value of 10,000 and an Ecosystem 

Bioaccumulation Factor Value of 50,000 for PCBs results in an Ecosystem Toxicity/Mobility/Persistence/ 

Bioaccumulation Factor Value of 5 × 108 [1, p. 51640; 2, pp. 1-2]. 

Ecosystem Toxicity/Mobility/Persistence/ Ecosystem Bioaccumulation Factor Value: 5 × 108
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Environmental Threat – Waste Characteristics

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4.2.4.2.2 Hazardous Waste Quantity

Table 35 – Hazardous Waste Quantity

Source No. Source Type Source Hazardous Waste Quantity

1 Contaminated Soil 3.14 

2 Pile 13,300 

Sum of Values: 13,303.14 

Based on HRS Section 2.4.2.2, if the Hazardous Constituent Quantity is not adequately determined for one or 

more sources and if any target for the SWP is subject to Level I or Level II concentrations, a factor value is 

assigned from Table 2-6, or a value of 100, whichever is greater, as the Hazardous Waste Quantity Factor Value 

for that pathway [1, pp. 51591-51592 (Section 2.4.2.2)]. 

Hazardous Waste Quantity Factor Value [1, Table 2-6]: 10,000 

4.2.4.2.3 Waste Characteristics Factor Category Value

The Ecosystem Toxicity Factor Value (10,000) and Mobility Factor Value (1.0) for PCBs are multiplied in order 

to determine the Ecosystem Toxicity/Mobility Factor Value (10,000) [1, pp. 51602 (Section 3.2.1.3, Table 3-9)]. 

The Ecosystem Toxicity/Mobility Factor Value (10,000) and the Persistence Factor Value (1.0) for PCBs are 

multiplied in order to determine the Ecosystem Toxicity/Mobility/Persistence Factor Value (10,000) [1, pp. 

51638-51639 (Section 4.1.4.2.1.5, Table 4-29)]. The Ecosystem Toxicity/Mobility/Persistence Factor Value for 

the watershed (10,000) is multiplied by the Hazardous Waste Quantity Factor Value for the watershed (10,000) 

in order to determine the Waste Characteristics Product, subject to a maximum value of 1 × 108 [1, pp. 51590 

(Section 2.4.1.2), 51591 (Section 2.4.2.2), 51592 (Section 2.4.3.2), 51624 (Section 4.1.4.2.3)]. 10,000 × 10,000 

= 1 × 108

. 

Ecosystem Toxicity/Mobility/Persistence Factor Value: 10,000

Hazardous Waste Quantity Factor Value: 10,000 

Ecosystem Toxicity/Mobility/Persistence Factor Value x Hazardous Waste Quantity Factor Value: 1 × 108

Ecosystem Bioaccumulation Potential Factor Value: 50,000 

The product of the Ecosystem Toxicity/Mobility/Persistence Factor Value and the Hazardous Waste Quantity 

Factor Value (equal to 1 × 108

) is multiplied by the Bioaccumulation Potential Factor Value (50,000) for PCBs 

in order to determine the Waste Characteristics Factor Category Value, subject to a maximum product of 1 × 

1012 [1, pp. 51638 Section 4.2.4.2.1.5; 51592 (Section 2.4.3.2, Table 2-7)]. 1 × 108 × 50,000 = 5 × 1012. 

However, since the value exceeds maximum product value, the value of 1 × 1012 is assigned.

(Ecosystem Toxicity/Mobility/Persistence Factor Value × Hazardous Waste Quantity Factor Value) × 

Ecosystem Bioaccumulation Potential Factor Value: 1 × 1012

Based on the Waste Characteristics Factor Category Value (1 × 1012) and HRS Table 2-7, the Waste 

Characteristics Factor Category for the Watershed is 1,000 [1, p. 51592 (Section 2.4.3.2, Table 2-7)]. 

Waste Characteristics Factor Category Value [1, Table 2-7]: 1,000
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Environmental Threat – Targets

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4.2.4.3 Environmental Threat Targets

On 5 A pril 2013, VT ANR DEC District Wetlands Ecologist and START examined and documented the 

wetland area along the Jard SWP extending downstream of the PPE to Furnace Brook (see Figure 6B) [4, pp. 

19-21; 12, pp. 1, 3 -4]. The results of the wetland delineation activities indicated that the shape of the wetland 

area delineated by North Country Ecological Services in June 2002 w as generally consistent with what was 

observed in the field in April 2013 [4, pp. 20-21; 12, p. 3]. During delineation activities in April 2013, various 

wetland types were identified and documented within this wetland area [4, p. 20; 12, p. 3]. The VT ANR DEC 

District Wetlands Ecologist noted that there were HRS-eligible wetland fringes [Palustrine Emergent Marsh 

(PEM) and Palustrine Scrub-Shrub (PSS)] lining the banks of the Unnamed Stream on Property P030, located 

west of Park Street and west-northwest of the Jard property [4, pp. 20-21; 12, pp. 4]. The results of the wetland 

delineation documented the presence of continuous HRS-eligible (PEM) wetlands on both sides of this stream 

segment, between the point where the Unnamed Stream flows onto Property P030 and the most downstream 

sediment sample location, SD-49 [4, pp. 20, 71; 12, p. 4]. The calculated wetland perimeter frontage 

downstream of the PPE along this segment is 0.2546 miles [12, p. 4]. 

On 5 April 2013, the VT ANR DEC District Wetlands Ecologist and START also evaluated the “Background 

Wetland” located to the northeast of the Jard property [4, pp. 20 -21; 12, p. 1] . This wetland area had been 

previously documented on the United States Fish and Wildlife Service (USFWS) National Wetland Inventory 

(NWI) map as P SS1B (Palustrine Scrub-Shrub Broad-Leaved Deciduous Saturated) and on Vermont 

Geographic Information System (GIS) documents as VT ANR Class 2 Wetlands and Hydric soil areas [4, p. 21; 

12, pp. 2 -3]. The District Wetlands Ecologist and START personnel identified and outlined eligible HRSeligible wetland types with wetland characteristics similar to those identified in the release wetland area located 

on Property P030 [4, p. 21; 12, pp. 2, 6]. 

On 16 April 2013, as part of the EPA SR and in accordance with the EPA-approved February 2013 Site-Specific 

QAPP, eight sediment samples (SD-31A, SD-32A, SD-36A, SD-39A, SD-41A, SD-46A, SD-47A, and SD49A) were collected along the Jard SWP [4, pp. 56-58; 9, pp. 1, 29-32, 39; 18, pp. 25, 27, 31, 35, 37, 43, 44, 48]. 

Analytical results of four of those sediment samples (SD-49A, SD-47A, SD-46A, and SD-41A) document an 

observed release of PCBs (analyzed as Aroclor 1242) to the HRS-eligible wetland along the Unnamed Stream 

west-northwest of the Jard property [4, pp. 56-57, 64; 12, pp. 3-4, 14; 18, pp. 37, 43, 44, 48; 75, pp. 9-10; 84, pp. 

8-9, 76, 79, 84-85; 102, p. 5]. Sediment sample SD-49A was collected at a location 0.308 miles downstream of 

the most upstream PPE for the SWP [102, pp. 2, 5 ]. The analytical results of each contaminated sediment 

sample were compared to the contaminant concentrations detected only in those background sediment samples 

which displayed the most similar matrix composition [78]. As noted above in Section 4.2.1.3. of this HRS 

Documentation Record, Aroclor 1242 was detected in sediment samples SD-41A, SD-46A, SD-47A, and SD49A at concentrations above each sample-adjusted CRQL, and above the background concentrations established 

by analytical results of background samples (SD-51A, SD-51C, SD-52C, SD-54C), thereby establishing an 

observed release of PCBs (analyzed as Aroclor 1242) to the SWP via chemical analysis [1, p. 51589 (Table 2-3); 

75, pp. 9-10; 76, p. 8 ; 77, pp. 8-9; 84, p. 8, 9, 76, 79 , 84, 85; 85, pp. 4-5, 47]. For the purposes of this HRS 

Documentation Record, only the downstream wetland perimeter frontage extending from the point where the 

Unnamed Stream flows onto Property P030 (0.0105 miles upstream of SD-41) to sediment sample location SD49A is evaluated to document actual contamination to greater than 0.1 miles of wetland perimeter frontage. 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Environmental Threat – Targets

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Table 36 – Contaminated Sediment Samples and Benchmark Concentrations

Sample 

ID

Sample 

Medium

Hazardous 

Substance

Hazardous 

Substance 

Concentratio

n 

(μg/Kg) 

Benchmark 

Concentration Benchmark References

SD-41A 

(A4C04) Sediment 

PCBs 

(Aroclor 1242) 250 N/A N/A

2, p.2; 18, p. 37; 

75, p. 9; 84, pp. 5, 

8, 79 

SD-46A 

(A4C10) Sediment 

PCBs 

(Aroclor 1242) 220 N/A N/A

2, p.2; 18, p. 43; 

75, p. 10; 84, pp. 

6, 9, 85 

SD-47A 

(A4C09) Sediment 

PCBs 

(Aroclor 1242) 87 N/A N/A

2, p.2; 18, p. 44; 

75, p. 10; 84, pp. 

6, 9, 84 

SD-49A 

(A4C01) Sediment 

PCBs 

(Aroclor 1242) 320 N/A N/A

2, p.2; 18, p. 48; 

75, p. 9; 84, pp. 5, 

8, 76 

N/A = Not Applicable. 

The observed release to sediment from sources associated with the Jard property is established by sediment 

sample analytical results [1, p. 51589 (Table 2-3); 75, pp. 9-10; 76, p. 8; 77, pp. 8-9; 84, pp. 5, 6, 8, 9, 76, 79, 

84, 85; 85, pp. 4-5, 47]. Sensitive environments that are determined to be actual contamination targets based on 

sediment sample analytical results, but for which no ecological-based benchmarks are applicable, are evaluated 

as subject to actual contamination at Level II [1, p. 51625 (Section 4.1.4.3.1)]. 

Most Distant Level II Sample

Sample ID: SD-49A 

Distance from the probable point of entry: 0.3080 miles 

Reference: 102, pp. 2-3 

4.2.4.3.1 Sensitive Environments

4.2.4.3.1.1 Level I Concentrations

Level I Sensitive Environment Targets

The observed release to sediment from sources associated with the Jard property is established by sediment 

sample analytical results (see Section 4.2.1.3). No Level I sensitive environments have been identified.

Sum of Level I Wetland Frontages: 0
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Environmental Threat – Targets

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Wetland Value [1, Table 4-24]: 

Sum of Level I Sensitive Environments Value + Wetlands Value: 0

(Sum of Level I Sensitive Environments Value + Wetlands Value) x 10: 0 

Sum of Level I Sensitive Environments Value: 0

Level I Concentrations Factor Value: 0

4.2.4.3.1.2 Level II Concentrations

Level II Sensitive Environment Targets

One sensitive environment, an HRS-eligible wetland located along the Unnamed Stream, west of the Jard 

property and extending to sediment sample location SD-49, which was determined to be an actual contamination 

target based on chemical analysis of sediment samples, is evaluated at Level II concentrations [1, p. 51644 

(Section 4.2.4.3.1)]. An observed release to sediment from sources associated with the Jard property has been 

established for the documented wetland located along the Unnamed Stream, which encompassed 0.2546 miles 

of wetland perimeter frontage downstream of the PPE [12, p. 4; 75, pp. 9-10; 76, p. 8; 77, pp. 8-9; 84, pp. 8, 9, 

76, 79, 84, 85; 85, pp. 4-5, 47; 86, pp. 7-8, 93, 95-96, 98]. No other sensitive environments were evaluated along 

the TDL for the surface water migration pathway for the Jard site.

Level II Wetland Frontages 

Based on the results of the 5 April 2013 wetland delineation activities completed by VT ANR DEC District 

Wetlands Ecologist and START personnel, there are 2.36258 acres of HRS-eligible wetlands (PEM and PSS) 

[in accordance with the definition of a wetland presented in 40 Code of Federal Regulations (CFR) 230.3] 

located on the undeveloped property (identified as P030) located west of the residential properties along Park 

Street and along the Unnamed Stream, extending from 0.0105 m iles upstream of SD-41A to 0.0254 miles 

downstream of sediment location SD-49 [1, p. 51625 (Section 4.1.4.3.1.1, Table 4-24); 4, p. 20; 12, pp. 2-4, 35; 

102, pp. 1 -2]. In addition, the VT ANR DEC District Wetlands Ecologist noted that there were possibly 

additional wetland areas located on property P030 and along portions of the Unnamed Stream upstream of the 

eastern border of P030 to the PPE and sediment sample point SD-30 [4, p. 20; 12, p. 4]. The VT ANR DEC 

District Wetland Ecologist noted that more extensive investigation would be required to document the possible 

HRS-eligible wetlands [1, p. 51625 (Section 4.1.4.3.1.1, Table 4-24); 4, p. 20; 12, p. 4]. Field observations by 

the VT ANR DEC District Wetlands Ecologist indicated that HRS-eligible wetlands, specifically PEM and PSS, 

border both sides of the Unnamed Stream channel from 0.0105 miles upstream of SD-41 to 0.0246 m iles 

downstream of sediment location SD-49 [12, pp. 4, 6; 4, p. 20; 102, pp. 1-2]. The documented HRS-eligible 

wetland perimeter frontage encompassing the channel downstream of the PPE (Greene Pond – SD-30 and SD31) to sample location SD-49A is 0.2546 miles in length [12, p. 4]. For the purposes of this HRS Documentation 

Record, only the HRS-eligible wetlands located along the Unnamed Stream channel between 0.0105 miles 

upstream of SD-41 (P030 property boundary) to 0.0246 miles downstream of sediment location SD-49, located 

west of the Jard property, and subject to actual contamination are evaluated to document actual contamination to 

greater than 0.1 miles of wetland perimeter frontage. 

PCBs (analyzed as Aroclor 1242) were detected at concentrations documenting an observed release in four 

sediment samples (SD-41A, SD-46A, SD-47A, and SD-49A) collected from the downstream wetland located 

along the Unnamed Stream and extending to 0.0105 miles upstream of SD-41 [1, p. 51588 ( Section 2.2.2), p. 

51609 (Section 4.1.2.1.1); 12, pp. 4; 75, pp. 9-10; 76, p. 8; 77, pp. 8-9; 84, p. 5, 6, 8, 9, 76, 79, 84, 85; 85, pp. 4-

5, 47; 102, p. 1]. An HRS-eligible wetland perimeter frontage of 0.2546 miles is documented as a Level II actual 

observed release environmental target [1, pp. 51589 (Table 2-3), 51625 (Section 4.1.4.3.1); 12, p. 4]. 
Surface Water Migration Pathway 

Ground Water to Surface Water Component 

Environmental Threat – Targets

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Table 37 – Sensitive Environment Value

Sensitive 

Environment

Distance from PPE 

to Nearest Sensitive 

Environment References

Sensitive Environment 

Value

[1, Table 4-23] 

Wetlands

(Unnamed Stream) 0.1800 miles 

1, pp. 51624 (Table 4-23), 

51625 (Section 4.1.4.3.1.2); 102, 

p. 2 N/A*

* In accordance with HRS Section 4.1.4.3.1.2, for those sensitive environments that are wetlands, assign 

an additional value from HRS Table 4-24 [1, pp. 51624 (Table 4-23), 51625 (Section 4.1.4.3.1.2)]. 

Sum of Level II Sensitive Environments Value: 0

Level II Wetland Frontages

Table 38 – Wetland Frontage Value

Wetland 

Wetland Frontage

(miles) References

Wetland Value 

[1, Table 4-24] 

Wetlands

(Unnamed Stream) 0.2546 

1, p. 51625 (Section 4.1.4.3.1.2, 

Table 4-24); 12, p. 4 25 

 Sum of Level II Wetland Frontages: 0.2546 miles 

Wetlands Value (Ref. 1, Table 4-24): 25 

Sum of Level II Sensitive Environments Value + Wetlands Value: 25

Level II Concentrations Factor Value: 25

4.2.4.3.1.3 Potential Contamination

Potential Sensitive Environment Targets: Not Evaluated

Potential Contamination Factor Value: Not Scored