EPA
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01-84/006
September 1984
Superfund
Record of Decision:
Western Sand & Gravel
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TECHNICAL REPORT DATA
(Please read Instructions on the revene before completing)
,. REPORT NO. \2. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/ROl-84!006
4. TITLE AND SUBTITLE 5. REPORT DATE
SU~ERFUND RECORD OF DECISION: !nQ/?R/R.1
Western Sand & Gravel Site, RI 6. PERFORMING ORGANIZATION CODE
7. AUTHORIS) 8. PERFDRMING ORGANIZATION REPORT NO.
'.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
1,. CONTRACT/GRANT !'Io.
. 12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. 14. SPONSORING AGENCY CODE
Washington, D.C. . 20460 800/00
.
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This semi-rural site has been a sand and gravel mining operation owned by
Western Sand and Gravel, Inc., since 1953. In 1975 approximately 12 acres of the
20-acre site were used for the disposal of 480,000 gallons of liquid wastes, in-
cluding chemicals and sewage waste. These wastes were dumped into unlined lagoons
and seepage pits. Ground water contamination has occurred at the site and a plume
of contamination is moving towards domestic wells adjacent to the site.
The selected cost-effective remedial alternative includes: the installation
of a permanent alternate water supply to service approximately 56 parcels of land,
and the installation of carbon canister filters as a temporary abatement measure
for 8 homes with contaminated wells until the permanent water supply is functional.
Key Words: Cost Factors; Fire ProtectioniWaterSupply System; Alternate
Concentration Limit (ACL); Ground Water contamination; RCRA;
Enforcement; Negotiated Settlement; Ground Water. Cleanup;
Ground Water Strategy
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Western Sand & Gravel Site, RI
Contaminated media: gw, soil
Key contaminants: VOCs, solvents, TCE,
acids
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None
EPA Form 2220-1 (Rn.4-77)
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AUTHOR(S)
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Include a brief (200 words 0' less) factual summary of the most signiti~.itnt informalion ~'ontail1l'd III "". ,,'pml. II Ih,' 1"pOl' ,'OIllalll' a
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ROD ISSUES ABSTRACT
Site:
Western Sand and Gravel, Inc.
Burrillville, Rhode Island
Region:
I
AA, OSWER
Briefing Date:
June 25, 1984
SITE DESCRIPTION
This semi-rural site has been a sand and gravel mining operation
owned by Western Sand and Gravel, Inc., since 1953. In 1975
approximately 12 acres of the 20-acre site were used for the disposal
of 480,000 gallons of liquid wastes, including chemicals and sewage
waste. These wastes were dumped into unlined lagoons and seepage
pits. Ground water contamination has occurred at the site and.a plume
of contamination is moving towards domestic wells adjacent to the site.
SELECTED ALTERNATIVE
The selected cost-effective remedial alternative includes: the
installation of a permanent alternate water supply to service
approximately 56 parcels of land, and the installation of carbon
canister filters as a temporary abatement measure for 8 homes with
contaminated wells until the permanent water supply is functional.
ISSUES AND RESOLUTIONS
1.
The alternate water supply system will provide
capacity for fire protection, based on current
demand, because of the minimal additional cost.
2.
Although the final remedial action will
provide for source control measures, the
ground water in the vicinity of the site
will remain contaminated. The selected
remedial measure (alternate water supply)
will abate the public health risk associated
with the contaminated ground water and the
RI/FS indicates that there will not be
adverse impacts to ground water receptors.
If CERCLA actions are required to be in
-2-
KEY WORDS
. Cost Factors
. Fire Protection
. Water Supply
System
. Alternate
Concentration
Limi t (ACL)
. Ground Water
Contamination
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Western Sand and Gravel, Inc., Rhode Island
June 25, 1984
Continued
ISSUES AND RESOLUTIONS
conformance with the technical provisions of
RCRA, corrective action must be taken to
address the remaining contaminated ground
water or an Alternate Concentration Limit
(ACL) established. The Region submitted a
proposal for an ACL at the site. It was
determined that there was insufficient data
to warrant an ACL at this time.
5.
The negotiated eighty percent settlement will
be rejected because additional ground water
investigation and possible future remedial
actions may be required to mitigate the con-
taminated ground water.
6.
Since this ROD did not address all the ground
water issues pertaining to site closure,
a future ROD will be prepared for Western
Sand and Gravel to focus on the cost impli-
cations and technical considerations for
cleanup of the contaminated ground water.
This ROD will also incorporate the Agency's
ground water strategy into the recommended
alternatives.
-3-
KEY WORDS
. Enforcement
. Negotiated
Settlement
. Ground Water
Cleanup
. Ground Water
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..
site:
. ~...._---
R ECOO D OF DECIS ION
REMEDIAL ALTERNATIVE SELECTION
Western Sand and Gravel
Burrillville. Rhode Island
. -
DOCUMENTS REVIEWED:
-.- -' .-.- -. - .-.-" ....- -- '. _. - -----
I am basing my decision primarily on the following documents
describing the analysis of cost-effectiveness of remedial
alt@.rnatives for the Western Sand and Gravel Site:
o
~emedial Investigation/Feasibility Study for Western
Sand and Gravel, Arthur D. Little, Inc., May 22, 1984.
o
Remedial Investigation/Feasibility Study for Western
Sand and Gravel. Arthur D. Little Inc., January 31, 1984.
Remedial Investigation/Feasibility Study for Western
Sand and Gravel, Arthur D. Little. Inc. October 5, 1983.
o
o
Test pit Explorations, Goldberg-Zoino and Associates,
June 1981.
o
Lettp.r from Philip P. Virgadamo of Environmental Resources
Associates, Inc. to Christine J. S padafor, EPA Region I
site Manager, April 9, 1984.
o
Staff summaries and recommendations.
o
Responsiveness summary dated June 1984.
DES CR I PTION OF S ELECTED OPTIONS:
~.__._._- - - ..--'---- .------.- --- ---.- ----. - - ---- _.--
o
Installation of water filters as an Initial Remedial
Measure to provide protection for homes with contaminants
identified in their wells, until the permanent alternate
water supply is functional.
o
Installation of a permanent alternate water supply to
service approximately 56 parcels of land.
DECLARATIOf15 :
--------
Consistent with the comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), and the
National Contingency Plan (40 CFR Part 300), I have determined
that the remedial action providing for a permanent water supply
at the Western Sand and Gravel site is a cost-effective remedy
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-2-
the environment. with respect to present drinking water
contamination. I have also determined that the installation
of filters on individual homes as an initial remedial measure
is a cost effective remedy and provides adequate protection
of public health, welfare, and the environment. The State
of Rhode Island has been consulted and agrees with the.approved
remedy, since it is consistent with the conditions that the
State believes are appropriate for this site. In addition,
some actions will require future operation and maintenance
activities to ensure the continued effectiveness of the remedy.
These activities will be considered part of the approved action
and eligible for Trust Fund monies for a period not to exceed
one year.
I have also determined that the action being taken is
appropriate when balanced against the availability of Trust
Fund monies.used at other sites. In addition, the agency will
authorize the. collection of additional contamination and ground
water data necessary to characterize the requirements of source
control and site closure.
~PA will also undertake an additional study to evaluate
alternative ground water corrective actions. If additional
remedial actions are determined to be necessary, a Record of
Decision will be prepared for approval of the future remedial
action.
--~7j~~' Qi_-
Date
~_\~j~~_:_------- -----
Lee M. Thomas
Assistant Administrator
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SUMMAR Y OF REMEDIAL ALTERNATIVE SELECTION
Western S and and Gravel
Burrillville, Rhode Island
SITE HIS TCR Y AND DES rn I PTION
--
The Western S and and
Rhode Island, adjacent to
. line of North Smithfield.
a gravel mining operation
and operated by Mr. James
Gravel site is located in Burrillville,
the Douglas Pike and close to the town
Historically, this semi-rurai site was
owned by Western Sand and Gravel, Inc.,
Cardi since about 1953.
Bp.ginning in about 1975, approximately 12 acres of the 20
acre site were used for the disposal of liquid wastes, including
chemicals and sewage waste (see Figure 1). Wastes were dumped
into four chemical lagoons and eight or more seepage pits. All
lagoons and pits were unlined. The waste pits and lagoons were
80 to 100 feet long, 18 to 20 feet wide and 8 to 10 feet deep.
The wastes subsequently infiltrated into the soil, percolating
through the highly permeable soils into the groundwater.
There are approximately 56 parcels of land within 1/2 mile
of the site affected or potentially affected by the contaminants
migrating off-site. The Remedial Investigation/Feasibility Study
(RI/FS) determined that ground water has been contaminated by
hazardous waste at the site and is moving in a northerly direction
to domestic wells adjacent to the site. There are approximately
600 persons that are served by groundwater via private drinking
wells within a one mile radius of the site. The contaminated
ground water also discharges into both the Tarkiln Brook and the
Slatersvi11e Reservoir. The Reservoir is used for recreational
purposes and is not a source of drinking water. However, the
site does overlie the Slatersville Aquifer, a major ground water
aquifer for the State of Rhode Island.
In May of 1975, the Rhode Island Department of Health approved
a request by Mr. Cardi to dispose of sewage waste in two trench~s
at Western Sand and Gravel. These operations continued and were
initially monitored by the Rhode Island Division of Solid Waste
Management in March 1976. In November 1976, a chemical pit was
identified during a site inspection by the Rhode Island Division
of Solid Waste Management, and acid wastes were observed being
disposed of during a subsequent site visit in January 1977. A
fire occurred in one of the chemical pits in March 1977, and
officials from the Burril1ville and North Smithfield Fire Depart-
ments ordered Mr. Cardi to remove the chemicals from the site.
Mr. Cardi responded by burying the contents of the chemical
lagoon. During the period of April through August 1977, there
were a series of State court hearings held related to Mr. Cardi's
violations of guidelines for the disposal of septic tank and
cesspool wastes. Also, the State received complaints from nearby
residents, regarding chemical odors emanating from the Western
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APPROXIMATE
LOCATION
OF PLUME
/
,
I /
I /
I /
/ /
/
PORTION OF
SITE ENLARGED
TO SHOW DETAI.
FIGURE 1 .
WESTERI SAND AID GRAVEL
HYDROGEOLOGIC SETTING
SLATERSVIlLE
AQUifER
TRANSMISSIVITY
5000.8000 FT1IDAY
LEGEND /
. SWOGE' ./ ./
m MIXED SOIl . SLUDGE
e SOl. . TRACE AMOUNTS OF SLUDGE
-5 /
/ . iii SURFACE CONTAMINATION
/
APPROX"ATE LOCATIONS
. CONTAMIIATED DOMESTIC MllS
. MONITOMIIG MllLOCATIONS
. SURFACE SAMPlING WCATIONS
DOUGLAS PtIlE
\
400
I
o
I
SCALE
400 n.
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-2-
The Rhode Island Department of Environmental Management (OEM)
was formed in October 1977 and this agency forwarded emergency
industrial waste regulations to Mr. Cardi in December 1977.
Mr. Cardi responded to these regulations by notifying OEM in March
1978 that the site was an industrial waste disposal site.. There
was no further regulatory activity (other than inspections) during
the remainder of 1978.
In January 1979, concern of local residents and State officials
over the site resulted in a joint meeting of the Burrillville and
North Smithfield town councils to discuss the operations at the
site. Private domestic wells in the area of the site were sampled
by the Rhode Island Department of Health for contamination and in
February 1979, a Notice of Violation Order was sent to Mr. Cardi
by OEM. A Cease and Desist Order was issued by OEM on April 24,
1979, for among other things, violation of water and air pollution
regulations, and odors. Hearings on the Order were held in May
and June 1979.> Also, the towns of Burril1ville and North Smithfleld
declared tnRt thp Slatersvil1e Aquifer had become contaminated by
wastes migrating from the site. Six ground water monitoring wells
were installed by Western Sand and Gravel under a consent agreement
with OEM and tested during November 1979. Analyses of the samples
showed the presence of toluene, xylene, chloroform, l,l,l-trichloro-
ethane, trichloroethylene, tetrachloroethylene and dichloromethane.
In the same time period OEM issued a consent decree, a show cause
order on closure, and a final closure order for pumping the chemical
wastes from the lagoons.
In 1979, hazardous wastes were no longer accepted at the site.
State industrial waste manifests were kept for materials deposited
at the site from May 1978 to April 1979. The manifests show
approximately 470,000 gallons of waste deposited at the site curing
that one year period. The quantity of wastes deposited at the site
prior to May 1978 is unknown.
In March 1980, personnel from the EPA Environmental Services
Division, on request from OEM, pumped the lagoons and began removal
of the hazardous material. It is estimated that approximately
60,000 gallons of liquid materials were removed. These actions
w~re taken under the authority of Section 311 of the Federal Water
Pollution Control Act. as amended.
In December of 1983. the ground water recirculation system
installed by the State of ~hode Island in November 1982. with
the intent of controlling the migration of hazardous wastes from
the site, malfunctioned, causing an overflow of between 50 and
250 gallons of waste material from an underground 10,000 gallon
capacity tank. The Rhode Island Department of Environmental
Management immediately took action to clean up the spill and
disposed of the contaminated spill debris at its expense. OEM
then notified the EPA Environmental Services Division and requested
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-3-
samples of aqueous and non-aqueous materials from the underground
tank were sampled. In addition, the Department of Environmental
Management excavated and removed from the site twelve drums of
soil that were contaminated because of the overflow and replaced
one of the system's pumping wells. .. .
CURRENT STATUS
.. A.
Quantity, Types and Concentrations of Hazardous Substances
The RI/FS for the Western Sand and Gravel site was conducted
by Arthur D. Little, Inc. The exact quantity and types of waste
deposited at the site are unknown. In addition, it is not certain
when hazardous wastes were first deposited there. Therefore, it
is not possible to determine the maximum possible amounts of wastes
dumped at the site. However, based on information provided by the
Rhode Island .Department of Environmental Management manifests,
approximately 470,000 gallons of wastes were disposed of at the
site during 1978-1979, with a monthly average of 36,000 gallons.
YEAR
MONTH
GALLOt-S
1978
May
June
July
August
September
October
November
December
January
February
March
April
TOTAL
10,000
. 22,700
5,300
40,600
52,500
28,100
23,100
32,750
51,400
58,300
63,800
79,000
467,750
1979
A priority pollutant analysis of hazardous wastes in the lagoons
provided the following information on the types and concentrations
of the substances present (results in ug/l or ppb). Prior to the
pumping out of the lagoons, they were sampled at the surface and
the bottom (sediments). Leachate run-off from the lagoons was
also sampled.
Volatiles
Surface
( ug/l)
5 ed iments
(ug/l)
Methylene chloride
1,1-Dich1oroethylene
Trichlorofluoromethane
1,2-Dichloroethane
1,1,1-Trichloroethane
1,1-Dichloroethane
Trichloroethylene
19,000
340
730
1,200
230,000
4,700
140,000
23,000
Leachate
---cug,7l)
30
460,000
7,500
550,000
66
24
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-4-
Volatiles (Cont.)
5 urface
5 ~diments
Leachate
--- --.---
Benzene
1,1,2,2-Tetrachloroethylene
Toluene
Ethylbenzp.ne
Chlorobenzene
69
280,000
24,000
68,000
970
91,000
7,200
23,000
.::.
17
2
230
13
2.8
Acids
.- .-- --
o-Ch 1 orophenol
Phenol
4-Chloro-m-cresol
4,6-Dinitro-o-cresol
540
980
1,000
940
160
_.- - --------. -----
Base Neutrals
Naphthalene'
Anthracenp.
pyrene
Fluoranthene
Chrysene
Butyl benzylphthalate
7,800 2,900
1,600 360
440 110
210 230
490 170
47,000 14,000 24
10 42 0.2
Detection Limits
B.
Extent of Contamination
There are three primary sources of contamination at the Western"
Sand and Gravel site. These include the contaminated ground water
plume located primarily in the northwest quadrant of the site but
extending in a northerly direction toward the Slatersville"Reservoir,
chemical sludges found in the unsaturated zone at several locations
on the site, and non-aqueous phase liquids (not soluble in water)
that are primarily in the area near the existing ground water recir-
culation system. It is estimated that 3,818 cubic yards ot sludge
and sludge contaminated soils remain on site, as well as 582 cubic
yards of contaminated surface material (contained within the surface
areas to a depth of 6 inches) 1573 cubic yards of contaminated
soil below the sludge in the unsaturated zone (these soils are
contaminated by the overlying sludge and less viscous materials),
and approximately 17,000 cubic yards of contaminated soils located
in and around the waste handling areas. These numbers were
calculated as follows (quantities were derived from the RI/FS
unless otherwise noted and include a 30% contingency)~
Sludge & Sludge Contaminated Soil
LOCATION
VOLUME (yd3)
.----- -
---
plus
Pit 11 (Area A inRI/FS)
Pit 2 (Area B in RI/FS)
Area C inRI/FS
additional GZA calculations
Area E in R I/FS
TOTAL
145
30
233
2210
1200
.38-fs
(R I/FS )
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-5-
The R I/FS estimated a total of 1600 yd3 of contaminated
sludges. The Goldberg-Zoino (GZA) report estimates between 2000
and 4000 yd3 total contaminated sludges. The GZA report appears
to be more accurate in its calculations for the amount of sludge
on site, as the-GZA investigation done in support of the~report
included numerous test pit explorations in an area not able to
be investigated by the RI/FS contractor due to placement of the
- -ground wa ter rec i rcula t i on sys tem. Based on the GZA report as a
supplement to the RI/FS, the amount of sludge remaining on-site
is calculated to be 3820 yd3, which includes a 30% contingency
for sludge-contaminated material located next to the sludges
(hereafter referred to as the visibly contaminated soils).
LOCATION
S DR FACE MATER IAL
VOLUME (yd3)
----..-.--
Pit 1.1
Dit 2
Area F in RI/FS
160
22
400
TOTAL
582
CONTAMINATED SOIL TO SATURATED ZONE
LOCATION VOLUME (yd3)
------- .-- ----.-
Pit 11 350
Pit 2 48
.a.rea C in R I/FS 1175
TOTAL -Y5-1-j-
CONTAMINATED WAS TE HANDLING AREAS
LOCATION
VOLUME (yd3)
_. .- - -- - .
_.- --.- ---
Area D in RI/FS
Area G in R I/FS
1,070
17,000
TOTAL
18,070
The contaminated ground water plume is migrating in a northerly
direction and has intersected monitoring wells at depths ranging
from 45 to 75 feet below ground level.
C.
Pathways of Migration
The contaminants leaving the Western Sand and Gravel site are
migrating primarily via ground water and surface water. Contaminants
are entering drinking water wells, the Tarkiln Brook and the Slaters-
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-6-
The ground water flow in the area of the Western Sand and
Gravel site occurs principally in the unconsolidated deposits and
in fractured portions of bedrock. Measured depth to ground water
ranges from approximately 4 feet to 30 feet. The thickness of
unconsolidated material is variable beneath the disposal site and
generally parallel to the Tarkiln Brook. The lower portion of
unconsolidated deposits is slightly more permeable than the upper
.portion.
The contaminated ground water flow at Western Sand and Gravel
discharges to the Slatersville Reservoir and Slatersville Aquifer.
The hydrogeologic conditions downgradient from the site are such
that this flow is partitioned with approximately 80% discharging
directly to the Reservoir and 20% recharging the Slatersville
Aquifer that ultimately discharges to the Reservoir (partitioning
based on an evaluation of the horizontal and vertical hydraulic
gradients in areas adjacent to the Reservoir). The contaminant
loading to the ~eservoir is approximately 3 gallons per day of
volatile organics, assuming a ground water flow of 9000 gallons/day
with a worst case volatile organic content of 410 ppm, based on
monitoring well observations. Based on modeling, the dilution
capacity of the Reservoir in the area of the contaminated discharge
was estimated at 30 million gallons, yielding an effective concen-
tration of 0.10 ppm of total volatile organics. The concentration
of specific chemicals would be appreciably lower. Approximately
0.7 gallons per day of volatile organics would flow to the Aquifer,
which in turn discharges to the Reservoir.
Estimates of hydraulic properties of the stratified drift on
site include hydraulic conductivity that ranges from 12 to 90 feet
per day and porosity that ranges from 0.20 to 0.35. These in
combination with hydraulic gradient estimates of 0.002 to 0.003
yields a transport velocity range of 0.2 to 1.5 feet per day.
Test drilling results indicate that the upper portion of the
bedrock is fractured and is a path for ground water flow. The
estimated hydraulic conductivity is one foot per day and porosity
is 0.01 (1%) for the fractured bedrock.
D.
Actual or Potential Affected Receptors
There are both human and environmental receptors that are
currently or potentially exposed to contaminants migrating from
the Western Sand and Gravel site. The primary receptors are the
individual residents downgradient from the site whose drinking
water wells have already or may potentially become contaminated
with hazardous chemicals. Currently, nine homes have shown
contamination of private drinking water wells at least one time
during their sampling history. The highest levels detecteo in
the private wells are within the National Interim Primary Drinking
Water Standards for noncarcinogens. However, the levels are in
excess of a 10-6 excess cancer risk. The levels detected and
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-7-
Contaminant
Level
10-6 Excess Cancer Risk
-----
1,1,1 - trichloroethane
6 ppb
being investigated by
EPA Cancer Assessment Group
for carcino~enic properties
. -
trichloroethylene
5 ppb
8 ppb
2.8 ppb
0.9 ppb
..' tetrachloroethylene
1,2 - dichloroethane
21 ppb
2 ppb
0.95 ppb
1,1 - dich10roethane
carcinogenic properties
suggested in animal studies
dichloromethane
18 ppb
0.19 ppb - cancer risk
based on chloroform, a
suspected carcinogen
In addition, based on the extent and directional flow of the
plume and monitoring observations, it is expected that more private
wells will exhibit contamination in the future, although (because
of the nature of the subsurface conditions, i.e. a ground water
flow gradient down into fractured bedrock) it is difficult to
predict precisely which of the existing and potential future wells
in the threatened area will actually become contaminated. It is
also difficult to predict how long a given well is likely to remain
contaminated. While the ingestion of contaminated drinking water
poses a current and future public health risk, the current and
projected use of the Reservoir indicates there is no acute or
chronic public health risk associated with exposure to surface
water in the Reservoir.
In the vicinity upgradient from the majority of residential
wells, yet within the contaminated ground water plume, is ground
water monitoring well GZ-l. Because of the location of GZ-1, it
provides information on the horizontal and vertical extent of
contamination and was used as an indicator well for possible future
impacts on the residential wells.
Contaminant
Level (ppb)
GZl-2* GZl-3**
10-6 Excess
Cancer Risk (ppb)
Draft
S NAR L J~J-
7
1,1-dichloroethylene
10
14
l,l-dichloroethane
184
226
carcinogneic proper-
ties suggested in
animal studies
trans-1,2-dichloroethylene 398
202
-------
1,1,1-trichloroethane
-8-
2
12 66
0.95
1,2-dichloroethane
being investigated
for carcinogenic
properties
1000(HA)
,; -
chlorobenzene 23 64
. be nzene 10 38
toluene 87 440
ethy1benzene 32 190
xylene 120 720
chloroethane 2
20 ( ° )
0.68
340
620
*GZl-2 is 45'feet below surface
**GZl-3 is 74 feet below surface
***lO-day EPA Draft Suggested No Adverse
(HA) Health Advisory .
(0) based on organoleptic properties,
EPA Ambient Water Quality Criteria
Response Leve Is (S NAR IS )
Recent monitoring results from this well indicate an increase
in the concentration of hazardous substances in the contaminant
plume. It is believed that this increase will begin to be
reflected as increased contaminant levels in residential wells.
Based on the available residential and ground water well data
coupled with the determined location and migration of the contamin-
ated ground water plume, a threat to public health is determined
to exist, as evidenced by contaminant levels above the 10-6 excess
cancer risk. In addition, in the absence of established formal
drinking water standards or maximum contaminant limits for the
substances cited in the table immediately above, EPA believes that
the draft SNARL's (prepared by EPA's Office of Drinking Water for
advisory purposes), although not enforceable regulations, provide a
reasonable indication that the levels of certain contaminants found
in well GZ-l may be of concern. Even with complete removal of the
contaminant source, it would take at least 15 years and probably
longer for contaminant levels at GZ-l to decrease to safe levels.
Direct contact is another route of exposure of concern at this
site. The site has been used for dirt biking and for pet runs, as
well as being in close proximity to the sand and gravel operations
located on the property.
Other receptors include the biological flora and fauna found in
the Tarkiln Brook and Slatersville Reservoir including piCkerel,
blue-gill, and bass living in the Reservoir. However, the quantities
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-9-
below those associated with aquatic toxicity. In addition, small
game including rabbits and squirrels have been observed in the
area and may be exposed to the contaminated waters of Tarkiln
Brook. The remedial investigation indicated that these species
are not being impacted by the contaminated surface flow. The U.S.
Department of the Interior (001) stated in its prelimin~ry natural
resources evaluation of the site that no lands, minerals, waters
or Indian resources under DOl's trusteeship have been damaged by
- releases of hazardous substances and that the current existing
risk to 001 trust resources is relatively low. Monitoring data
from April 1984 indicate that concentrations of hazardous substances
within the Tarkiln Brook decrease with distance downstream, owing
in part to dilution effects.
The five surface water samples collected (one up-stream from
the site, two adjacent to the site, one in the swamp and one at
the confluence where the Tarklin Brook and Reservoir meet) represent
the most recent surface water monitoring data. All samples measured
at non-detectable levels except for one sample taken adjacent to
the site. According to the RI/fB, the levels detected in that
sample do not pose an acute toxic hazard to aquatic and terrestrial
species.
The levels of contamination projected in Tarkiln Brook and the
Slatersville Reservoir do not pose an acute toxic hazard to aquatic
and terrestrial species. Also, the concentrations of contaminants
discharging to the Slatersville Aquifer are below any levels associ-
ated with immediate risk to flora and fauna.
ENFORCEMENT
On February 7, 1984, a meeting attended by 49 of the 91
potentially responsible parties (PRPs) was held in Boston, MA, to
begin negotiations in order to determine whether any responsible
party was willing and able to undertake remedial design and
construction. Negotiating meetings were conducted with the
steering committee representing approximately 45 PRPs on March 20;
April 11: May 3; May 16 and May 30, 1984. On April 4, 1984, EPA
met with a technical representative of the steering committee to
discuss comments on the RI/FS. EPA does know that 17 of the 20
largest contributors (by volume) are represented by the steering
committee. A negotiation schedule was developed requiring the
parties to commit by May 30, 1984, their willingness to undertake
the remedy. On May 30, 1984, the PRPs made an offer and EPA
responded with a counter-offer requiring implementation of the
remedy outlined in this document and repayment of most post-CERCLA
expenditures. In light of the imminence of settlement and
delay in the ROD briefing from June 14 to June 25, EPA extended
its negotiation deadline until June 15, 1984. On June 22, 1984,
the PRP's offered the agency a cash settlement of approximately
S2.23 million, representing 80% of the Agency's costs. This
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-10-
financial risks, because the proposed settlement would leave 20%
of EPA's costs unreimbursed with few viable PRP's remaining to
pursue.
ALTERNATIVES EVALUATION
-.
Based on the findings of the remedial investigation and risk
assessment, the following response objectives were identified:
1 )
2)
3 )
To provide residents in the affected area with a per-
manent supply of safe drinking water;
Abate local sources of contamination at the site;
Minimize future public health risks by restricting
site access.
There were twelve alternatives considered in attempting to meet
the above objectives. These remedial alternatives were developed
by combining off-site components for a permanent water supply and
on-site components for contaminant source reduction and site closure.
The twelve alternatives include:
1 .
2 .
3 .
4 .
No action.
Off-site water supply only.
Permanent relocation only.
Off-site water supply, limited capping, fencing,
grading, seeding, loaming and monitoring.
5 .
Off-site water supply, full capping, fencing, grading,
seeding, loaming and monitoring.
6 .
Off-site water supply, on-site land farming, encapsulation,
and/or 1andfil1ing of sludges and visibly contaminated
soil, fencing, grading, seeding, loaming and monitoring.
7 .
Off-site water supply, limited excavation and off-site
disposal of sludges and visibly contaminated soil,
fencing, grading, seeding, loaming and monitoring.
8.
Off-site water supply, Area E excavation and off-site
disposal, fencing, grading, seeding, loaming and monitoring.
9 .
Off-site water supply, limited excavation and oft-site
disposal of sludges and visibly contaminated soil
including Area E, fencing, grading, seeding, loaming and
-------
10.
11.
12.
-11-
Off-site water supply, total site excavation and off-site
disposal of sludges and visibly contaminated soil,
fencing, grading, seeding, loaming and monitoring.
Off-site water supply, limited capping and limited
excavation and off-site disposal of sludges and visibly
contaminated soil, fencing, grading, seeding, loaming
and monitoring.
Off-site water supply, limited capping and limited Area E
excavation and off-site disposal of sludges and visibly
contaminated soil, fencing, grading, seeding, loaming
and monitoring.
In accordance with Section 300.68(g) of the National Contingency
Plan (NCP), these alternatives were developed considering both source
control and off-site remedial actions. The alternatives were based
on the results provided in the remedial investigation which determined
that contami na'nts are migra t ing of f-s i te via ground wa ter and have
already impacted nine drinking water wells. (The RI/FS determined
that seven residences in the affected area have shown contamination
in their drinking water. Discussions between the EPA Regional
Site Manager and the Rhode Island Department of Health, after the
RI/FS was completed, confirm that as of May 1984, nine homes
within the affected area have shown contamination in their private
drinking wells.)
The initial listing of the twelve remedial systems can best be
classified by evaluating the components of each system according to
on-site and off-site remedies.
Off-site components investigated include:
A.
B.
C.
D.
E.
No action.
Permanent relocation of residents.
Permanent drinking water treatment
(carbon filters, bottled water).
Permanent alternate water supply.
Treatment of the contaminated water using the
existing groundwater recirculation system.
On-site components investigated include:
A.
Contaminant Source Reduction/Control
1 .
2.
3 .
4 .
No action
Capping
Landfarm/encapsulation
Excavation and off-site disposal
a. Limited
b. Total site
Existing groundwater recirculation system
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-12-
6. On-site Landfill (in compliance with RCRA)
a. Limited
b. Total site
B. Site Closure
- -
1 . No action
2. Fencing
3. Grading, loaming and seeding
4. Monitoring
5. Capping
The components of the twelve remedial systems were screened
according to the requirements of Section 300.68(h) of the NCP in
order to narrow the list of potential remedial actions for further
detailed analysis. The criteria used in the initial screening process
included: 1) total system costs, considering net present value of
capital and a ~nd M costs~ 2) effects of the alternative upon the
environment with evaluation of whether the alternative will achieve
source control and mitigate threats to public health, welfare and
the environment~ and 3) acceptable engineering practices with
respect to feasibility and reliability for addressing the problem.
The initial screening of the off and on-site remedies ~esulted
in excluding the off-site option of no action. considering the
criteria (i.e. mitigation of the threat to public health) for
effects of the alternative, this option was screened out based on
the fact that certain wells are now contaminated at levels of
concern, and that there is a reasonable expectation that contamin-
ation will appear in additional wells located between the site and
the reservoir. A representative sample of contaminants identified
in private drinking water wells at "levels of concern" includes:
l,l,l-trichloroethane, trichloroethylene, tetrachloroethylene,
l,2-dichloroethane, l,l-dichloroethane and dichloromethane. Based
on sampling from upgradient wells these levels are likely to increase.
The reason for consideration of permanent relocation of resi-
dents located within the affected area is based solely on public
health concerns related to the present and potential ingestion of
contaminated drinking water from the private wells. The cost of
purchasing the 56 parcels of land, which now show or may in the
future show ground water contamination, at fair market value is
$3,310,000. The public health problem of ingesting contaminated
water can be more cost-effectively abated by installing an uncon-
taminated alternate water supply for $1,200,000. The cost of
relocation was evaluated against only the cost of the installation
of an alternate water supply because the public health concern was
based solely on the ingestion of contaminated drinking water from
the private wells. Therefore, the off-site option for permanent
relocation of residents in the affected area for public health
-------
-13-
Treatment of the contaminated ground water off-site using the
existing ground water recirculation system was omitted as an option
based on the determination that the system will not mitigate the
threat to public health caused from ingestion of the contaminated
ground water. A portion of the plume has already migrated off-site,
contaminating nine private drinking water wells. While. such a
system may help retard contaminant migration from the site, the
existing system would not pull back the contaminated groundwater
. already downgradient from the site or restore the contaminated
wells. Without such restoration, current and future threats to
public health from ingestion of contaminated drinking water would
not be mitigated.
Several on-site remedies for contaminant source reduction/control
were also excluded from further consideration during the initial
screen. The no action alternative was excluded using the criteria
for effects of the alternative, based on the fact that no action
would not achieve source control. Based on the results of the
remedial investigation and risk assessment, a continuing source of
contamination would provide a threat to public health from potential
dermal exposure. In addition, in reviewing site conditions to
develop a natural resources survey, the U. S. Department of the
Interior has determined that in the absence of remedial action,
there is a definite potential for future damages. The continuing
source of contamination would result in adverse environmental effects,
in that the sludges left on-site could cause degradation in surface
and ground waters and lengthen the time necessary for the Slatersvill~
Aquifer to cleanse itself.
The landfarming/encapsulation options were excluded from
consideration because the technologies are considered to be unproven
with respect to treating the types of wastes found in the soils at
Western Sand and Gravel and, therefore, did not meet the criteria
for acceptable engineering practices.
The existing groundwater recirculation system was excluded
from consideration as a long-term on-site option for contaminant
source reduction/control based on effects of the alternative. As
previously stated, regarding its impact on public health, operation
of such a system would not improve the water quality in already-
contaminated private drinking water wells. The system has proven
somewhat effective in capturing non-aqueous phase liquids floating
on the groundwater surface.
The RI/FS predicted that removal of the recirculation system
could permit any remaining non-aqueous phase liquids to migrate in
a northerly direction until intercepted by the Tarkiln Brook.
Should this occur, projections indicate that there would be no
adverse acute toxic effects on aquatic and terrestrial life from
the nonaqueous material, as it is suspected that most of the non-
-------
-14-
and stored in an underground tank. This estimation that most of
the non-aqueous phase liquids have already been removed is based
on observations that the system has been capturing non-aqueous
phase liquids at a rate much below that experienced during 1982
and 1983. .: .
The on-site alternative of no-action for Site Closure was also
rejected, because closure provisions are necessary to adequately
-. protect public health and the environment from future migration
from this site.
Consistent with Section 300.68(i) of the NCP, the oft-site
and on-site remedies remaining after the initial screening were
included in a detailed evaluation. The detailed analysis of each
option included:
4 .
6.
7 .
8.
9 .
10.
11.
12.
13.
14.
1 .
Description of appropriate treatment and disposal
technology.
2 .
Special engineering considerations (pilot plant,
additional studies).
3.
Environmental impacts of proposed methods.
Operating, maintenance and monitoring requirements.
5.
Off-site disposal needs and transportation plans.
Temporary storage requirements.
Safety requirements for remedial implementation on-site
and off-site.
Description of how the alternative could be phased into
operable units.
Description of how the alternative could be segmented
into areas to allow implementation of differing phases
of the alternative.
A review of the off-site facilities provided by the
state to ensure present and future compliance with RCRA.
Environmental risk assessment.
Cost analysis - total costs including operating and
maintenance.
Reliability of the system.
-------
-15-
The remedial components 'considered after the initial
screening are listed below:
Off-site
---.---
-.
°Permanent limited water supply system (bottled water).
°Permanent alternate water supply.
°Permanent drinking water treatment for total home use (filters).
°Temporary drinking water treatment for total home use (filters)
until the permanent supply is functional.
°Temporary alternate water supply (bottled water) until the
permananent supply is functional.
On-site
-.----.- ---
~emoval of existing recirculation system.
°Soil and sludge excavation and on-site RCRA Landfill.
a. Limited (3,820 yds3)
b. Total (24,000 yds3)
°Soil and sludge excavation and off-site disposal at A RCRA
facility. .
a. Limited (3,820 yds3)
b. Total (24,000 yds3)
°Capping.
a. Limited
b. Total (400,000 ft2)
os i te Closure.
- Capping
- Fencing
- Grading,
Loami ng, Seed i ng
°Ground water monitoring consistent with RCRA requirements.
In the course of the assessment of on-site alternatives, EPA
determined that existing sampling data on the location of the
sludges, concentrations of contaminated material below the sludges,
and the extent to which those areas were subject to ground water
saturation on a seasonal basis were insufficient to permit final
selection of a remedy. Therefore, the decision for on-site
remedies is being deferred pending the development of additional
contamination and ground water data. The remainder of this ROD
-------
-16-
RECOMMENDED ALTERNATIVE
------. ------ _.._--- -.- - - - -
The recommended off-site alternatives for the Western Sand
and Gravel Site were selected in accordance with the NCP. partic-
ularly Section 300.68(j), and was determined to be the MOst
cost-effective alternative that adequately protects and mitigates
rlamage to public health, welfare and the environment.
A. OFF-S ITE ALTER NATIVES
- -
In considering the off-site options for a potable water
supply, the alternative of a permanent alternate water supply
was determined to be the most cost-effective long-term remedy.
The areas to be provided with an alternative water supply have
been determined as follows. First, water would be provided to
nine parcels where wells have demonstrated contamination to
date. Second, there are 47 other parcels of land located between
the source of contamination and the reservior, and in the general
area where contaminated wells have been found. It is expected
that at least some of these wells will show contamination in the
future, and that contamination would continue for some time. It
is impossible, however, to reliably identify which particular
wells will be contaminated. If EPA did not provide alternate
water for these parcels at this time, it would be necessary to
sample the wells periodically and if contamination were found in
the future, to consider extending alternative water supplies at
that time. Although EPA has not specifically analyzed the costs
of long-term monitoring of the potentially affected area and
extending alternative water on a piecemeal basis, it is believed
that it would be more efficient to provide alternative water to
the entire potentially affected area at one time. In addition,
extending water now would reduce the risk that persons may be
exposed to contamination before periodic sampling could detect
this contamination. The estimated present worth cost for provid-
ing a safe drinking water supply through an alternate system is
$1,200,000. The estimated cost for individual carbon canisters
(total home use) is $156,800 for 56 units for the first year,
including capital and 0 & M. Yearly 0 & M after the first year
is $100,800. Therefore, in 11 years, the cost of filtration
units would be approximately the same as the cost of a permanent
altp.rnate water supply. Starting the 12th year of filtration
use, that system would become increasingly more expensive than
the other permanent alternate water system. The same cost
argument is true for bottled water, estimated to cost $95,200
per year to supply 56 parcels. In 12 to 13 years, the cost of
using ~ottled water for drinking purposes only and not total
home use would exceed the cost of the permanent alternate water
supply. Therefore, an alternate water supply providing uncontam-
inated potable water for total home use to 56 parcels is the
-------
-17-
The installation of an alternate water system has been
determined to be the most cost-effective long-term method to
abate the current and potential public health risks associated
with ground water contamination. The cost of the system provides
for water to the tap for all home uses for 56 parcels and for
fire protection. Fire protection capacity was calcula~ed as
comprising 4.2% or approximately $50,000 of the total cost of
the alternate water system. Because the cost of fire protection
is such a small percentage of the cost of the total system and
would offset some of the maintenance required system costs (i.e.
flushing valves), it is recommended that it be a component ot
the alternate water system.
Once it was determined that an alternate water
the most cost-effective option for the provision of
water, locations and availability for the alternate
explored:
system was
potable
supply were
EVALUATION OF ALTERNATE WATER SUPPLY LOCATIONS
S YS TE M
EVALUATION
1. S latersville
-inadequate capacity as sole
source
2. Industrial
-inadequate capacity as sole
source; currently used for
industrial purposes and one of
the two wells is high in iron
3. Nasonville
-inadequate capacity as sole
source
4. Slatersville/Industrial
Tie-In
-adequate capacity but local
institutional constraints make
it unavailable
5. Well Field A
-adequate yield and upgradient
from the site; close to the
affected area
6. Well Field B
-close to the affected area with
adequate yield, but may possibly
have future contamination from
the W5G site
7. Well Field C
-close to the affected area with
adequate yield, upgradient from
W5G but downgradient from Landfill
and Resource Recovery, a nearby
NPL site, so there is a potential
-------
-18-
8. Area by Tarkiln Pond
-close to the affected area with
adequate yield and upgradient
from ~ G; recommended by local
citizens involved with local
water systems. -
Water Systems 1, 2, and 3 were eliminated as alternative water
supplies because of inadequate capacity. Water Systems 4 through
8 have adequate capacity. System 4 is unavailable because of
institutional constraints. Systems 6 and 7 could potentially be
impacted by contamination, and would require additional investigation
before they could be utilized.
Water systems 5 and 8 are acceptable because 1) both have
adequate capacity: 2) both are located within the town of Burrill-
ville and therefore eliminates the politial constraints encountered
with water sources located outside of the town and 3) the Town
Council of Burrillville has a mechanism for land acquistion, if
necessary, to obtain land for a wellfield.
The costs for water systems 5 through 8 are approximately
equal. The only difference between the systems is the location
of the production wells. The final selection of the well location
will be based on technical criteria developed during design.-
As previously stated, the contaminant levels in the domestic
drinking water wells do not exceed the recommended levels for
non-carcinogens prescribed by EPA. However, some of the chemicals
detecten in these wells are suspect carcinogens. The measured
levels and associated 10-6 excess cancer risk are as follows:
HIGHEST LEVELS OF SUSPECT
CARCINOGENS DETECTED IN ffi IVATE WELLS
10-6 EXCESS
CANCER R IS K
CONTAMINANT
trichloroethylene
6 ppb
8 ppb
2.8
ppb
ppb
tetrachloroethylene
0.9
l,2-dichloroethane
21 ppb
0.95 ppb
It is reasonable to assume that these low-levels of carcinogens
have been ingested for some time and adverse health effects from
such long-term low-level exposure is unknown. In addition, it is
appropriate to take preventive public health measures when an
excess cancer risk greater than 10-6 is determined. Therefore,
it is a prudent preventive public health measure to provide
temporary clean potable water to those residences exhibiting
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-19-
While carbon canister filters and bottled water were
determined not to be the most cost-effective options for long-term
potable water, it is recommended that filters be used as the
initial remedial measure for those homes with contaminated wells,
until the permanent water supply is functional. In the~event that
monitoring results show contamination above an acceptable level
for additional residences in the affected area, filters will be
provided.
The costs associated with providing carbon canisters for
total home water use (bathing, drinking, etc.) for nine homes
(including operation and maintenance) for one year is $3l,500/yr.
The cost for providing bottled water for drinking purposes only
and not total home use is $13,600/yr. for 9 homes. Due to the
wide range of chemicals present in the plume, it is not certain
that ingestion is the only possible route of exposure. To protect
against the possibilities of inhalation and dermal exposure, it
is recommended' that protection for the total home use of water
be prc'\"i-3ej. Th0rf'fore, it is recommended that the homes with
contamlnaLed drin~lng water wells be provided with carbon canister
filters as an initial remedial measure until the permanent water
supply is functional.
The recommended alternative includes:
Remedial System
Permanent water supply
to 56 Parcels
Present Worth
1.
$1,200,000
2 .
Temporary water supply (filters)
for 9 homes until permanent water
supply is functional (2 yrs)
51,750
S UBTOT AL
$1,251,756
15% CONTINGENCY
1-8 7 , 7 6 3
$1,439,513
TOT AL cas T
COMPLIANCE WITH OTHER ENVIRONMENTAL LAWS
The permanent alternative water supply and the temporary
filters will assure that persons in the area potentially affected
by contaminated ground water will be provided with water which meets
the standards of the Safe Drinking Water Act.
GROUND WATER PROTECTION
The RI/FS indicates that even with source control measures
such as capping and soil removal, which will be addressed in a
subsequent ROD, ground water in the vicinity of the site would
-------
-20-
The recommended remedy will abate the most immediate and
significant public health risk from contaminated ground water.
In addition, however, the Agency will also consider the need for
p.ither corrective action to address the remaining contaminated
ground water. The Agency currently lacks sufficient dat~ to
detp.rmine the proper course of action for the ground water at
this site. A final decision on the necessity and feasibility
of ground water treatment at this site will be made upon the
'completion of additional study. The need for further soil
excavation will also be evaluated as part of the cost-effective
analysis of ground water treatment.
SCHEDULE
ACTIVITY
DATE
- Approve Remedial Action (ROD)
September 1984
- u.s. Army Corps of Engineers begins
selection and procurement process
for engineering design services
5 eptember 1984
- Award Superfund state contract and
issue lAG for design and construction
september 1984
- Amend cooperative agreement
September 1984
- Award design contract, start design
December 1984
- Complete design of
Permanent water supply
September 1985
- S tart construction of
Permanent water supply
November 1985
- Complete construction of
Permanent water supply
August 1986
COMMUNITY RELATION:;
"EPA released a draft feasibility study (FS) to the public
the week of January 30, 1984. Press releases, paid newspaper
advertisements, and direct mailings to about 90 persons were used
to announce the availability of the document, the comment period,
-------
-21-
EPA held a public meeting on February 2, 1984, to explain
the recommendations of the FS, and another meeting, on February 23,
to accept community comments on the FS. Both meetings were held
in the local community. EPA, the State, and State's consultant,
media represent~tives, citizens, local officials, and C6ngressionals
attended. Between 50 to 100 people were present at each meeting.
The written comment period was initially announced to run
from February 2 until February 23, and later extended by EPA to
February 29. Citizens then requested the comment period be
extended to March 15. EPA compromised and extended it until
~arch 7. Several comments were received shortly after the last
deadline. They have been included in this summary.
The majority of the comments came from the Western Sand and
Gravel Coordinating Committee, and advisory committee formed in
1981 by the Burrillville Town Council, at the request of the Rhode
Island Department of Environmental Management (DEM), to facilitate
communication between DEM and local government and to review plans
and provide advice to DEM.
The Committee's recommendations were endorsed by the North
Smithfield and Burrillville Town Councils, the North Smithfield
Conservation Commission, the Burri1lville Health officer, State
-------
SEP 2 8 1984
COMMUNITY RELATIONS RES PONS IVENESS SUMMAR Y
Western S and and Gravel Superfund Site'; -
Introduction
The responsiveness summary will describe citizen concerns
raised during the coment period on the feasibility study and how
EPA considered and responded to these concerns.
In addition to the public meetings, EPA and DEM met informally
with the Western Sand and Gravel Coordinating Committee twice
during the comment period to answer questions about the proposed
remedial action and to hear the committee's concerns.
DEM commented on the FS at the February 23 public meeting.
Those comments, which recommend modifications of the remedial
action recommended by the FS, are listed separately.
Comments from the generators' committee (the Western Sand
-------
CD1MUNITY ~ms
------.----- --------
o RemOlTal of cootaminated soil
suggestions--rangedfran 16.000
cubic yards to "remove all toxic
waste." ~stern Sand and Gravel
Coordinating Camti ttee (W>GCC)
recarmendeci removing "20,833
cubic yards or all sludge and
cootaminated soil." Also want
excavated areas filled with
clean fill.
o Need f~ublic wate£~J>1Y.:
WSGCC and several others emphatically
supported this F.S rec(]l'l"rendation, with
stipulation of free tie-ins and fees
ooly for usage.
o Ground water re~irculation sy~tem:
want system continued as long as non-
aqueOJs liquids remain, skinrning of
non-aqueOJS liquids, and additiooal
ptmping wells near areas A and R,
and between areas C,D, and E and the
hrcx:k (recO'l1lrendations of WSGCC and
an individual). Another comment
n~c~nded expansion of the system
to "remove the' source' of the plume."
II.
EPA RES laSE
- - -".. - -_..~ - - . .
o After further pvaluation of the
amcunt of contaminated soils and sludges
remaining on site, the Agency recommends
the deferral of arsite rerredies pending
the develq;trent of additional grOJnd water
and contaminat ion .data, To detennine more
precisely what contaminants needs to be
removed. and what can safely be contained
on-site.
o EPA agrees that a permanent alternate water
supply shOJld be provided to residences
located in the affected area.
o Data indicates that the grOJnd water recircu-
lation system has not been effective in
stcpping migrat i.on of cootaminated grOJnd water
fran the site Clnd its usefulness in capturiny
the non-aqueous liquids appears to be declin-
ing. Therefore. EPA dres not support long
term ~ration or expansion of the system.
Rather, the Agency expects that the system
will be shut dOwn and removed in coordination
with the soorcc control actions to be selected
in a subsequent: ROD.
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o ~at:.~oo__~~_~ter ~l3.?plL s~Ec_~:
Several c<:1Tl'OOnters sugest specific
water supply srurces. W3GCC recrnmanded
establishing a new domestic well upgradient
of the site, and criticized the recommendation
to use S latersville Water System as srurce;
they believe the S latersville Reservoir has
insufficient capacity, and may be subject to
contamination fran the site and industrial or
domestic waste entering Branch River.
o Monitoring: W:;GCC recamends 25 years or until
steady decline for five years: include surface
water fran Tarklin Brook, swamp near S latersville
Reservoir, the Reservoir itself, test wells and
private wells. Supported by two individuals.
o Grrund water treatIoont: W3GCC endorses grrund water
treatIoont and suggests a facility [EM had prq)(:seed
in 1981. Supported by three cC1l1fTenters.
III.
o Based on widespread citizen concern re-
garding the location of the supply swrce,
EPA reevaluated the recommended swrce,
the Slatersville - Industrial Tie-in, as
provided in the RI/FS . Further in-depth
discussions with hydrologists, regarding
locations recommended by the citizens,
have resulted in the Agency recommending
the location of the water su~ply be within
the Town of Burrillville and in the vicin-
ity swth of the site.
o EPA agrees that. a monitoring pr
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o ~~nci~ if additional soil is excavate,
\'OGCC believes fenci(YJ will be necessary
only aramd thp. recirculation system.
o Warning sign~: W:;GCC and another c01lrenter
supported this fS rec01lrendat ion of placards
aramd site perimeter.
o Pr~rty buy-oot: requested by two individuals.
o Protection/cleanup of S late_~~vi])e Rese~oi~:
one caTl'OOnter requested EPA "remove the heavy
oily layer which floats on the water." W;GCC
endorses applyi(YJ F:PA drinkioJ water quality
stanrlards to reservoir.
IV .
o The Agency expects that the final swrce control
alternatives will include placing a fence around
the area where the pits and lagoons were located
(9.25 acres) in order to restrict site access
and subsequent further use of the area.
Restricti(YJ site access also serves as a preven-
tive public health measure in protecting persons
fran dermal cOlltact with any remaini(YJ contam-
inated soils.
o The Agency agn~es that placards should be placed
aramd the perimeter of the site, as well as at
the brad<., swamp and ma.Jth ot the reservoir.
o The Agency bel ieves that providing a potable
saJrce of uncontaminated water is the ccst-
effective meaSIIre for mitigating the public health
threat pcsed by the presence of contaminated yrouOO water.
The Agency bel j eves that prq?erty buy-outs are not
warranted at this site as there are no significant
adverse public health effects which are not addressed
by the rec01lIV2' ded rE!lredy.
o The citizens voiced concerns that there was
limited samplinq data on the reservoir. In
response, [EM cooducted a rwOO of surface
water sampling, includi(YJ the reservoir, in
April 1984. TIt.~ monitoring data fran the mwth
of the reservoi.r:- indicates that there is neither
an environmental nor public health risk associa-
ted with any c! ~Itcmination of the reservoir
(latest resevoi r- sampling was belOo1 detection
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o ~~r protection:- w.;GCC enrlorses
applyirg EPA drinkirg water quality
standards to aquifer.
REMAINING COMMUNITY ~CFRN3
o Temporary point-of-use-water treatment:
advocated by w.;GCC. Want carbon filtraticn
system am free installation and maintenance.
v.
o Contaminated grr:J..Ind water has already
moved off-site to the downgradient neighbor-
hoaj and reservoir. Hcwever, a study to
focus on the technol<::gical feasibility of
recapturing that part of the escaped plure
and treatirg it will be conducted.
lnstallaticn of a cl-ean permanent water
supply will abate ~ny present public health
problems associated with drinking con- .
taminated water fran wells located in the
aquifer.
o On reevaluatinj the hanes determined to have
contaminated private well water, EPA supports
providinj tempo~ary water supply treatment
(for total hane use) to nine residences that
have exhibited ccntamination at least cnce in
their sampling history.
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S TAm CX»!EN1S
-----
o
~rmanent water supply to
60 land parcels.
o
Temporary water supply to
individuals with contam-
inated water.
o Removal of 1f;00 to 500 cubic
rams of contaminated soil,
lncluding pit *3, plus con-
tingency for more remooal.
Make determination based on
first excavations.
o
Two year min}mum for phase-rot
of groundwoLer recirc~~l~ion
system. Phase-OJt not be done
until nan-aqueOJs layer contam-
inant~ no longer remooed or
until permanent water in place,
if no temporary water provided.
Learning and seed~ of lagoon
area, in addition to site
grading.
o
pencing: agree with this FS
recammennation for fencing
periIreter of site.
o
Warning signs arOJnd perimeter
of site and at bred<, swamp, and
maJth reservoir.
o
Moni toring prcgram to include
wells, brook, swamp, reservoir,
and continue until "sustained
and substantial" decrease in
cootami nants.
VI .
EPA RES.r0N3E
--.-.- ---- -_.- .- -
o
The State ccmrents coocernio:;
alternative water suppiies have
been addressed in the bcdy of the
Record of Decision. . In addition,
a number of ccmrents were
similar to community comments;
see previaJs "Camumity Ccmrents"
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VII.
GENERA!tR COMMENIS
o
Public Water supply:
1.
Need not supported by R I/FS .
Study does not present sufficient
data to support finding that site
poses a present or potential
threat to public health. Medel
that was used to predict health
risks not useful for making
predictions of contaminants levels
at same future point in tUne for
estllnating heal~h risks.
2.
1=:x':.ert of "affectee" area ~'o.r-
stated. Includes three damestic
wells on DaJglass Pike. "Highly
unlikely" that site is SaJrce of
contamination in those wells.
May have been fran damestic
disposal or septic tank cleaners.
Affected area shaJld be redefined
based on contaJrs of graJndwater
plume. Size is 1/3 to 1/2
exaggerated .
3.
Estimated water demand of 500,000
gal/day exaggerated. 25,000 gal/day
more than adequated to supply affected
area. No crn.LCA requirerrent that
remedial action prO/ide benefits beyond
those necessary to mitigate and
minilnize damage to public health and
thE'! environment; therefore, no
need for fire protection capability.
4.
Not shewn to be "feasible for the
location" as required by National
contigency Plan. Determination of
feasibility requires thoraJgh analysis
of available water saJrces for that
water supply system.
EPA RES rot£E
.-
1.
The basis for EPA' s conclu-
sions on threats due to coo-
taminated graJnd water is
discussed in the ROD.
2.
Although the precise extent
of the plume is difficult to
define, EPA has a reasonable
basis for including the
DaJglas Pike wells.
3.
The size of pipes used in
the system is based on standard
technical considerations,
not on alleged exaggerated
demand projections. Includio;J
fire protection as part of the
alternate water system increases
the cost of the system by only
4.6%, as discussed in the ROD.
4.
After analysis, EPA has determined
that there are several available
water saJrces for the alternative
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..
.
5. Removal of Centaminated soil:
recarmerrled -Off-site-cfispesal
400 cubic yards, and site grading.
6.
Fencini!: recanmend fencing, but
do not speci fy area.
7.
Menitoring: long-term monitoring
not cost effective; if permanent
public water supply is installed,
threat will have been eliminated.
A.
Point-of-use water treatment:
reccmnend for "these darestic
wells that have exhibi ted cen-
sistent levels of contamination,"
(three at present). Rationale for
dismissing this option was not
presented in RI/FS .
9.
Phase-rut of grrund water
recirculatien system: reccmnended
but tiJre frame not specified.
VIII
5.
It is EPA I s judgement that
removal of all the roes t
heavily centaminated soil
is necessary to protect
against continued ~rrund
water deterioration.- Based
en the contractors estimate,
it appears that the amrunt of
higly centaminated wastes is
censiderably greater than 400
cubic yards. This estimate
will be finalized after
additional data is developed.
EPA believes that unless all
contaminated soil is removed
(which would probably not be
cost effective) site capping
wruld be a necessary part of
final clesure of the sites.
6.
Discussed in ROD
7.
Menitoring will be addressed
in a subsequent ROD. Loog-
term monitorirq, con-
sistent with RCRA Part 264,
is necessary and appropriate
to ensure that the source control
measures which are selected
are and continue to be effective.
8.
Discussed in ROD.
9.
EPA agrees with this comment.
This issue will be addressed
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