United States
Environmental Protection
Aoency
Office of
Emergency and
Remedial Response
EPA/ROD/R01-90/048
September 1990
&ER&
Superfund
Record of Decision:
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REPORT DOCUMENTATION 11. REPORT NO. I ~ 3. A8dpIenI'I ~on No.
PAGE EPA/ROD/ROl-90/048
4. TItle end SUb... 5. A8por1 0818
SUPERFUND RECORD OF DECISION 09/28/90
Stamina Mills, RI
II.
First Remedial Action - Final
7. Author(l) II. PIrtorming Orgenlz8l1on Alp&. No.
e. Perfonnlng Orgllnizllllon NIm8 end Add.... 10. ProjleVTuklWork Unit No.
11. Con1rICI(C) or Gr8mIO) No.
(e)
(0)
1 ~ St)_oring Orgllli.ullon NIm8 end AddIHI 13. Type of Report' Period Cov.8d
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supple.........., No'"
111. Ab81rld (Unlit: 200 _rdl)
The five-acre Stamina Mills site is a former textile weaving and finishing facility in
North Smithfield, Providence County, Rhode Island. A portion of the site is within the
100-year floodplain and wetland area of the Branch River. The facility was operated
from the early 18005 to 1975, and was subsequently destroyed by a fire. The
manufacturing process used cleaning solvents, acids, bases and dyes for coloring,
pesticides for moth proofing, and plasticizers to coat fabrics. Mill process wastes
were placed in a landfill on site. TCE was used to remove oil and dirt from newly woven
fabrics. In 1969, an unknown quantity of TCE was spilled onsite, and migrated into
soil and the bedrock aquifer beneath the site with some runoff to the Branch River. EPA
initiated three removal actions from 1984 to 1990, including an extension of the
municipal water supply to residents obtaining water from the affected aquifer; and
treatment of two underground and one above-ground storage tanks, followed by offsite
disposal. Subsequent investigations have identified a septic tank that may be
contaminated with TCE. This Record of Decision (ROD) provides a final remedy and
addresses both source control and management of contaminated ground water migration at
this site. The primary contaminants of concern affecting the soil, debris, sediment,
. (See Attached Page)
17. Document AnIIy8la .. Dl8cripto,. -
Record of Decision - Stamina Mills, RI
First Remedial Action - Final
Contaminated Media: soil, sediment, debris, gw
Key Contaminants: VOCs (PCE, TCE), other organics (pesti<::ides), metals (chromium)
b. 1dan1lll8r8l00000Endad Tanna
c. COS" TI FIeIdIOroup
18. Ayli1ibiUty Sta\8rnInt 18. Slcurity CIa.. (TIlII Report) 21. No. 01 Pagel
None 208
20. SlcUrity ClI.. (nI11 Page) 22. PrIce
Mnnl'>
.18 SH ..v-~
50272 101
(See ANSl-Z3e )
INtrucli- on IM-
(Forrnatty NT1~)
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EPA/ROD/ROl-90/048
Stamina Mills, RI
First Remedial Action - Final
Abstract (continued)
and ground water are VOCs including TCE and PCE; other organics including pesticides; and
metals 'including chromium.
The selected remedial action for this site includes treating VOC-contaminated soil using
vacuum extraction, followed by treatment of the extracted gases using an activated carbon
filter; excavating approximately 550 cubic yards of landfill wastes, and sediment from
the Branch River 100-year floodplain area; placing these within the landfill area outside
of the floodplain; capping landfill wastes and installing a leachate collection system to
collect runoff from the landfill; testing, removing, and disposing of the septic tanks
and their contents offsite; demolishing and removing partially standing structures with
onsite disposal of all earthen debris and disposing of all other solid wastes offsite;
grading and vegetating the site after remediation; ground water pumping, pressure
filtration, and treatment using UV/hydrogen peroxide innovative technology; discharging
the treated ground water to surface water, subsurface water onsite, or existing sewer
line contingent upon pilot test studies; surface water diversion; long-term monitoring of
ground and surface waters; and implementing institutional controls including deed
restrictions to limit land use. The estimated present worth cost for this remedial
action is $4,316,485, which includes an annual O&M cost of $164,400.
PERFORMANCE STANDARDS OR GOALS: Soil cleanup levels that will ensure attainment of MCLs
in ground water include TCE 195 ug/kg (MCL) and PCE 66 ug/kg (Proposed MCL, PMCL). Soil
levels for chromium were not established since elevated levels were detected only in
landfill wastes that will be consolidated and capped as part of this remediation. Ground
water cleanup levels include TCE 5 ug/l (MCL), PCE 5 ug/l (PMCL), and chromium 50 ug/l
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REGION
I
RECORD OF DECISION
STAMINA MILLS SITE
NORTH SMITHFIELD, RHODE ISLAND
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.;-f.0 .,..~.
(St)
~04( 1W1I'f.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F. KENNEDY FEDERAL 8UILDING, 80STON,IIASSACHUIETTS 02203-2211
DECLARATION POR TBB RECORD OP DBCISION
stamina Kills
North Smithfield, Rhode Xsland
STATEMENT OP PURPOSE
This decision document represents the selected remedial action for
the stamina Mills Site (the site) in North Smithfield, Rhode
Island, developed in accordance' with the comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986, and to the extent practicable, the
National Oil and Hazardous Substances contingency Plan (NCP), 40
CFR Part 300 n H,g. f as amended. The Region I Administrator has
been delegated the authority to approve this Record of Decision.
The State of Rhode Island has concurred on the selected remedy.
STATEMENT OF BASIS
This decision is based on the Administrative Record which has been
developed in accordance with Section 113 (k) of CERCLA and which
is available for public review at the North Smithfield Public
Library in Slatersville, Rhode Island and at the Region I Waste
Management Division Records Center in Boston, Massachusetts. The
Administrative Record Index (Appendix E of the ROD) identifies each
of the items comprising the Administrative Index upon which the
selection of the remedial action is based.
'ASSESSMENT OP THE SITE
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to the public health or welfare or to the environment.
DESCRIPTION OP ~ SELECTED REMEDY
The selected remedy for the Stamina Mills Site includes both source
control and management of migration components to obtain a
comprehensive remedy.
The source control measures include:
The in-si tu vacuum extraction of soil contaminated wi th
trichloroethylene (TCE) in the spill area. A number of
shallow wells will be installed throughout the spill area and
will be used to withdraw air containing TCE and other volatile
organic compounds (VOCs) from the 60ils. The air containing.
,," "
, .
. '
- . .
. -
. . . .
*
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2
.
VOCs is then treated using activated carbon filters prior to
being discharged to the atmosphere. Spent activated carbon
filters will be transported off-site where they will be either
regenerated or disposed of. Attaining the soil target c;leanup
levels will eliminate the potential migration of contaminants
from the soils into the groundwater at levels exceeding
groundwater cleanup goals.
Excavation of approximately 550 cubic yards of a mixture of
landfill wastes and sediments from within the 100-year
floodplain of the Branch River. This material will be
redeposited onto the landfill above the floodplain and
incorporated under the new RCRA multi-layer cap to be
installed. A leachate collection system will be installed
along the base of the landfill's southern boundary and the
leachate generated will be discharged into the on-site sewer
system subject to the final approval of the Woonsocket
Wastewater Treatment Authority.
.
Institutional controls in the form of deed restrictions will
be used at the site to regulate land use. The institutional.
controls would be focused on preventing the disturbance of the
physical integrity of many of the remedy's components. EPA
has proposed, in a consent decree lodged in federal court,
institutional controls with the current owner to protect the
remedy.
Confirmation of the septic tank location, testing and removal
of its contents, and disposal of the contents of the tank and
the tank itself. The contents of the septic tank will be
disposed of off-site but the type of facility at which it will
be disposed of will be contingent upon the testing results.
.
The management of migration remedial measures include:
.
Active restoration of the groundwater aquifer contaminated
with TCE and other VOCs using the innovative ultraviolet light
and hydrogen peroxide (UV/hydrog£r. p~ro~d~.::j technology. This
component of the remedy will extract and treat groundwater
contaminated by releases at the site. The goal of this
remedial action is to restore the groundwater to drinking
water quality standards as rapidly as possible. The results
of an on-site pilot test using the UV/hydrogen peroxide system
will be conducted during the predesign phase to determine
which of the three disposal options being considered for
treated groundwater will be used. The disposal options being
considered are on-site surface water discharge, on-site
subsurface water discharge, and on-site discharge to the
existing sewer line. The time frame for groundwater
restoration has been estimated at 10 to 15 years. EPA will
conduct an evaluation of the groundwater restoration remedy
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3
*
reveals that the remedy cannot achieve the cleanup levels
within a reasonable time frame, consideration will be given
to making changes in the remedy.
Extraction of groundwater through on-site wells installed into
the bedrock. Design details of the extraction system will be
determined from the results of a predesign pump test.
Groundwater extraction would act to halt the migration of
contaminants and facilitate the removal of contaminants which
have migrated off-site.
*
utilization of a pressure filtration system to remove
suspended solids and suspended metals in the groundwater prior
to treatment in the UVjhydrogen peroxide.
Sealing of the entrances and exits of two raceways with
impermeable barriers. The raceways were used to transport
water to mill buildings. sections of both raceways which have
not collapsed will be collapsed and backfilled.
*
*
Demolishing and removing partially standing buildings at the
site which include a deteriorating smokestack. It is believed
that this activity will have to be one of the first to occur
in order to allow workers to safely perform work at the Site.
Solid waste of an earthen nature (Le., bricks) will be
disposed of on-site and all other solid wastes will be
disposed of off-site in accordance with state solid waste
regulations.
*
Grading and vegetation of the site at the conclusion of the
remedial activities.
*
Long-term environmental monitoring of the groundwater and
Branch River to ensure the effectiveness of the remedy.
DECLARATION
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate for this remedial'action and
is cost-effective. This remedy satisfies the statutory preference
for remedies that utilize treatment as a principal element to
reduce the toxicity, mobility, or volume of hazardous substances.
In addition, this remedy utilizes permanent solutions and
alternative treatment technologies to the maximum extent
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4
As this remedy will result in hazardous substances remaining on-
site above health-based levels, a review will be conducted within
five years after commencement of remedial action to ensure that the
remedy continues to provide protection of human health and the
environment.
jf~10
Date
"
ie Belaga
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I.
Contents
SITE NAME, LOCATION AND DESCRIPTION.
. . .
. . . . . . .
II.
A.
B.
C.
RECORD OF DECISION
STAMINA ~LLS SITE
TABLE OF CONTENTS
Paae Nmllher
General Description. . . . . . . . . . . . .
Geologic Characteristics. . . . . . . . . . . . .
Hydrogeological Characteristics .. . . . . . . . .
SITB mS'1'ORY A1ID ENFORCEMENT AC'nVITIES
A.
B.
. . .
. . . . .
Land Use and Response History .
Enforcement History. . . . . .
. . . .
. . .
. . .
. . .
. . . .
. . .
III. COMMUNITY PARTICIPATION
. . . .
. . . .
. . . . .
. . .
IV.
SCOPE AND ROLE OF RESPONSE ACTION
. . .
. . . . . . . .
SUMMARY OF SITE CHARACTERISTICS
v.
A.
VI.
. . . . . .
. . .
. . .
B.
C.
D.
E.
8011 . . . . . . . . . . . . . . . . . . . . . . .
1. TCE Spill Area. . . . . . . . . . . . . . . .
2. Landfill Area. . . . . . . . . . . . . . . .
3. OVerall Site. . . . . . . . . . . . . . . . .
Groundwater. . . . . . . . . . . . . . . . . . . .
Surface Water. . . . . . . . . . . . . . . . . . .
Air. . . . . . . . . . . . . . . . . . . . . . . .
Sediment. . . . . . . . . . . . . . . . . . . . .
SUMMARY OF SITE RISKS
. ~. .
. . . .
. . . . . .
. . . .
VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
VIII.
. . .
. . . .
A.
B.
Statutory Requirements/Response Objectives
Technology and Alternative Development
Screening. . . . . . . . . . . . . . . .
. . . . .
. . . .
and
DESCRIPTION OF ALTERNATIVES
.......
. . .
. . .
A.
Source Control (SC) Alternatives Analyzed. . . . .
1. TCE spill Area. . . . . . .- . . . . . . . .
2. Landfill Area. . . . . . . . . . . . . . . .
Management of Migration (KM) Alternatives
Analyzed. . . . . . . . . . . . . . . . . . . . .
1. Groundwater Extraction and ~atment . . . . .
2. overall Site. . . . . . . . . . . . . . . . .
B.
i
1
1
1
2
3
3
4
5
6
7
7
7
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25
28
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32
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IX.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
c.
D.
A.
B.
TCE Spill Area. . . . . . . . . . . . . . . . . .
1. OVerall Protection of Human Health and the
Environment. . . . . . . . . . . . . . . . .
Compliance with ARARs . . . . . . . . . . . .
Long-Term Effectiveness and Permanence. . . .
Reduction of Toxicity, Mobili ty , or Volume
through Treatment. . . . . . . . . . . . . .
Short-Term Effectiveness. . . . . . . . . . .
Implementability . . . . . . . . . . . . . . .
Cost. . . . . . . .; . . . . . . . . . . . . .
state Acceptance. : . . . . . . . . . . . . .
community Acceptance. . . . . . . . . . . . .
2.
3.
4.
5.
6.
7.
8.
9.
Landfill Area. . . . . . . . . . . . . . . . . . .
1. Overall Protection of Human Health and the
Env ironment. . . . . . . . . . . . . . . . .
Compliance with ARARs . . . . . . . . . . . .
Long-Term Effectiveness and Permanence. . . .
Reduction of Toxicity, MObility, or Volume
through Treatment. . . . . . . . . . . . . .
Short-Term Effectiveness. . . . . . . . . . .
Implementability . . . . . . . . . . . . . . .
Cost. . . . . . . . . . . . . . . . . . . . .
2.
3.
4.
5.
6.
7.
8.
9.
State Acceptance. . . . . . . . .
Community Acceptance. . . . . . .
. . .
. . .
. . .
. . .
Groundwater Extraction and Treatment. . . . . . .
1. Overall Protection of Human Health and the
Environment. . . . . . . . . . . . . . . . .
Compliance with ARARs . . . . . . . . . . . .
Long-Term Effectiveness and Permanence. . . .
Reduction of 'l'Dxicity, MObility, or Volume
through Treatment. . . . . . . . . . . . . .
Short-Term Effectiveness. . . . . . . . . . .
Implementability . . . . . . . . . . . . . . .
Cost. . . . . . . . . . . . . . . . . . . . .
2.
3.
4.
5.
6.
7.
8.
9.
State Acceptance. . .
Community Acceptance.
. . .
. . . .
. . . . .
. . .
. . . . . .
. . .
OVerall Site. . . . . . . . . . . . . . . . . . .
1. Overall Protection of Human Health and the
Env ironment. . . . . . . . . . . . . . . . .
Compliance with ARARs ..... . . . . . . .
Long-Term Effectiveness and Permanence. . . .
Reduction of Toxicity, MObility, or Volume
through Treatment. . . . . . . . . . . . . .
Short-Term Effectiveness. . . . ~ . . . . . .
Implementability . . . . . . . . . . . . . . .
Cost. . . . . . . . . . . . . . . . . . . . .
2.
3.
4.
5.
6.
7.
8.
State Acceptance. .
. . . . . .
. . . .
. . . .
ii
40
41
41
42
43
43
43
44
44
45
45
45
45
46
46
47
47
47
48
48
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49
49
50
50
51
51
52
52
53
S3
53
53
54
55
55
56
56
57
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9.
Community Acceptance
. . .
. . . . .
. . . . .
X.
THE SELECTED REMEDY. . . . .
. . . .
..........
A.
Cleanup I,evels . . . . . . . . . . . . . . . . . .
1. Groundwater.................
2. Soil Cleanup I,evels . . . . . . . . . . . . .
Description of Remedial components. . . . . . . .
B.
XI.
STATUTORY DETE~NATIONS
. . . . . . .
. . .
. . . . .
A.
The Selected Remedy is Protective of Human Health
and the Environment. . . . . . . . . . . . . . . .
B.
The Selected Remedy Attai,ns ARARs . . . . . . . . .
1. Chemical-specific Relevant and Appropriate
Requirements. . . . . . . . . . . . . . . . .
Location-Specific Relevant and Appropriate
Requirements. . . . . . . . . . . . . . . . .
Action-Specific Relevant and Appropriate
Requirements. . . . . . . . . . . . . . . . .
Chemical-Specific TBCs . . . . . . . . .
Action-Specific TBCs . . ~ . . . . . . . . . .
Land Disposal Restrictions. . . . . . . . . .
2.
3.
4.
5.
6.
C.
The Selected Remedi~l Action 1& Cost-Effective
1. TCE Spill Area. . . . . . . . . . . . . . . .
2. Landfill Area. . . . . . . . . . . . . . . .
3. Groundwater Extraction and Treatment. . . . .
4.' OVerall site. . . . . . . . . . . . . . . . .
D.
The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery
Technoloqies to the Maximum Extent Practicable .
1. TCE Spill Area. . . . . . . . . . . . . . . .
2. Landfill Area. . . . . . . . . . . . . . . .
3. Groundwater Extraction and Treatment. . . . .
4 . OVera 11 Site. . . . . . . . . . . . . . . . ~
E.
The Selected Remedy Satisfies the Preference for
Treatment Which Permanently and Siqnificantly
reduces the toxicity, Mobility or Volume of the
Hazardous Substances as a Principal Element. . . .
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
. . .
. . . . .
XIII. STATE ROLE
. . . . . . . . . . . . . . . .
. . .
. . .
APPENDICES
APPENDIX A - FIGURES
APPENDIX B - TABLES
APPENDIX C - RESPONSIVENESS SUMMARY
APPENDIX D - STATE OF RHODE ISLAND CONCURRENCE
APPENDIX E - ADMINISTRATIVE RECORD INDEX
LETTER
i1i
57
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62
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67
69
71
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73
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75
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79
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ROD DBCI8IOII .1JMXARY
.epteaber,
1990
I.
SITB ~, LOCATIOII &lID DB.CRIPTION
A.
General De.criptioD
The stamina Mills Superfund Site (the site), a former textile
weaving and finishing mill, ia located in the Town of North
smithfield, Providence County, Rhode Island. The Site is
located approxiaately one-h~lf mile 80uthwest of the
interaectionof Highway ~46 and ~46A and ia approximately 14
miles northwest of Providence, Rhode Island (Appendix A,
Fiqure 1).
The Site, comprising approximately 5 acres, is bounded to the
south by the Branch River. A dam constructed immediately
adjacent to the site forms the Forestdale Pond. The pond
forms the western boundary of the Site (Appendix A, Fiqure
2). The land to the north and east of the Site is largely
residential witb some commercial use. The Halliwell Memorial
Elementary School is approximately four-tenths of a mile
northwest of the site. Areas directly east of the Site, which
are in the floodplain of the Branch River, have been left
undeveloped. The area to the south and southwest of the site
is occupied by industrial and commercial facilities. These
include a fertilizer plant, a paper and tape coating
manufacturer, an electronics and gauge producer, and a metal
fabricator. The southeast section of the Site, which includes
a small portion of the on-site landfill, is located within the
loo-year floodplain of the Branch River. The site is within
200 feet of the Branch River and is therefore a wetland under
Rhode Island law.
In 1969, an unknown quantity of the solvent trichloroethylene
(TCE) was spilled at the site and has since migrated into the
soil and the bedrock aquifer beneath the site. The
contaminated groundwater beneath the Site bas been shown to
be hydraulically connected to areas north of the Site and has
affected these areas. The Site bas remained vacant since a
fire destroyed the mill in 1977 and currently rubble, piles
of debris, and foundation remains (including a deteriorating
smoke stack) cover the site. A more complete description of
the Site can be found in the -Remedial Investigation Report,
Stamina Mills site", January, 1990, (RI) in section 2 of
Volume I. . .
B.
Geologic Characteri.tic.
The bedrock underlying the site is made up of schists, gneiss,
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and quartzite belonging to the Precambrian to lower Paleozoic
age Blackstone Series. These rocks are exposed in outcrops
over an area extending from 1.5 miles northwest of the Site
to the southern side of Woonsocket Hill, approximately 2 miles
to the south.
On-site drilling and qeophysical work indicated that: the
bedrock surface is irreqular; the orientation of joints and
fractures appear to be qenerally northeast-southwest and
northwest-southeast; the fractures qenerally dip between 15
and 35 deqrees and are parallel to the foliation planes in
the rock. These discontinuities in the rock are important
because they are the principlil areas where qroundwater is
stored and transmitted. .
Natural overburden 80ils encountered on the site consist of
thin qlacial till, stratified ice contact deposits and local
recent fluvial deposits. Glacial deposits found are qenerally
thin, with relatively dense till deposited as a mantle
overlying bedrock. . Surficial soils have been siqnificantly
al tered in the course of excavations and construction of
structures at the Site. The overburden materials vary in
thickness from 0 to 20 feet.
c.
Hydrogeological Cbaracteri8tic8
The Site lies within the watershed of the Branch River, which
is the recipient of most surface water runoff from the
residential area north of the site, the stamina Mills
property, and the area south of the Site. A dam constructed
adjacent to the Site forms the eastern boundary of the
Forestdale pond. Groundwater Jliqratinq beneath the Site
occurs predominantly in the bedrock aquifer and to a lesser
extent in the lower few feet of the overburden. with the
exception of the landfill area at the east end of the Site,
unconsolidated materials may lie completely above the
saturated zone or may only be seasonally saturated and,
therefore, do not playa major role in the storaqe and
movement of qroundwater throuqh the Site.
Regional qroundwater flow under natural conditions (i.e., non-
pumping of residential wells north of the Site) is generally
toward the Branch River from upland areas alonq the north and
south banks, and then eastward parallel to the River.
Residential and community pumpinq, occurring prior to the
installation of public water supplies, altered the natural
hydraulic system shown in Appendix A, Fiqure 3. EPA
determined by the pump test conducted at the Forestdale Water
Association Well that the pumping of individual bedrock wells
to the north of the Site produced a reversal of the regional
groundwater flow. As presented in Appendix A, Fiqure 4, the
regional flow was reversed such that flow from beneath the
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II.
site was induced toward the residential area north of the
Site. Groundwater sampling data obtained in March 1988,
indicates thet the groundwater flow continues to follow the
natural regional trend under non-pumping conditions.
Flow within the bedrock aquifer is controlled by hydraulic
head and interconnected fractures and is affected locally at
the Site by hydraulic gradients induced by the Forestdale
Pond. The orientation of what are believed to be the
principal water bearing features are to the northeast and
northwest coinciding roughly with the location of the
contaminant plume. Additiona~data, collected and described
in section 5 of the RI, indicabed that locally across the Site
the upper 15 ~.et of bedrock vas aiqnificantly fractured
providing available openings for qroundwater flow while below
this depth the bedrock 8Jd1ibited a auch tighter structure
1imitincJ tbe groundwater flow. Groundwater elevations
indicated that hydraulic gradients at the Site are further
effected by the local surface hydrology, specifically the
Forestdale pond which borders the western section of the site.
SITE HISTORY AND BHPORCEMENT ACTrvITIBS
~.
Land Va. and ...pona. Hiatory
Since the early 1800's the site has been operated as a textile
(cotton and wool) weaving and finishing facility. As part of
the manufacturing process, various chemicals were used at the
Site. These included detergents and solvents to clean the
wool; acids, bases and dyes to color fabrics; pesticides and
solvents for moth proofing; and plasticizers to coat fabrics.
During the 1930's a fire at the Site destroyed one of the mill
buildings. A portion of the burned-out foundation was used
as a landfill for process wastes until approximately 1968.
In 1968, the landfill was covered and used as a parking area.
In March 1969, a solvent-based scouring system was installed
at the mill. The scouring system used TCE to remove oil and
dirt from newly-woven fabrics. Shortly after the aystem was
installed, an unknown quantity of TCE was spilled during the
filling of an above-ground storage tank. The mill did not
clean up the spill. Some of the spilled TCE infiltrated into
the soil and entered the groundwater. The remainder of the
TCE ran off into the Branch River. The mill continued to
operate the scouring system until the mill closed in 1975.
In October 1977, a fire destroyed the mill complex. Since
that time the property has remained vacant-and unused. The
Site is currently overgrown and contains rubble, piles of
debris, and the remains of the building's foundation
(including a deteriorating smokestack). A more detailed
description of the site history can be found in the RI, pages
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1-4 through 1-7.
In 1979, TCE was detected off-site in the Forestdale Water
Association. well, a community water. system located
approximately 800 feet north of the Site. This sampling was
conducted by the Rhode Ialand Department of Health (RIDOH) as
part of a statewide groundwater survey. RIDOH then expanded
the groundwater sampling program to include an additional 51
private residential wells in the Forestdale area. As a result
RIDOH found elevated levels of TCE in 18 of these residential
wells and advised area residents to boil water used for
drinkinq and cooking.
,
.
In 1981, the State of Rhode Island Water Resources Board and
the Town of North Smithfield financed the construction of a
municipal water main to aerve the residential area north of
the Site that had been affected or bad the potential to be
affected by conta~1nation from the Stamina Mills Site.
Between 1981 and 1984, only seven of the approximately 50
affected or potentially affected residences had been connected
to the new municipal water supply, reportedly because of the
costs associated with connecting to the water main.
On September 8, 1983 the Site was placed on the final National
Priorities List (NPL) and later that month EPA began to supply
bottled water to residents not connected to the municipal
water supply. During November 1984 EPA initiated an immediate
removal action under the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA) 1104(a), 42
V.S.C. 19604(a) (1984) to extend the existing water line as
well as fund the residents' costs for connecting to the
municipal water supply. In July 1988, EPA initiated a second
removal action at the Site which dealt with two deteriorating
underground storage tanks. The contents of both tanks were
removed and then treated and disposed of off-site. The
interiors of both tanks were decontaminated and the tanks were
then decommissioned. In Auqust 1990, EPA initiated a third
removal action which removed the contents of an above-ground
storage tank. The contents were treated and disposed of off-
site. The interior of the tank was decontaminated and the
tank shell was left on-aite and will be disposed of during
remedial activities. A more detailed description of the Site
history can be found in the RI at pages 1-7 through 1-8.
8.
Bnforc...nt Hiatory
.-
On September 19, 1984, EPA notified the owner of the Site at
the time of the spill, Kayser-Roth Corporation, of its
potential CERCLA liability with respect to the Site. In
addition, on October 23, 1984, EPA notified the current owner
of the Site, Hydro-Manufacturing Company, of its potential
CERCLA liability with respect to the Site. In the absence of
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an offer by Kayser-Roth or Hydro-Manufacturing to reimburse
the government for the costs of the removal actions and to
fund the remediation of the site, EPA filed suit against both
companies in federal district court on May 23, 1988.
In July 1989, EPA entered into a partial consent decree with
Hydro-Manufacturing in 8ettlement of the company's liability.
The consent decree, with subsequent modifications, has been
lodged with the district court.
On October 11, 1989, the district court ruled that Kayser-Roth
is liable under CERCLA fo~ cleanup costs at the site. The
court entered a declaratory jUdgement on January 16, 1990,
holding lCayser-Roth ~iable for all past and future costs
consistent with the Act:. . JCayser-Roth filed an appeal on
April.5, 1990. On August 2, 1990, the Court of Appeals for
the First Circuit affirmed the district court's ruling.
Technical comments on the proposed plan were first presented
by representatives of Kayser-Roth at the informal public
hearing during the public comment period. A summary of the
comments received during the meeting as well as the written
comments are included in the Administrative Record.
III. COMMUNITY PARTICIPATION
Throughout the Site's history, community concern and involvement
has been moderate to low. EPA has kept the community and other
interested parties apprised of the Site activities through
informational meetings, fact sheets, press releases and public
meetings.
During December 1986, EPA released a community relations plan which
outlined a program to address community concerns and keep citizens
informed about and involved in activities during' remedial
activities. On March 10, 1986, EPA held an informational meeting
in the Municipal Annex Building, North Smithfield, Rhode Island to
describe the plans for the Remedial Investigation (RI) and
Feasibility Study (FS). On February 21, 1990 EPA beld an
informational meeting in the Municipal Annex Building, North
Smithfield, Rhode Island to discuss the results of the RI.
On March 22, 1989, EPA made the administrative record available
for public review at EPA's offices in Boston and at the North
Smithfield Public Library. Additional materials were added to the
Administrative Record on February 12, 1990 with the release of the
RI and on July 10, 1990 with the release of the FS and the Proposed
Plan. EPA published a notice and brief analysis of the Proposed
Plan in the Woonsocket Call on June 29, 1990 and made the plan
available to the public at the North Smithfield Public Library. .
On July 10, 1990, EPA held an informational meeting to discuss the
cleanup alternatives presented in the Feasibility Study and to
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present the Agency's Proposed Plan. Also during this meeting, the
Agency answered questions from the public. From July 11 to
'August 9, the Agency held a 30-day public comment period to accept
public comment on the alternatives presented in the Feasibility
study and the Proposed Plan and on any other documents previously
released to the public. On July 31, 1990, the Agency beld a public
meeting to discuss the Proposed Plan and to accept any oral
comments. A transcript of this meeting and the comments and the
Agency's response to comments are included in the attached
responsiveness summary found in Appendix C of this document.
IV.
SOOPI: UD JtOLB 07 UBPO.SB AC'UOH
The selected remedy was developed by cOmbining components of
different source control and management of migration alternatives
to obtain a comprehensive approach tor Site remediation. In
summary, ~he remedy provides for the treataent of contaminated soil
in the TCE spill area, the excavation of landfill wastes within the
100-year floodplain of the Branch River and consolidation with
landfill wastes above the floodplain, construction of a leachate
collection system and an impermeable cap over the on-site landfill,
and the confirmation of the Mills' septic tank location and
disposal of its contents. These activities constitute the source
control measures that will be undertaken to remediate areas which
are acting as sources of contamination to the groundwater and
surface water.
The remedy also includes the extraction and treatment of
contaminated groundwater as well as the sealing and filling of the
existing on-site raceways. These constitute the management of
migration measures. They address the contaminated groundwater
plume which has migrated beyond the Site boundaries and the
migration of contaminants into the Branch River via the raceways.
Prior to safely implementing either the source control or
management of migration alternatives discussed above, it will be
necessary to demolish the partially standing buildings at the Site
and thereby ensure the safety and protection of on-site workers.
The remedial action will address the principal threats identified
at the Site through treatment and will use engineering controls for
areas of the Site which pose a relatively low long-term threat,
consistent with the National Oil and Hazardous Substances Pollution
Contingency Plan 40 CFR 300.5, Federal Register, Vol,. 55, No. 46,
March 8, 1990 (NCP). Areas of the site which have be~n identified
as the principal threats include the TCE spill area soils and the
groundwater contaminant plume. The areas of the Site which are
believed to pose a lower long-term threat include the landfill,
raceways and septic tank. The remedial action will address the
following threats to human health and the environment posed by the
Site:
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1.
The off-site migration of contaminants;
The future ingestion of contaminated groundwater on-site
and off-site;
2.
3.
The direct contact with and ingestion of contaminated
soils, sediments, 801id waste.
v.
8UKKARY OP 8ITB CBA~CTBRI8TICS
Chapter 1.0 of the FS contains an overview of the RI. The study
area extends beyond the Site '.8 boundaries and includes
residential/ccmmercial areas that are bounded to the north and east
by Route 146, to the south by railroad tracks and to the west by
Roselawn Avenue (See Appendix A, Figure 1). These areas were
included to help delineate the extent of the contaminated
ground~ater pl~~ resulting from the TCE spill at the Site. The
significant findings of the RI are summarized below. A complete
discussion of Site characteristics can be found in the RI at pages
6-1 through 6-59.
A.
80il
The discussion of the types and nature of contaminants found
in the soil at the site follows the format described in the
RI and is broken up into the following three areas; 1) TCE
spill area, 2) landfill area, and 3) remaining areas of the
overall Site (Appendix A, Figure 5). These areas are
described separately because of their different physical
characteristics and chemical contaminants.
1.
TCE SDill Area
Soil in the TCE spill area consists mainly of granular fill
(e.g., sand and gravel), fragments of bedrock, and smaller
amounts of miscellaneous construction debris (e.g., brick,
concrete, and cinders). The thickness of this layer ranges
from 10 to 18 feet, with groundwater seasonally occurring in
the lower few feet.
Soils from the TCE spill area were found to contain the
highest concentrations of volatile organic compounds (VOCs)
detected at the site. Smaller concentrations of base neutral
compounds, pesticides, and metals were also detected in this
area as well as over most of the Site. TCE (detected in 71
of 80 soil samples) and its degradation product 1,2-
dichloroethylene (detected in 31 of 80 8amples) were the
principal VOCs detected in the spill area.
The following is a partial list of the volatile organic
compounds detected in the spill area:
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ComDound
concentration Ranae (DDb)
Trichloroethylene
1,2-Dichloroethylene
Methylene Chloride
Tetrachloroethylene
less
less
less
less
than 5 - 430,000
than 5 - 19,000
than 5 - 1,120
than 5 - 39
other VOCs which were detected less frequently in the spill
area and at much lower concentrations include toluene,
chlorobenzene, ethylbenzene, total xylenes, chloroform, and
1,1,1-trichloroethane.
The following were the principal .emi-volatile, base neutral
compounds detected in the spill area .oils:
C01IIDound
Concentration Ranae (DDb)
Chrysene
Pyrene
Benzo(a)pyrene
Benzo(a) anthracene
Phenanthrene
37 - 2,700
96 - 4,300
110 - 3,600
120 - 2,800
52 - 2,200
Pesticide compounds identified above their detection limits
and the range at which they were found include: dieldrin (1
- 200 ppb), endosulfan I (2 - 16 ppb), and endosulfan II (5
ppb). Thr~e other pesticides (Alpha BHC, Beta BHC, and 4,4'-
DDT) were detected in one soil sample each. No PCBs were
observed above the contract required quantitation limit
(CRQL) . The CRQL is the amount of a compound which is
necessary to produce a response that can be identified and
reliably quantified and is part of the EPA contract laboratory
program (CLP).
The following trace metals were among the ones that exceeded'
background levels and also typical ranges of trace metals
found in soils:
ComDound
Concentration Ranae (DDb)
Cadmium
Copper
Lead
Mercury
Vanadium
Zinc
7,000
45,000 - 139,000
78,000 - 880,000
2,000 - 4,000
37,000 - 506,000
90,000 - 542,000
The principal route of off-site migration of these
contaminants from the spill area is through leaching from the
soil into the bedrock aquifer located beneath it. Soil
sampling indicated that the highest concentrations of TCE were
found adjacent to where the TCE tank was reported to have been
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and where the spill occurred. In addition, sampling results
indicated that the TCE concentration increases with soil depth
in this area. The. higher concentrations of TCE in the deeper
soils are most likely due to two 8echanisms: 1) TCE near the
surface of the soil was able to volatilize easily irito the
ambient air, and 2) spilled TCE miqrated through the coarser
fill material near the surface and its progress was impeded
when it encountered the finer qrained material at the bedrock
surface. Further contaminant miqration through
volatilization, wind, and water erosion is not likely to be
significant because the concentrations of TCE and other VOCs
in the upper soil layers have,decreased to low levels as a
result of these processes.
2.
Lanaf!ll Area
The landfill wastes consist of a mixture of various fabric
wastes, plastic, paper, felt, wood, metal, brick, cinders,
glass, and rock interbedded with layers of sandy fill. The
material ranges in thickness from 2 feet to more than 19 feet.
The most prevalent contaminant types detected in the landfill
wastes were semi-volatile compounds, both base neutral and
acid extractable compounds. These compounds were found
distributed throughout the landfill material but the areas of
highest concentrations of total semi-volatile compounds were
found to correspond to sections of the landfill with depths
greater than 10 feet of landfill material (Appendix A, Figure
6). Concentrations of individual base neutral semi-volatile
compounds, primarily consisting of polycyclic aromatic
hydrocarbons (PAHs), -ranged between 40 ppb and 10,000 ppb.
The PAHs detected with the greatest frequency include:
ComDound
Concentration Renae (DDb)
Benzo(b)fluoranthene
Fluoranthene
Phenanthrene
Chrysene
Benzo(k)fluoranthene
Pyrene
Benzo(a)pyrene
Benzo(a) anthracene
Phenanthrene
41 - 8,300
41 - 9,100
48 - 8,700
66 - 5,100
43 - 8,300
48 - 8,700
40 - 4,900
40 - 5,000
52 - 2,200
Among the seven acid extractable compounds detected in the
landfill material only 4-methylphenol and benzoic acid were
found at concentrations above 8,000 ppb. The 4-methylphenol
and benzoic acid were detected as high as 100,000 ppb and
70,000 ppb, respectively.
TCE and other VOCs were detected in some of the landfill
-------
samples, but at much lower concentrations and frequencies than
the semi-volatile compounds. The concentrations of VOCs
detected in the landfill wastes did not exceed 2,500 ppb with
the exception of one sample in which 51,000 ppb of TCE was
detected. This .ample was taken at a depth of 13 feet below
the qround surface and at the time of .ampling this was
immediately above the water table. The other VOCs detected
in the landfill in order of decreasing frequency are 1,2-
dichloroethylene (2 - 980 ppb), toluene (5 - 81 ppb), and
chlorobenzene (31 - 97 ppb).
Of the pesticides tested for, ~ieldrin was detected the most
frequently (in 32 of 54 soiI aamples) and at the highest
concentrations (33 ppb to 17,000 ppb). Two other pesticides,
4,4'-DDD and 4,~'-DDT, were detected 18SS frequently and at
concentrations below 100 ppb. No PCBs were observed at levels
above the CRQL.
The following trace metals, among others, were detected in
the landfill wastes at concentrations in excess of both
background levels and published ranges typical of soils:
Comoound
Concentration Ranae (oob)
Cadmium
Copper
Lead
Arsenic
Vanadium
zinc
Antimony
3,000 -
45,000 -
70,000 -
18,000 -
24,000 -
91,000 -
120,000
17,000
2,130,000
1,380,000
71,000
427,000
1,900,000
The presence of some of the semi-volatile compounds,
pesticides, and metals in the groundwater beneath the landfill
is believed to be the result of the leaching of these
contaminants from landfill wastes. In addition, "there is
evidence based upon the erosional patterns shown in the steep
side slope of the landfill adjacent to the Branch River, and
the similarity of compounds detected in the sediment of the
river, that erosion is playing a part in the migration of
contaminants from the landfill into the Branch River.
The concentrations and locations at which TCE was detected in
samples obtained from landfill wastes ~o not indicate that
the TCE migrated from a source within the landfill. Test pit
activities carried out during the RI did not detect the
reported disposal of TCE still bottoms in" the landfill.
Rather, it appears that the TCE found in landfill wastes is
the result of TCE contaminated groundwater migrating from the
spill area through the raceway and sewer line into the
landfill area and then volatilizing into the landfill wastes. .
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3.
. OVerall site
The overall Site refers to the remaining areas of the five
acre site. These areas are primarily covered with piles of
rubble, partially collapsed buildings, or overqrown with weeds
and small trees. No laboratory analyses vere performed on the
on-site debris and building remains. A 8ample of 81udge from
the on-site 8eptic 8ystems drain pipe was 8creened in the
field during the RI and the results indicated the presence of
TCE. The septic tank itself is believed to be buried under
one of tbe piles of debris and therefore its contents could
not be tested during the RI to determine if TCE-contaminated
sludge were present. Based" . upon the results of the RI,
contaminants .detected in 80il 8amples from the overall Site
area were not acting as a 8ignificant miqration source to
either the qrounawater or 8urface water.
The types of compounds detected in soil samples from the
overall site are similar to those already described in the
TCE spill area and landfill area. Primarily low levels of
the. compound TCE, PARs, and metals were found throughout this
area. The low levels of these contaminants found in the soils
of the overall Site are believed to be associated with
residues produced during normal operations at the Mill. There
were no pesticides or PCBs found above their CRQLs in this
area.
TCE was detected in 12 of 45 soil samples in the overall Site
area and ranged from 2 ppb (estimated value below the CRQL)
to a high of 63 ppb. The 8ample with the highest TCE
concentration (63 ppb) was collected from within the ruins of
the former mill building. In addition to TCE, the following
VOCs were detected above their detection limits (in only two
or fewer soil samples out of 45): chloroform (1 - 27 ppb),
l,l,l-trichloroethane (19 ppb), methylene chloride (11 ppb),
and benzene (5 ppb).
Seventeen semi-volatile, base neutral compounds were detected
in soil samples from this area. The principal ones detected
include: .
C01r\Dound
Concentration Ranae (DDb}
Benzo(b)fluoranthene
Fluorantbene
Phenanthrene
Chrysene
Benzo(k)fluoranthene
Pyrene
Benzo(a)pyrene
Benzo(a) anthracene
Bis(2-ethylhexyl)phthalate
68 - 7,500
90 - 5,700
40 - 3,300
99 - 3,200
730 _. 7,500
33 - 6,000
120 - 2,900
71 - 4,500
130 - 1,300
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All of the base neutral compounds shown above wi th the
exception of the last are PARs. Although low levels of PARs
were found throughout. the overall Site, the highest
concentrations outside of the landfill area were confined to
one small area referred to as the "hot spot" which is located
just west of the partially .tanding mill building (Appendix
A, F iqure 5). The PARs detected in the -hot .pot" may be the
result of some former mill operation, the 1977 fire that took
place (the burning of wood produces PARs), or the location of
a nearby asphalt pad. Although this area of elvevated PARs
is referred to as a -hot spot" in the ~ and FS, the levels
af PAHs found in this area do not pose a risk to public health
and the environment. :
The fOllowing trace metals were among those detected in
samples obtained fram the overall Site which exceeded
published ranges typically found in soils:
ComDound
Concentration Ranoe (DDb)
Cadmium
Lead
Mercury
Selenium
1,000 3,000
4,000 - 2,340,000
100 - 2,000
3,000 - 4,000
The highest concentration of lead in a soil sample from the
overall Site (2,340,000 ppb) appears to be an anomaly, since
the second highest concentration is 65,000 ppb. The ranges
of metals detected in these samples from the overall Site also
served as "background levels" for the comparison of samples
from the landfill area and TCE spill area.
B.
Groundwater
The majority of groundwater at the Site is stored in and
transmitted through the bedrock aquifer located approximately
10 to 20 feet beneath the surface. '1'0 a lesser extent, the
lower few feet of the soil layer above this is seasonally
saturated. Under current conditions, with the residential
wells and the community well directly north of the Site not
pumping, the natural regional qroundwater flow is generally
toward the Branch River. The natural regional flow has been
shown to be affected by previous groundwater pumping activity
directly north of the Site. During the pump test conducted
as part of the ~, pumping of a the Forestdale Water
Association Well, a community well located north of the Site,
produced a reversal of the regional hydraulic gradient.
Reversal of the groundwater flow is. believed to be the
mechanism by which contaminants migrated from the Site to
residential wells north of the site.
In
1988,
the
groundwater
contaminant
plume
extended
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approximately 500 feet northwest of the TCE spill area and
then southeast towards the Branch River. The contaminant
plume appears, to be slowly reversing the previous trend of
northward migration based upon 1986 and 1988 groundwater
sampling results (Appendix A, Figure 7). TCE and its
breakdown products were found to be the maj or compounds
present in the contaminated groundwater. The highest
concentrations were found in the groundwater beneath the spill
area. The concentration of TCE in the groundwater in this
area had ranged as high as 850,000 ppb but during the most
recent sampling round (March, 1988) the highest concentration
detected was 290,000 ppb (Appendix A, Figure 8). The
following volatile organic compounds were the principal ones
detected in ~e 1IarCh, 1988 groundwater sampling round:
ComDound
Concentration Ranae (DDb\
Trichloroethylene
1,2-Dichloroethylene
Tol uene .
1,1-Dichloroethylene
Chloroethane
Vinyl Chloride
less than 5 -
32 -
9 -
12 -
2,200
129
290,000
31,000
16
36
TCE contamination is found to a depth of at least 175 feet in
the spill area as evidenced by the concentrations of 190,000
ppb detected in MW-10 in March 1988. Based on the high
concentrations of TCE detected in the groundwater, there is
a strong likelihood that a separate Dense Non-Aqueous Phase
Liquid (DNAPL) exits within the contaminant plume. If DNAPL
does exist, the higher specific gravity of TCE (when compared
to water) may increase ita downward migration through vertical
joints present in the fractured bedrock thereby extending the
contaminant plume. 'J'he presence of DNAPL in fractured bedrock
conditions such as those found beneath the Site will increase
the difficulty of extracting the contaminant plume and may
extend the time frame needed to meet groundwater cleanup
levels.
'1'0 a lesser enent, some .emi-volatile organic compounds,
trace metals, and pesticides have been found in the
groundwater beneath the 8i te. '!'bese compounds have been
primarily detected in the vicinity of the landfill. The
principal semi-volatile base neutral compounds detected in
March 1988, include:
ComDound
Bis(2-ethylhexyl)phthalate
1,2,4-Trichlorobenzene
1,2-Dichlorobenzene
1,4-Dichlorobenzene
1,3-Dichlorobenzene
Concentration.Ranae
less than 180 - 230
less than 10 '- 300
less than 10 - 14
less than 10 - 110
18 - 130
(DDb}
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Two semi-volatile acid extractable compounds, benzoic acid
and 2-methylphenol were found at concentrations below the CRQL
in the August 1986, sampling round. These compounds were not
detected in any subsequent groundwater sampling rounds.
The pesticides detected in ~e March 1988, sampling included
dieldrin (4 ppb), 4,41-DDE (0.48 ppb), and 4,41-DDD (0.54
ppb). One other pesticide, endosulfan I, was detected below
the CRQL. The metals that exceeded drinking water standards
in groundwater samples in March 1988, and ~e range of
detected values above the standard are: chromium (128 ppb -
190 ppb), iran (567 ppb - 14.0;100 ppb), manganese (76 ppb -
18,200 ppb) aDd zinc (710 ppb). ~ere were no PCBs found
above the CRQL 1D this area.
The semi-volatile compounds, pesticides, and metals detected
in the qroundwater in the vicinity of the landfill were found
primarily in two shallow wells. These two'wells, MW-4A and
MW-6A, were screened over intervals located in saturated
sections of landfill wastes (3 to 8 feet, and 11.5 to 21.5
feet, respectively) and which are located above the bedrock
aquifer. As part of the RI activities, two additional deeper
wells were placed into the bedrock aquifer, adjacent to the
shallow wells. These wells, MW-4 and MW-6, were screened over
intervals below all landfill wastes and unconsolidated
materials. .
The results of the sampling and analysis during the RI shows
that the contaminants detected in the groundwater beneath the
landfill were found primarily in the shallow wells. Based on
the depths over which both shallow wells were screened and
the physical description and characteristics of the wastes
encountered over these screened intervals (See RI, Appendix
A), EPA believes the vater sampled in the shallow wells is
representative of landfill leachate rather than qroundwater
found in the bedrock aquifer. .
c.
surface Water
The Branch River located just south of the site flows from
west to east in this vicinity. A dam constructed adjacent to
the site forms the eastern-most boundary of the Forestdale
Pond. The pond was bistorically used as a source of
hydromechanical power for Dill operations. Two "raceways" or
rock tunnels were constructed to lead water away from the pond
to the mill buildings (Appendix A, Figure 5).
The "old" raceway originates at the Forestdale Pond, directly
west of the dam and loops in an easterly direction through
the Site exiting to the river just east of the landfill. The
inlet is still visible: however, the outlet has collapsed and
sections of the raceway in the landfill are also believed to
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be collapsed. Based on test pit excavations during the RI
and evidence o~ water .eepage in the area where the outlet is
believed to be located, water continues to travel through the
tunnel.
'l'he "new" raceway also originates just west of the dam and
exits into the river just .outhwest of the landfill. 'l'he
raceway inlet and outlet are still intact and there is visible
evidence of water flowing through it.
Surface vater' and .ediment .amples were obtained from ten
locations along the Branch River during two aampling rounds
in the summer of 1986 and ona during June 1988. Sampling
locations included those adjacent to the site immediately
upstream and downstream, as wall as a background location
approximately one-quarter of a mile upstream, and a sampling
location approximately one-half mil. downstream to identify
any contaminant transport. In addition, aurface water samples
were taken at the entrance and exits of both raceways to
determine their impacts on the River.
'l'he results of tbe aurface water sampling indicate that
upstream of the em1D there were no detectable levels of 'l'CE or
other site-related contaminants auch as the pesticide
dieldrin. Downstream of the dam, TCE and its breakdown
product 1,2-dichloroethylene were found approaching the CRQL
(i.e., concentrations at or below 5 ppb). Higher
concentrations of 'l'CE and its breakdown products were found
in surface water samples obtained from within or near the
raceway exits as described below.
concentrations of 'l'CE and 1,2-dichloroethylene ranged as high
as 59 ppb and 48 ppb, respectively, outside the exit 'of the
new raceway. In addition, vinyl chloride was detected at this
location at approximately 5 ppb. No aemi-volatile compounds
(base neutrals and acid extractables) were detected .in any of
the surface water samples collected in July and August 1986
and only one compound, diethylphthalate, was found below its
CRQL in 1988. 'l'he only pesticide detected in the surface
water sampling was 4,4'-DDT which was detected at a
concentration of 0.13 ppb outside the new raceway exit in June
1988. 'l'he surface water sampling results for metals indicated
that a limited number of metals were found both upstream and
downstream of the dam and the concentrations found did not
indicate any discernable site-related trends. There were no
PCBs found above their CRQL8 in aamples from this area.
Although the exact mechanism by which the contaminants from
the Site are entering the raceways is unknown (i.e., whether
from groundwater migration or transport of 80il particles
through water erosion), both raceways were shown to be'
preferential pathways for the miqration of contaminants from
-------
the site into the Branch River. The evidence for this
preferential pathway is the elevated levels of site-specific
compounds found during the RI at the exit of the new raceway
and where the exit to the old raceway is thought to be
located.
D.
Air
Ambient air monitoring completed during the RI to quantify
air emissions at the Site under existing conditions did not
detect any volatile compounds. Three of the principal
volatile compounds detected in the soils at the Site, TCE,
trans-l,2-dichloroethylene, and tetrachloroethylene, were used
as target compounds for this air sampling effort. Other
contaminants detected at the Site, which include PARs,
pesticides, and metals were not analyzed for at the time.
These compounds were not tested for because their airborne
release is primarily associated with particulate or fugitive
dust emissions from bare soil areas. Since the Site is
heavily vegetated, dust emissions and airborne releases would
be limited and therefore these compounds would not be expected
to. pose a risk to public health and the environment. Any
future activities at the Site which would potentially generate
dust or particulate matter, would require ambient air
monitoring to protect public health and the environment.
E.
Sediment
As described in Section C above, sediment and surface water
samples were obtained from ten sampling locations along the
Branch River and three locations at or inside the raceway
entrances or exits. Because the dam is located adjacent to
the Site, sediment samples were easily obtained upstream of
the Site. Downstream of the Site there was very little
sediment to collect due to the velocity and scouring action
of the water flowing over the dam. The one exception to this
was a quiescent area located adjacent to the new raceway exit
and extending downstream to approximately the eastern boundary
of the landfill. Because the quiescent area is protected
somewhat from the main flow of the river, sediment and soil
have accumulated there. .
The trends shown for the sediment sampling results are similar
to those described for the surface water sampling. Upstream
of the daD, levels of TCE or other .ite~related contaminants
such as the pesticide dieldrin were not detected apove the
CRQL. Downstream of the dam, elevated levels of TCE and its
breakdown product 1,2-dichloroethylene were found, with the
highest concentrations between the new raceway exit and the
eastern boundary of the landfill (e.g., the quiescent area).
The concentrations of TCE and 1, 2-dichloroethylene ranged
between 6 to 240 ppb and 110 to 140 ppb, respectively, during
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the June 1988 sediment .ampling round in the quiescent area.
A number of semi-volatile base neutral compounds were detected
in the sediments obtained both upstream and downstream of the
dam. Of those compounds detected in June 1988, six were
detected only downstream of the dam and .ost of these were
detected in the vicinity of the collapsed old raceway exit.
These compounds and the range of concentrations found
downstream of the Site are: .
COmDOund
concentration Ranae
(DDb)
1, 2, 4-TricblorObenzene
Naphthalene
Acenaphthylene
Dibenzoturan
Fluorene
Dibenz(a,h}anthracene
130
100
170 - 180
200
140 - 250
110 - 130
All other base neutral compounds detected downstream of the
dam were also detected in sediment collected upstream.
However, many of these compounds found downstream were
detected in samples at concentrations an order of magnitude
greater which indicates that the Site is potentially
contributing to the presence of base neutral compounds in the
sediment of the Branch River.
The pesticides' dieldrin and 4,4' -DDT were identified in
several sediment samples. Five sediment samples contained
4,4'-DDT at concentrations ranging from 35 ppb to 200 ppb.
The highest concentration of 4,4' -DDT was detected in the
sediment sample furthest upstream of the dam and the Site.
Dieldrin was detected only downstream of the dam and ranged
as high as 1,700 ppb in a sediment .ample taken 40 feet
downstream of the landfill. In June 1986, PCB aroclor-1254
was detected at 980 ppb at the same sampling location as the
1,700 ppb dieldrin.
Therefore, based on these findings, the presence of pesticides
in Branch River sediments cannot be linked specifically to the
site with the exception of dieldrin. The trend seen for
metals in the sediments was similar to that of the surface
water. Elevated levels of metals were seen both upstream and
downstream and no discernable impacts on the sediment could
be linked specifically to the site. The presence of PCB
aroclor-1254 in the one sample downstream of the landfill is
not believed to be Site-related because the presence of PCBs
were not confirmed in any other soil samples taken at the
Site. A more detailed discussion of the impacts of the
contaminants from the Site on the Branch River can be found
in the Ecological Assessment which is included in Appendix E
of the FS.
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VI.
8t7KKARY OP SIT!: aI81tS
A risk assessment (RA) for the Stamina Mills Site was performed to
estimate the probability and magnitude of potential adverse human
heal th and environmental effects from exposure to contaminants
associated with the Site. '!'he public health risk assessment
followed a four step process: 1) contaminant identification, which
identified those hazardous substances which, given the specifics
of the Site were of significant concern: 2) exposure assessment,
which identified actual or potential exposure pathways,
characterized the potentially exposed populations, and determined
the extent of the exposure; 3). toxicity assessment, which
considered the types and magnrtude of adverse human and
environmental effects associated with exposure to hazardous
substances, and 4) risk characterization, which integrated the
three earlier steps to summarize the potential and actual risks
posed by hazardous substances at the site, including carcinogenic,
noncarcinogenic, and environmental risks. The results of the
public health risk assessment for the Stamina Mills site are
discussed below.
Twenty-three contaminants of concern, listed in Tables 1 through
8 found in Appendix B of this Record of Decision, were selected
for evaluation in the RA. These contaminants constitute a
representative subset of the more than 90 contaminants identified
at the Site during the RI. The twenty-three contaminants of
concern were selected to represent potential Site related hazards
based on toxicity, concentration, frequency of detection, and
mobility and persistence in the environment. Toxicity profiles
describing the health effects of each of the contaminants of
concern can be found in Appendix J, Volume 2 of the RI.
Potential human health effects associated with exposure to the
contaminants of concern were estimated quantitatively through the
development of several hypothetical exposure pathways. These
pathways were developed to reflect the potential for exposure to
hazardous substances based on the present uses, potential future
uses, and location of the site. The current exposure pathways for
the Site, which is presently abandoned and fenced, are through
contact with contaminated soil and indirectly through the
consumption of fish from the Branch River. There is no current
risk posed by ingesting groundwater from the Site since it is not
being used as a drinking water supply. Potential future exposure
pathways include contact with contaminated soil, ingestion of
groundwater and consumption of fish from the Branch River and are
based upon the assumption that the Site would not be cleaned up and
would be developed for residential use. Although the Site is
currently zoned for manufacturing, a conservative assumption was
made based upon the current residential nature of the area
surrcunding the Site, that it might be developed for residential
use sometime in the future.
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The followinq is a brief summary of the exposure pathways
evaluated. A more thorough discussion can be found in Section 7.3
through 7.4 of the risk assessment which is located in the RI.
For incidental ingestion and direct contact with contaminated soil,
the health risk was evaluated for a child between the ages of 2 and
6 who .ay be exposed on average 60 times a year and at a maximum
of 120 times a year for two hours per visit. Durinq that time the
child might ingest 50 mq of contaminated soil and absorb
contaminants from soil coverinq the childs forearms, hands, legs
and feet. For inqestion of groundwater used as a drinking water
supply, the health risk was evaluated for an adult who may consume
two liters per day for seventy years. For incidental ingestion
and dermal absorption ot 8urface" water, the heal th risk was
evaluated ~or a child between the aqes of ~ive and eiqhteen who
may accidently inqest and swim in contaminated surface water once
each year~ For incidental inqestion of sediments via the
consumption of fisb (it was assumed that the fish tissues are
contaminated to a level in e~i11brium with the sediments), the
health risk was evaluated for an adult consuminq 6.5 qrams of fish.
per day over seventy years. For each pathway evaluated, an average
and a reasonable maximum exposure estimate was generated
corresponding to exposure to the averaqe and the maximum
concentration detected in that particular medium.
Excess lifetime cancer risks were determined for each exposure
pathway by multiplying the exposure level with the chemical
specific cancer potency factor. Cancer potency factors have been
developed by EPA from epidemioloqical or animal studies to reflect
a conservative "upper bound" of the risk posed by potentially
carcinoqenic compounds. That is, the true risk is very unlikely
to be qreater than the risk predicted. The resultinq risk
estimates are expressed in scientific notation as a probability
(e.g. 1 x 10-6 for one in a million) and indicate (usinq this
example), that an individual is not likely to have greater than a
one in a million chance of developinq cancer over 70 years as a
result of site-related exposure as defined to the compound at the
stated concentration. CUrrent EPA practice considers carcinogenic
risks to be additive when assessing exposure to a mixture of
hazardous substances. The hazard index was also calculated for
each pathway as EPA's .easure of the potential for noncarcinoqenic
health effects. The hazard index is calculated by dividinq the
exposure level by the reference dose (RfD) or other sui table
benchmark for noncarcinoqenic beal th effects. Reference doses have
been developed by EPA to protect sensitive individuals over the
course of a lifetime and they reflect a daily exposure level that
is likely to be without an appreciable risk of an adverse health
effect. RfDs are derived from epidemioloqical or animal studies
and incorporate uncertainty factors to help ensure that adverse
heal th effects will not occur. The hazard index is often expressed
as a sinqle value (e.9. 0.3) indicatinq the ratio of the stated
exposure as compared to the reference dose value (In this example,
the exposure as characterized is approximately one third of the
-------
acceptable exposure level for the given compound). The hazard
index is only considered additive for compounds that have the same
or similar toxic endpoints. As an example, conversely, the hazard
index for a compound known to produce liver damage should not be
added to a second whose toxic endpoint is kidney damage.
Table 1 depicts the cumulative risk summary for the carcinogenic
and noncarcinogenic contaminants of concern for each pathway
analyzed. The hazard indices for the individual contaminants of
concern and. their target endpoints can be found in Appendix B of
this ROD. For a more detailed analysis on the risk for each
contaminant of concern, see Tables ~-44A through J-66A of the RI.
."
CUmulative potential cancer risks associated with ingestion of
groundwater fraa off-site active wells, incidental ingestion of
soils from the spill area, incidental ingestion of shallow soils
(0-5') fro. the landfill area, and incidental ingestion of soils
from the site proper did not exceed EPA's acceptable cancer risk
range of 10.' to 10.6. '!'be cwmlative hazard indices as a measure
of the potential for non-carcinogenic effects for ingestion of
groundwater from off-site active wells and incidental ingestion of
soils from the spill area, did not exceed unity. All off-site
wells that are no longer being used as a drinking water source, as
a result of the construction of the public water supply, are
considered inactive and were not included in the off-site active
well category.
Based on the findings in the Baseline RA, EPA has concluded that
the risk posed by the future ingestion of groundwater from the site
will exceed the acceptable risk range of 10.' to 10.6. The
principle contributors to carcinogenic risk from the ingestion of
groundwater are trichloroethylene and 1,2-dichloroethylene. The
maximum concentration 0% trichloroethylene detected on-site,
850,000 ppb, exceeded the Maximum contaminant Level of 5 ppb
promulgated in the Safe Drinking Water Act. Total 1,2-
dichloroethYlene was also found at high concentrations with a
maximum concentration of 31,000 ppb. The Maximum Contaminant Level
established in the Safe Drinking Water Act for 1,2-dichloroethylene
is 7 ppb.
The hazard index exceeds unity for the future ingestion of
groundwater from the Site for both the average and maximum cases.
Total 1,2-dichloroethylene is the major contributor for the
noncarcinogenic effects with a hazard index of 50. In addition,
under a potential future scenario in which the landfill area would
be developed, and deeper 80il& from within the landfill would be
brought to the surface, the hazard index for these exposed soils
would exceed unity. ~e principle contributor to the hazard index
for the deeper soils from within the landfill is dieldrin, having
The excess lifetime carcinogenic risk posed by eating the fish from
the Branch River have been predicted to exceed the acceptable risk
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IfUU 1
cumula~ive Carcino~enic Ri8k ..~ima~e8 and cumula~iv.
Hazard xndioe8 bv EzD08ure Pa~bYav
zxp08ure Pa~bYay
Present
Ingestion of Groundwater,
Off-site Active Wells
Incidental Ingestion of
Soil, TCE Spill Area
Incidental Ingestion of
Soil (0 - 51), Landfill Area
Incidental Ingestion of
Soil (0 - 51), Soil outside
of Landfill and Spill Area
Cngestion of Sediments via
Fish, Downstream of ~ite
Ingestion of Sediments via
Fish, Upstream of site
Incidental ingestion of
Surface Water
Cancer Ri8k
Avera~e Maximum
Hazard Index
Avera~. Maximum
3X10.6 3X1p.6
1X10.'
3X10.'
2X10.6 8X10-.6
1X10.'
6X10.'
2X10.6 2X10.'
6X10.'
3XlOO
lX10.6 lX10.5
7X10.Z lX100
aXlO.) 3XlO.2
6X10.'
2X100
4X10.3 4X10.3
2X10.3 2X10.3
5xlO.7 6XlO.7
2xlO.Z 4xlO-2
7uture 8XlO.z 4X10.' 5XlO' 2Xl02
Ingestion of Groundwater,
Tce Spill Area
Ingestion of Groundwater, 2X10.z 7X10.z 3X10' 6X10'
Landfill Area
Ingestion of Groundwater, 3X10.6 3X10.6 lX10.' 3X10.'
Off-site Active Wells
Incidental Ingestion of 2X10.6 3X10.6 5X10.' 6X10o
Soil (5 - 201), Landfill Area
a hazard index of 5.
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-4 -6 i .
range of 10 to 10 . Th s is based on the assumption that contam1nant levels
in fish tissue are in equilibrium with contaminant levels found in sediment
from the river. The principle contributors to the predicted carcinogenic
risk are the PARs and the pesticide dieldrin. The total hazard index for the
most probable (average) case for the noncarcinogenic risk posed by eating
fish tissue is less than one. However for the maximum case the hazard index
is 2. Dieldrin is the compound of particular concern, having a hazard index
of 2.
An ecological assessment was also completed for the Site. The ecological
assessment found in Appendix E of the FS is a qualitative appraisal of the
potential effects and risks of hazardous.8ubstances found at the Site on the
environment (specifically target species. of the fish population found in the
Branch River). Using the quantitative information generated from the RI, the
assessment compares the concentrations of contaminants reported at the site,
to those reported in available literature, and subsequently, attempts to
define more clearly the potential ecological impacts from the Site. The main
conclusion of the ecological assessment is that there is some potential for
adverse impacts on the fish population in the Branch river due to
contaminants being released fram the Stamina Mills Site. Specifically, the
elevated concentrations of dieldrin detected in the sediments of the Branch
River, which are being released from the Site, pose a threat to the
environment. The higher concentrations of some contaminants found in the
furthest upstream sample, which is located well above where contaminants
. could be attributed to the Site, indicates that sources besides the Site may
be effecting the environment.
Consequently, the Stamina Mills Site remediation shall strive to achieve
cleanup levels for soil and groundwater that are protective of public health
and the environment. Actual or threatened releases of hazardous substances
in groundwater from the Site, if not addressed by implementing the response
action selected in this ROD may present an imminent and substantial
endangerment to public health, welfare or the environment.
VII. DEVELOPMEN'l' AND SCREENING 01' AL'1'BRHATIVES
A. Statutory Requirements/Respon.. O~j.ctiv.s
Under its legal authorities, EPA's primary responsibility at Superfund
sites is to undertake remedial actions that are protective of human
health and the environment. Zn addition, Section 121 of CERCLA
establishes several other statutory requirements and preferences,
including: a requirement that EPA's remedial action, when complete,
must comply with all federal and more stringent state environmental
standards, requirements, criteria or limitations, unless a waiver is
invoked; a requirement that EPA select a remedial action that is cost-
effective and that utilizes permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximu~
extent practicable; and a preference for remedies in which treatment
which permanently and significantly reduces the volume, toxicity or
mobility of the hazardous substances is a principal element over-
-------
remedies not involving such treatment. Response alternatives were
developed to be consistent with these conqressional mandates.
Based on preliminary information relating to types of contaminants,
environmental media of concern, prior and present use of groundwater as
a drinking water source, and potential exposure pathways, remedial
action objectives were developed to aid in the development and screening
of alternatives. These remedial action objectives were developed to
. mitigate existing and future potential threats to public health and the
environment. These response objectives were:
1.
Restore 'the C)%'oundwater to ,ederal and state drinking water
standards (or criteria when. drinking water atandards are not
available) as quickly as possible because the aquifer is a drinking
water source.
2.
Prevent the public fr01l direct contaat with contaminated soils,
sediments, and solid vastes which .ay present health risks.
Eliminate or minimize the migration of contaminants from the soil
into the groundwater.
3.
4.
Prevent the off-site migration of contaminants to the surface water
above levels protective of public health and the environment.
Reduce risks to huaan health associated with the physical hazards
while. implementing remedial actions at the site.
5.
B. Tecbnoloqy and Alternative Development and screening
CERCLA and the NCP set forth the process by which remedial actions are
evaluated and selected. In accordance with these requirements, a range
of alternatives vas developed for the site.
with respect to source control, a range of alternatives was developed
in the RI/FS, in which treatment reducing the toxicity, mobility, or
volume of the hazardous substances was a principal element. This range
included an alternative that removes or destroys hazardous substances
to the maximum extent feasible, eliminating or minimizing to the degree
possible the need for long term management. This range also included
alternatives that treat the principal threats posed by the site but vary
in the degree of treatment employed and the quantities and
characteristics of the treatment residuals and untreated waste that must
be managed1 alternatives that involve little or no treatment but provide
protection through engineering or institutional controls 1 and a no
action alternative.
with respect to qroundwater response action, the RI/FS developed a
limited number of remedial alternatives that .attain site specific
remediation levels using different technologies: and a no action
alternative.
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Section 3 of the FS identified, assessed and screened technologies based
on implementability, effectiveness, and cost. These technologies were
combined into source control (SC) and management of migration (MM)
alternatives. Section 3 of the FS also presented the remedial
alternatives developed by combining the technologies identified in the
previous 8creening process in the categories identified in Section
300.430(e) (3) of the NCP. The purpose of the initial screening was to
narrow the number of potential remedial actions for further detailed
analysis while preserving a range of options. Each alternative was then
evaluated and screened in Section 4 of the FS.
In su~~ary, of the nine source control and ten management of migration
remedial alternatives screened in Section 4, thirteen were retained for
detailed analysis. It 8hould be noted that among the ten remedial
alternatives being classified under the category of management of
migration, five specifically address existing physical conditions at
the Site. Because these five also address the remediation of the on-
site raceways which have been shown to be a pathway for the preferential
migration of contaminants, they are also being classified as management
of migration alternatives. Table 4-2 in Section 4 of the FS identifies
the thirteen al ternati ves that were retained through the screening
process, as well as those that were eliminated from further
consideration.
VIII.
DESCRIPTION OP ALTERNATIVES
This Section provides a narrative summary of each alternative evaluated.
A.
Source Control (SC) Alternatives Analyzed
As described in Section V of this document and Section 4 of the FS, the
Site consists of a number of areas with different physical
characteristics and chemical contaminants (Appendix A, Figure 9). As
a result, separate source control measures have been developed for both
the TCE spill area (identified as TSA alternatives) and landfill area
(identified as LA alternatives). The source control alternatives
analyzed for each of these areas include the following:
TCE SDill Area ITSA)
TSA-l:
Excavation and On-site Incineration;
TSA-3:
Soil Vacuum Extraction;
TSA-4:
No-action Alternative;
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Landfill Area (LA)
LA-l:
Excavation and On-site Incineration;
LA-S:
Capping Including Consolidation:
No-action Alternative.
LA-3:
1.
'IC. 81)111 area
.
~~1 .
Excavation and on-site Xncineration
This alternative would involve the excavation and incineration of
approximately 6,000 cubic yards of TCE contaminated soils. TCE
contaminated soils would be excavated to the groundwater table and then
processed and separated as necessary to prepare them for incineration
in a mobile rotary kiln. The soils in the TCE spill area have been
identified as one of the principal threats found at the Site and
therefore the use of treatment to remediate this area is preferred by
EPA.
The efficiency of rotary kiln incinerators for destroying organic
hazardous materials is well proven and a destruction and/or removal
efficiency (DRE) of 99.99% or greater is anticipated for TCE and other
VOCs in soils from the TCE spill area. During the excavation of
contaminated soils a foaming agent or other synthetic material would be
employed to suppress dust and vapor emissions. Stockpiled soil would
be stored in a lined containment area and will remain covered with
polyethylene sheeting.
Materials excavated from the spill area which are not suitable for
incineration would be disposed of.in accordance with Rhode Island Solid
Waste and Hazardous Waste Regulations. Because the TCE contaminated
soil is considered a listed hazardous waste under the Resource
conservation and Recovery Act of 1976, as amended, 42 C.S.C. 6901 ~
~. (RCRA), and the excavation, 'treatment, or disposal of contaminated
soils is considered placement, RCRA, Land Disposal Restrictions (LORs),
and Rhode Island Hazardous Waste Regulations are all important
applicable or relevant and appropriate requirements (ARARs) for this
alternative. A brief discussion of ARARs can be found on page 69 of
this document. Both state and federal air emission standards are ARARs
for any type of incineration.
Before implementing this alternative, site preparation activities
including grading, .taging pad construction, .ecurity fence
construction, and utility hookup will have to be completed. Prior to
the full-time operation of the incinerator, a aeries of test burns would
be required to determine the optimum operating parameters of the rotary
kiln. The principal residue expected to be produced during the
-------
operation of the incinerator is bottom ash: smaller quantities of
scrubber liquor and fly ash are expected to be produced. The bottom
ash, which is composed primarily of the inert inorganic elements of the
soil, would require testing to determine whether it exhibits a RCRA
hazardous waste characteristic. In the event that the bottom ash is a
hazardous waste, it would be treated consistent with the appropriate
federal and state hazardous waste regulations and LDR requirements and
disposed of at an off-site RCRA facility. The scrubber liquor and fly
ash are residues from the pollution control equipment used for treating
air emissions. The fly ash and scrubber liquor will also require
testing and, based upon the results, would be disposed of appropriately.
The options being considered for the scrubber liquor include: disposal
into a municipal .ewer with or withOUt treatment and on-site or off-site
treatment.
ESTIMATED TIME FOR CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED 0 , M (Cost/Year):
ESTIMATED TOTAL COST (Present worth):
TSA-J .
Soil Vacuum Extraction
3 Months
2.5 Years
$ 9,994,150
$ 100,000
$10,690,620
This alternative would use in-situ soil vacuum extraction to actively
remove TCE and other volatile organic compounds from the soil.
Contaminant laden air would be treated using vapor phase granular
activated carbon (GAC). Shallow wells would be installed to a depth of
ten feet, or far enough above the water table to avoid the extraction
of excess moisture. A plastic ground cover may be required to be
installed over the surface of the TCE spill area soils to minimize the
infiltration of air and precipitation. This will be decided during the
design phase or during the start up phase of the operational period.
Vacuum extraction has been shown to remove as auch as 99.99 percent of
similar VOCs from soils. A removal efficiency of 97 percent for TCE
would result in residual levels below the cleanup levels. 50il sampling
would be done to confirm that the technology reduced contaminants to
protective levels.
The technology, although proven for the type of contaminants found at
the Site, does have some uncertainties which .ay affect the exact time
frame required for cleanup. The physical properties of the chemicals
being removed (e.g., Henry's Constant) and the soil being cleaned up
(e. g. , permeability) both play an important role ln affecting the
cleanup time frame. These physical properties can be estimated using
calculated or laboratory derived values to obtain a rough estimation of
the cleanup time frame. Because the values being used for the physical
properties are not necessarily site-specific, the accuracy of the
estimated cleanup time would only be known once the system is
operational. Therefore, until the system is operational and field data
is available a more refined cleanup time frame cannot be estimated.
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The vapor phase GAC .ystem that would be used to meet air emission
standards would require the off-site transport of spent activated carbon
for treatment and. regeneration. It is also possible that a liquid
residue associated with condensate from the vapor stream may be
produced: this would be either combined with extracted groundwater for
treatment on-site or be shipped off-site for treatment. Because the
.oils from the TCE spill area are considered a listed RCRA hazardous
waste, any residues derived from the treatment of the soil would also
be considered a hazardous waste. Therefore, .tate and federal Hazardous
Waste Requlations, and state and federal air emission standards are the
major ARARs for this alternative. 80il vacuum extraction is considered
an in-situ activity, and as 8uch, there is no excavation or placement
of a RCRA wasta. Therefore, LDRs sr. 'not con.idered an ARAR.
ESTIMATED TIME Foa CONSTRUCTION:
ESTIMATED 'l'DIE POR OPERATION:
ESTIHATED CAPITAL COST:
ESTrMATED 0 , M (Cost/Year):
ESTIMAXED TOTAL COST (Present wortb):
TSA-4
No-Action
2 Months
1 Year
$266,465
$ 1,500
$280,605
This alternative is included in the FS, 85 required by CERCLA, to serve
as a basis for comparison with the other source control alternatives
being considered for the TCE spill area.
The no-action alternative for the TCE spill area would not involve any
treatment of the contaminated soils. However, in order to provide
minimal protection of human health and the environment, the no-action
option would require the placement of a vegetative soil cover over the
spill area. The soil in the spill area would be cleared and graded to
provide surface runoff, and then covered with clean fill and vegetated
with a low .aintenance growth cover. Institutional controls would be
implemented to limit future use of the area. A long-term groundwater
monitoring program, which would be implemented along with the
groundwater extraction and treatment alternative selected, would provide
further information on the migration of contaminants from spill area
soils if the no-action alternative were to be chosen. The no-action
alternative does not help meet any identified ARARs. Indeed, the no-
action alternative would impede the restoration of the groundwater to
federal and state drinking water standards because the TCE spill area
soils would continue to serve as a source of contamination of the
groundwater.
ESTIMATED TIME FOR CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED 0 , M (Cost/Year):
ESTIMATED TOTAL COST (Present worth):
27
2 Months
2 Months
$40,140
$ 1,500
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2.
Landfill Area
lA-l
Excavation and On-site Incineration
This alternative would involve the excavation and incineration of
approximately 12,300 cubic yards of landfill 50ils and wastes and
involves equipment and operations similar to TSA-l. Landfill soils and
wastes would be excavated, aeparated, and processed as necessary, to
prepare them for incineration in a mobile rotary kiln. Because of the
variety of materials which were place in the landfill, it is expected
that landfill wastes will require a greater effort to 50rt than the TCE
spill area 50ils. It is also expected for this same reason, that a
larger vol~ o~ 8aterials will be generated which cannot be
incinerated.~be vastes that cannot be incinerated, which may include
discarded mill equipment and building debris, may require some type of
decontamination prior to tbeir disposal. The disposal will be in
accordance with federal and state solid waste requirements.
The efficiency of rotary kiln incinerators for destroying organic
hazardous materials is well proven and a destruction and removal
efficiency (DRE) of 99.99% or greater is anticipated for the organic
materials in the landfill area. Material of an organic nature makes up
a majority of the volume of landfill wastes expected to be excavated,
but smaller quantities of inorganic compounds, primarily trace metals,
were found in the landfill as described in Section V .A. 2. of this:
document. Most trace metals would not be removed by incineration ar\
will accumulate in the bottom ash. During the excavation of landfill
wastes a foaming agent or other synthetic material would be employed to
suppress dust and vapor emissions. Stockpiled landfill wastes would be
stored, prior to disposal, in a lined containment area and would remain
covered with polyethylene sheeting.
The major ARARs for this alternative would be similar to those described
for TSA-l and include state and federal Hazardous Waste Regulations, and
federal and state air emission standards. Since the landfill is
considered a wetlands under state regulations, state laws concerning
the protection of wetlands will be an ARAR. In addition, sections of
the landfill are in the 100-year floodplain of the Branch River and
federal policies regarding floodplains would be considered.
Landfill wastes are not known to contain listed RCRA wastes, but further
testing would be needed to determine if the wastes exhibit a hazardous
waste characteristic. If the wastes exhibit a RCRA hazardous waste
characteristic then LDRs would be applicable to this alternative. Even
if the wastes do not exhibit a RCRA hazardous waste characteristic, the
toxicity of the compounds already found in the landfill would make LDRs
relevant and appropriate for this alternative. It is expected that
incineration could achieve the treatment limits established by the LDRs.
Before implementing
including grading,
this alternative, site preparation activities
staging pad construction, security fe~=e
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construction, and utility hookup would have to be completed. Prior to
the full-time operation of the incinerator a series of test burns would
be required to determine the optimum operating parameters of the rotary
kiln.
The principal residue expected to be produced during the operation of
the incinerator is the bottom ash with smaller quantities of scrubber
liquor and fly ash produced. Bottom ash, which is composed primarilY
of the inert inorganic elements (i. e., trace metals), would require
testing to determine if it exhibits a RCRA hazardous waste
characteristic. In the event that the bottom ash is a hazardous waste
it would be treated consistent wi~ LDRs and disposed of in a RCRA
facility, off-site, in conformance with state and federal requirements.
The scrubber liquor and fly ash are residues from the pOllution control
equipment used for ~ting air ..issions. The fly ash and 8crubber
liquor wi11 also reqnire testing, and based upon the results, will be
disposed of appropriately. ~e optians that were considered for the
waste scrubber liquor include: disposal into a municipal sewer with or
without treatment and on-site or off-site treatment.
ESTIMATED TIME FOR CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED 0 , M (Cost/Year):
ESTIMATED TOTAL COST (Present worth):
3 Months
3 Years
$17,960,700
$ 100,000
$18,815,840
LA-3
CaDDina Includina Consolidation
This alternative would involve the consolidation of approximately 550
cubic yards of landfill wastes beneath a new multi-layer cap to be
installed on the landfill. A schematic of the mUlti-layer cap, designed
to meet the requirements of RCRA (40 CFR Part 264, Subpart N), and the
proposed limits of excavation can be found in Appendix A, Figure 10.
Emissions created by the excavation would be minimized by using a
foaming agent or other synthetic material to cover excavated wastes.
Erosional control measures would be implemented during excavation of
landfill wastes and consolidation activities to reduce the potential
effects on the adjacent Branch River. Once the waste is removed from
the 100-year floodplain of the Branch River, and the side slopes of the
landfill have been stabilized and covered. with a RCRA cap, the area of
the landfill subject to the 100-year flooding would be .further protected
by placement of a stone layer (e.g., rip-rap) over it.
The multi-layer cap system will include a vegetative layer, a drainage
layer, and an impermeable barrier (e.g., a low permeability barrier of
clay and synthetic liner material). A leachate collection system is to
be constructed along the southern toe of the landfill. Any leachate
generated would be discharged into the existing on-site sewer line,
subject to meeting all state of Rhode Island pre-treatment requirements
and receiving approval from the Woonsocket wastewater treatment plant.
The leachate generated from the landfill is not expected to exceed pre-
-------
treatment standards and therefore require treatment prior to its
discharge into the sewer system based upon data obtained during the RI.
An environmental monitoring program consisting of surface water and
sediment sampling in the Branch River will be implemented to assure that
the leachate collection system is meeting the response objectives of
this Record of Decision. The details regarding the environmental
monitoring program, including the frequency of sampling, sampling
locations, and parameters to be sampled will be decided during the
design phase..
A passive qas collection .ystem may ~e required to control the potential
releases of volatile emissions. The cap design would incorporate the
existinq manholes which currently provide access to the on-site sewer
line traversinq the landfill. The manholes will be raised to the new
surface of the cap to continue to provide access to the sewer line.
Institutional controls in the :fora ot deed restrictions would be
implemented to limit further land use of the landfill area. EPA has
proposed, in a consent decree lodged in federal court, institutional
controls with the current owner -- Hydro-Manufacturinq -- to protect the
remedy. An extended policy of inspections and maintenance would be
needed over the life of the landfill to insure that the remediation
goals continue to be met over time.
Because of the location of the landfill, as explained under LA-1 above,
state wetland requirements and federal floodplain policies are ARARs
for this alternative. One of the purposes of state and federal
hazardous waste regulations is to minimize the risks posed by hazardous
wastes by providing for their safe disposal. Al thouqh no known
hazardous wastes were disposed of in the landfill, other hazardous
substances as defined by CERCLA have been disposed of there. These
hazardous substances disposed of in the landfill present a potential
risk to public health a'nd the environment. Since the disposal of
hazardous substances in the landfill at the Site presents circumstances
sufficiently similar to those beinq requlated under state and federal
hazardous waste requlations, the~e requlations would be relevant and
appropriate to the closure of the on-site landfill. RCRA LDRs are not
an ARAR for LA-3 because all wastes to be excavated are either within
the confines of the existinq landfill or contiquous to the landfill:
therefore, there will be no "land disposal" within the meaning of RCRA.
Wastes identified in the landfill area bave been found to contribute a
lower lonq-term threat than the principal threats identified at the
Site. Therefore, in accordance with the NCP it is appropriate to
consider enqineerinq controls, such as containment, to address these
threats.
ESTIMATED TIME FOR CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED 0 , M (Cost/Year):
ESTIMATED TOTAL COST (Present worth):
30
6 Months
30 Years
$ 587,750
$ 62,000
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LA-5
No-Act.ion
This alt.ernat.ive is included in the FS, as required by CERCLA, to serve
as a basis for comparison with the other 80urce control alternatives
being considered for the landfill area.
The no-action alternative for the landfill area would not involve any
treatment of the contaminated 80ils and materials. However, in order
to provide minimal protection of human health and the environment, the
no-action option would require the placement of a vegetative soil cover
over the landfill area. 1'be area would be cleared and graded to provide
. surface runoff, and ~en covered with clean fill and vegetated with a.
low maintenance growth cover.
Ingtitutianal control. would ~e implemented ~o limit future use of the
area. A lOmJ-term qrcn:mawater acmi'toring program, which would be
implemented along with the groundwater extraction and treatment
alternative selected, would monitor the groundwater in the vicinity of
the landfill area. Contaminants from the landfill have been detected
in sediments found in the Branch River and this alternative would not
eliminate the continued release of contaminants from the landfill into
the river. Therefore, this alternative does not help meet any
identified ARARs.
ESTIMATED TIME ~OR CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED 0 & M (cost/Year):
ESTIMATED TOTAL COST (Present worth):
2 Months
2 Months
$ 30,140
$ 18,500
$204,540
, B.
Management of Kiqration (MM) Alternatives analyzed
Management of migration alternatives address contaminants that have
migrated from the original source of contamination. At the stamina
Mills site, contaminants have migrated from the TCE spill area into the
bedrock aquifer beneath the site as well as into, the on-site raceways
and from there into the Branch River. As discussed in section v.c. of
this document, contaminated groundwater i. currently found approximately
500 feet northwest of the site as a result of pumping activities of
residential wells and a community well north of the site. The plume
appears to be slowly recedinq toward the spill area and the Branch
River, now that pumping activities directly north of the site have
ceased. The management of migration alternatives evaluated for the Site
have been divided into two groups. The first group addresses the
extraction and treatment of contaminated groundwater in the bedrock
aquifer and the second addresses the migration of contaminants through
the on-site raceways. The filling and 8ealing of the raceways is only
one component of the overall Site remedy which also deals with the
buried on-site septic tank, demolition of partially standing structures,
and removal of debris piles.
-------
contaminated groundwater has been identified as one of the principal
threats found at the Site and therefore the use of treatment in
remediating the groundwater is preferred by EPA. The migration of
contaminants through the raceways is believed to contribute a lower
long-term threat than principal threats identified at the Site, and
therefore, it i. appropriate to consider engineering controls, such as
contairmaent, to address this threat. The following management of
migration alternatives were developed for the groundwater extraction and
treatment and overall Site:
GW-1:
Groundwater Extraction and ~atment lGW)
Air Stripping;
GW-2:
GW-4:
GW-5:
Granular Activated Carbon;
Ultraviolet Light and Hydrogen Peroxide;
No-action;
Overall Site (OS)
OS-3:
OS-4:
OS-5:
Building Demolition, Sealing Raceways, Location and
Excavation of Septic Tank, and Site Grading:
Building Demolition, Sealing Raceways, Location and
Excavation of septic Tank, Excavation of PAH "Hot Spot" I'
Site Grading:
No-action.
1.
Groundwater Extraction and Treatment
As identified in Section 4 of the FS, the principal objectives for the
groundwater remedial action is to return the groundwater within the
contaminated plume to federal and state drinking water quality standards
within a reasonable time frame. EPA's preference for contaminated
groundwaters that are currently a source of a drinking water supply,
such as those found in the bedrock aquifer at the Site, is to design an
extraction and treatment system for rapid restoration, when technically
practicable. The minimum restoration time frame for the site will be
determined by hydrogeological conditions, physical properties of
contaminants found in the groundwater at a site, and the size of a
plume. EPA is aware that the subsurface conditions found at the Site
present inherent difficulties that may affect achieving the cleanup of
the groundwater in the time frame estimated for all treatment
alternatives, approximately 10 to 15 years. As a result, EPA will
conduct a complete evaluation of the treatment system within five years
of the start up of the treatment system, regardless of which treatment
system is chosen. If the evaluation reveals that the remedy cannot
achieve the stated cleanup levels, or that they cannot be reached in a
reasonable time frame, then consideration will be given to making
-------
{)
changes in the remedy.
The groundwater beneath the Site has been classified under the draft,
state of Rhode Island Groundwater Protection Regulations as GAA, non-
attainment (i.e., groundwater which must be restored to drinking water
quality) with the exception of the landfill area which has been
classified as GB (Le., groundwater which has been degraded but will not
require cleanup). Since this groundwater classification system has not
yet been adopted, the federal groundwater classification system which
is baaed upon EPA's Groundwater Protection strategy will apply to the
site. Onder this classification system, groundwater within a two mile
radius of the site boundary, has been identified as Class II, Subclass
IIA. This classification indicates:that the groundwater within the two
mile radius of the site is being used 8a 8 current source of drinking
water.
During the FS assumptions were made regarding desiqn details of the
extraction system based on the information that was available at the
time. Many of these details, including the specific number of
extraction wells, depth, pumping rates, and locations, will only be
defined upon completion of a predesiqn pump test. To allow for a
comparison in the FS of the differences between treatment technologies,
the following assumptions for the extraction system were held constant
for each groundwater treatment alternative. All groundwater treatment
alternatives were based upon: 1) the placement of two extraction wells,
2) a maximum combined pumping rate of 40 gallons per minute (gpm), 3)
the extension of each well to approximately 200 feet below the ground
surface, and 4) the casing of each well over the upper 50 feet of bore
hole.
The pumping rate of 40 qpm was based upon a pulsed-pumping scenario.
In a pulsed-pumping scenario, a maximum flow rate of 40 qpm might be
seen for short durations. Therefore, this pumping rate was used to
provide a conservative estimate of what the maximum capital costs and
operation and maintenance (O&M) costs would be for each alternative.
Although a flow rate of 40 qpm was used for costing purposes, a lower
flow rate of 10 qpm vas used for calculating cleanup times. This lower
flow rate, which was based upon actual pumping yields from nearby wells
and an off-site pump test, was believed to be more representative of a
reasonable yield from the bedrock aquifer on a long term basis. As
described above the results of the predesiqn pump test will help
validate these assumptions.
A pretreatment step would probably be necessary to remove inorganic
compounds and solids in the extracted groundwater prior to treatment.
A pressure filtration unit is assumed for all groundwater extraction
and treatment alternatives and has been included. in the costing of each
alternative. This pretreatment unit would be primarily designed to
remove suspended metal ions, primarily iron and .anganese. Bench-scale
laboratory testing, as part of the predesign work, will determine if any
additional pretreatment is necessary. The bench-scale testing would
focus on the necessity of removing soluble metal ions in order to mee~
-------
discharge requirements.
Three methods of disposal for treated groundwater were discussed and
compared in the fS. Theae included: on-aite surface water discharge,
disposal via an on-site aewer hookup to an off-site publicly owned
treatment works (POTW), and on-a ita aubsurfac8 discharge.. The on-site
subsurface discharge was selected during the FS but EPA believes at this
time that the on-site surface water discharge may be the most
appropriate and feasible disposal alternative. The final decision on
what discharge alternative will be used for treated groundwater will be
made during design based upon the results of predesign activities which
will include pilot testing of the groundwater treatment technology.
Should the results of the pilot testing of the groundwater treatment
technology indicate that the effluent would not meet Rhode Island water
quality criteria then the additional costa of treating the water to meet
water quality criteria as well as the feasibility of the other two
discharge options would be considered.
GW-l
Air StriDDina
This alternative would treat the extracted groundwater using a system
consisting of air stripping, vapor phase granular activated carbon
(GAC), and liquid phase GAC polishing. Extracted groundwater is pumped
to the top of an air stripping tower filled with an inert packing
material while clean air is forced up through the tower. The packin~
material provides a large surface area over which groundwater and ai
can come in contact, and where contaminants can be transferred from the
groundwater to the air.
The air stripper to be designed for the Site would consist of
approximately 40 feet of packing material and is expected to achieve
about 99 percent removal for the VOCs found at the Site. Assuming this
removal rate, the remaining TCE concentration in the treated groundwater
would still exceed drinking water quality standards and therefore
require the use of a polishing step consisting of liquid phase GAC.
The air emissions would also be treated using a vapor phase GAC system
to meet state and federal air emission standards. Carbon residues
generated from the liquid polishing step and treatment of air emissions
would require off-site disposal and treatment. These residues will
contain elevated levels of TCE and therefore be subject to the
requirements of State and Pederal Hazardous Waste Regulations pertaining
to the generation, transportation, and disposal of hazardous wastes.
In addition, Rhode Island Pollutant Discharge Elimination System
(RIPDES) requirements, state pretreatment reqUirements, and Rhode Island
Underground Injection Control Regulations (UIC) would be important ARARs
for the three discharge options being considered for the disposal of
treated groundwater. Prior to full operation of the air stripper, pi lot
testing will be required to ensure that all air emissions and effluent
discharge limitations would be met.
Construction activities associated with the implementation of the a:,
-------
. .
stripping alternative are minimal and are similar for all groundwater
treatment alternatives. Activities include the drilling and
installation of extraction wells; plumbing and piping installation to
and from the air .stripper; grading and preparation of the staging area;
and utility bookup.
The time trame to achieve groundwater restoration is estimated to be 10
to 15 years based upon modeling. This time trame is the same for all
groundwater treatment alternatives and is primarily dependent upon the
subsurface conditions found in the bedrock aquifer. Quarterly
moni toring of the groundwater trom selected wells would also be
considered part of all qroundwater.treatment alternatives.
ESTIMATED IJ'ZKB FOB CONSTRUCTION:
ESTIMATED !'DIE FOR OPERATION: .
ESTIMATED CAPITAL COST:
ESTIMATED 0 ~ M (Cost/Year):
ESTmATED TOTAL ClOST (Pr..ent worth) :
GW-2
Granular Activated Carbon
2 Months
10 - 15 Years
$1,537,140
$ 139,525
$3,190,010 .
This alternative is identical to alternative GW-1 with the exception
that the method of treatment for the groundwater is solely a liquid
phase granular activated carbon (GAC) system. Based upon the
concentrations of VOCs detected in the groundwater two 20,000 pound
carbon units would be required to achieve the desired cleanup levels.
Carbon replacement for both units would be needed on a monthly basis
initially but carbon usage is expected to decrease with time.
The effectiveness of GAC for removing TCE and most VOCs is well proven.
A bench-scale treatability study was conducted using groundwater from
the Site to determine the applicability of this technology to site-
specific contaminants. The analytical results obtained from the
treatability saDple were not in 1ine with the results of the sampling
which occurred during the RI. Very high concentrations of the
contaminant vinyl chloride were detected by the company performing the
accelerated carbon test. EPA believes, based upon the fact that these
results differ significantly trom all of the qroundwater sampling
resul ts obtained during the RI, and the fact that the company performing
the treatability study bad concerns about their own analytical results,
that the treatability study results cannot be used without additional
confin.ation through sampling and analysis. Quarterly monitoring of the
groundwater from selected wells, which is. considered part of all
groundwater treatment alternatives, would help indicate any changes in
groundwater contaminant 8Akeup such as those which can produce vinyl
chloride. I
The significance of the presence ot vinyl chloride is that vinyl
chloride is very difficult to treat using carbon adsorption and there
is a possibility that cleanup levels could not be achieved using GAC.
Prior to full operation of the GAC system, pilot testing would be
-------
required to ensure that all cleanup levels and effluent discharge:
limitations would be met. .
'Construction activities associated with' the implementation of the GAC
alternative are minimal and are similar for all groundwater treatment
alternatives. Activities would include the drilling and installation
of extraction wells, plumbing and piping installation to and from the
GAC units, grading and preparation of the staging area, and utility
hookup.
The time frame to achieve groundwater restoration is estimated to be the
same for all groundwater treatment alternatives, approximately 10 to 15
y.ears. The uncertainty associated with this time frame is discussed in
the introduction to the groundwater extraction and treatment section
(Section VIII.B.l.) above.
There are no air emissions associated with ~is treatment alternative.
Therefore federal and state air pollution control requlations will not
be ARARs. Carbon residues generated from the groundwater treatment
would require off-site treatment and clisposal. These residues will
contain elevated levels of TCE, a RCRA hazardous waste. Therefore state
and federal hazardous waste requlations pertaining to the generation,
transportation, and disposal of the spent carbon, are ARARs. RIPDES,
POTW pretreatment requirements, and UIC requlatians are potential ARARs
for the three discharge alternatives being consiaered.
ESTIMATED TIME FOR CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED 0 , M (Cost/Year):
ESTIMATED TOTAL COST (Present worth):
2 Months
10 - 15 Years
$1,789,425
$ 114,225
$3,262,792
GW-4
Ultraviolet Liaht and Hvdroaen Peroxide
This alternative utilizes an innovative technology to destroy VOCs so
that the only residuals procluced are carbon dioxide, water, and very
small quantities of free chlorides which go on to form simple salts.
The technology uses ultraviolet (UV) light to react with hydrogen
peroxide to form hydroxyl radicals whiCh then react with and destroy
organic contaminants. .
The system, which vas sized for the 40 gpm qroundwater extraction rate,
consists of a self-enclosed treatment unit approximately two feet wide
by three feet long and five feet hiqh and also includes a 300 gallon
hydrogen peroxide storage tank. A bench-scale laboratory test was
completed using groundwater from the Site and it was found that TCE
levels could be destroyed down to a level below the drinking water
quality standard within an exposure time Df approximately three minutes.
Although vinyl chloride was not detected in the sample submitted for
the UV/hydrogen peroxide treatability test, this system has been sho.~
to be effective in destroying this compound.
-------
Prior to full operation of the tJV/hydrogen peroxide aystem, pilot
testing will be required to ensure that all cleanup levels and effluent
discharge limitations would be met. Quarterly monitoring of the
groundwater from .elected wells would also be considered part of this
alternative. .
construction activities associated with the implementation of the
UV/hydrogen peroxide alternative are minimal and are similar for all
groundwater treatment alternatives. Activities include the drilling
and installation of extraction wells, plumbing and piping installation
to and from the UV/hydrogen peroxide system, qrading and preparation of
the staging area, and utility bookup.
.'
The time fraDe to achieve qroundwater restoration ia .stimated to be the
same for all groundwater treatment alternatives, approximately 10 to 15
years. The uncertainty as.ociated with this time frame is discussed in
the introduction to the groundwater extraction and treatment section
(Section VIII.B.l.) above.
There are no air emissions or residues produced as a result of this
treatment alternative. Therefore the only major ARARs would be those
regarding RIPDES, POTW pretreatment requirements, and UIe regulations
for the discharge alternatives being considered.
ESTLKATED TIME FOR CONSTRUCTION:
ESTrMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED 0 , M (Cost/Year):
ESTIMATED TOTAL COST (Present worth):
GW-5
No-action
2 Months
10 - 15 Years
$ 705,890
$ 73,500
$1,889,760
This alternative is included in the FS, as required by CERCLA, to serve
as a basis for comparison with the other management of migration
alternatives being considered for the groundwater.
The no-action alternative for the on-site groundwater is also the no-
action alternative for the entire Site. Under this alternative, there
would not be any treatment of the contaminated groundwater. However,
in order to provide minimal protection of buman beal th and the
environment, the no-action option would include quarterly sampling of
selected existing monitoring wells to monitor the condition of the
groundwater contaminant plume. An estimated. 70 to 175 years would be
needed to achieve the cleanup levels for the groundwater if this
alternative were implemented along with one of the source control
alternatives which involves treatment of the TCE apill area soils, An
estimated 300 years would be needed to reach groundwater cleanup levels
if nothing were done to eliminate the apill 80i18 as a continuing
contaminant source. The no-action alternative does not help meet the
remediation levels for the groundwater and also does not return the
groundwater to its beneficial use in a reasonable time period as
-------
described in the NCP and further defined in EPA's Groundwater Protection
strategy.
ESTIMATED TIME FOR CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED 0 , M (Cost/Year):
ESTIMATED TOTAL COST (Present worth):
2.
OV.rall Sit.
o Months
70 - 175
$ 6,850
$ 46,200
$442,372
Years
OS-3
Buildina Demol i tion. Sealina Racewavs. Location and Excavation of Set)tic
Tank. and Sit.r- Gradinq
This al ternati ve would include the demolition of the on-site structures,
location of the septic tank, removal of its contents, and sealing and
filling of the two raceways. At the conclusion of these remedial
activities and in conjunction with the source control actions and other
management of migration action taking place, the entire five acre site
would be graded and covered with a vegetative 80il covering, and the
perimeter fencing would be enhanced.
The first activity which would have to take place under this alternative
would be the demolition and removal of the remaining structures. The
implementation of any of the overall Site alternatives cannot safel'
take place until this step is completed. The wood and metal materia~
encountered during demolition would be removed to an off-site disposal
area. Construction materials of an earthen nature (i. e. , bricks and
concrete) would be disposed of on-site while all other debris would be
disposed of off-site, in accordance with Rhode Island Solid Waste
Regulations. Material to be removed from the septic tank would be
tested prior to its disposal. Based on the state's hazardous waste
regulations, septage is a hazardous waste and must be disposed of in
accordance with the hazardous waste regulations. In the event that
testing indicates that the sludge from the aeptic tank is a hazardous
waste, the disposal would have to adhere to LDRs. The inlets and
outlets of both raceways would be sealed with a concrete barrier and
then suitable backfill material would be placed in sections of the
raceway that are not collapsed. Some of the raceway construction
activities will occur within the floodplain of the Branch River as well
as within an area defined as a wetlands by the State of Rhode Island.
Therefore federal and state regulations regarding floodplains and
wetlands will be important ARARs.
ESTIMATED TIME FOR CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED 0 , M (Cost/Year):
ESTI~~TED TOTAL COST (Present worth):
38
3 Months
3 Months
$715,825
$ 27,400
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05-4
Buildina Demolition. Sealina Racewavs. Location and Excavation of 5eotic
Tank. Excavation of PAH "Hot Soot". Site Gradina
This alternative is identical to OS-3 with the addition of the
excavation of contaminated raceway sediments and Whot spot" soils. It
is estimated that 22 cubic yards of sediment would be excavated from
both raceways prior to their being backfilled. The sediments would be
tested and if they did exhibit a hazardous characteristic as defined by
Rhode Island Hazardous Waste Regulations, they would be treated and
disposed of off-site. Sampling and analysis of the Whot spot" area
would be necessary to delineate th. extent of soil contamination that
would require excavation and treatJl(ent. The whot spot" as described in
section V.B.3., of this document, is a localized area of PAH
contamination. Al though elevated levels of PARs, as compared to
background levels were found in the Whot spot", these levels were not
found to pose a health risk to pUblic health and the environment.
For cost estimation purposes, the volume of contaminated soils in this
area was assumed to be 15 cubic yards. . The exact amount will not be
Jcnown until further sampling and analysis of the area is completed. The
ul timate disposal of "hot spot" soils would be dependent upon analytical
results, but would be in accordance with the appropriate State Solid
Waste Regulations or Hazardous Waste regulations.
ESTIMATED TIME FOR CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED 0 , M (Cost/Year):
ESTIMATED TOTAL COST (Present worth):
OS-5
No-action
4 Months
4 Months
$ 914,475
$ 31,400
$1,210,480
This alternative is included in the FS, as required by CERCLA, to serve
as a basis for comparison with the other management of migration
alternatives being considered for the overall Site.
The no-action alternative would implement institutional controls on
future land use to ensure that future development of the Site be limited
to prevent future health and environmental risks. In addition, the
fencing around the site would be improved to provide. a more effective
barrier preventing entry of third parties onto the site. This
alternative would not prevent the migration of contaminants from the
site through the raceways into the Branch River and therefore the
current risk to the public health and environment would continue.
ESTIMATED TIME FOR CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED 0 , M (cost/Year):
ESTIMATED TOTAL COST (Present worth):
39
2 Months
2 Months
$ 42,510
$ 8,000
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xx.
8UMKARY OP !'BE COKPARAT:IVB &DLYSIS OP &LHRNATIVES
Section l2l(b) (1) of CERCLA presents several factors that at a minimum EPA
is required to consider in its assessment of alternatives. Building upon
these specific statutory mandates, the National Contingency Plan articulates
nine evaluation criteria to be used in assessing the individual remedial
alternatives.
A detailed analysis was performed on the alternatives using the nine
evaluation criteria in order to select a site remedy. The following is a
summary of the comparison of each alternative's strength and weakness with
respect to the nine evaluation criteria. These criteria and their
definitions are as follows:
Thre.ho14 criteria
.
The two threshold criteria described below must be met in order for the
alternatives to be eligible for selection in accordance with the NCP.
1.
OVerall protection or human health an4 the environment
addresses whether or not a remedy provides adequate protection
and describes how risks posed through each pathway are
eliminated, reduced or controlled through treatment,
engineering controls, or institutional controls.
Compliance with applicable or relevant an4 appropriate
requirement. (ARARS) addresses whether or not a remedy wilJ
meet all of the ARARs of other Federal and state environmenta.
laws and/or provide grounds for invoking a waiver.
2.
PrimarY Balancina criteria
The following five criteria are utilized to compare and evaluate the
elements of one alternative to another that meet the threshold criteria.
3.
Long-term errectivene.. an4 permanence addresses the criteria
that are utilized to assess alternatives for the long-term
" effectiveness and permanence they afford, along with the
degree of certainty that they will prove successful.
4.
..duction of tozicitJI .o~ilitJI or volume through tr.atment
addresses the degree ~o which al~erna~ives employ recycling
or treatment that reduces toxicity, mobility, or volume,
including bow treatment is used to "address the principal
threats posed by the site.
Short-term errectivene.. addresses the period of time needed
to achieve protection and any adverse impacts on human health
and the environment that may be posed during the construction
and implementation period, until cleanup goals are achieved.
s.
6.
Implementability addresses the technical and administrative
-------
feasibility of a remedy, including the availability of
materials and .ervices needed to implement a particular
option.
coat includes estimated capital and Operation Maintenance
(O'M) costs, as well as present-worth costs.
7.
Modifvina criteria
The modifying criteria are used on the final evaluation of remedial
alternatives generally after EPA bas received public comment on the
RI/FS and Proposed Plan.
-
9.
state acceptance addresses the state's posi tion and key
concerns related to the preferred alternative and other
alternatives, and the state's comments on ARARs or the
proposed use of waivers.
C088Uni~ acceptance addresses the public's general response
to the alternatives described in the proposed Plan and RI/FS
report.
8.
A detailed narrative assessment of each alternative according to the
nine criteria can be found in Section 5 of the FS on pages 5-4 through
5-82.
Following the detailed analysis of each individual alternative, a
comparative analysis, focusing on the relative performance of each
alternative against the nine criteria, was conducted. This comparative
analysis can be found in Table 6-1 of the FS.
The section below presents the nine criteria and a brief narrative
. summary of the alternatives and their strengths and weaknesses according
to the detailed and comparative analyses.
A.
'1'CE Spill Area
1.
OVerall protection of Suman Sealth and the Environment
Alternatives TSA-l and TSA-3 use technologies that will be protective
of human health and the environment by treating the soil so that the
mobility, toxicity and volume of contaminants will be reduced.
Alternative TSA-1 uses excavation and incineration. TSA-3 uses in-situ
soil vacuum extraction. Alternative TSA-4 is. not protective because it
proposes no-action.
Both alternatives TSA-1 and TSA-3 use treatment technologies which are
effective in eliminating the principal threats found in the spill area,
i.e., TCE and its breakdown products. Alternative TSA-1 would achieve
the destruction of additional contaminants such as PAHs, which were
found in the spill area at lower concentrations. The concentrations of
PAHs found in the spill area were not found to present a risk to putlic
-------
health and the environment.
The time frame required to reach the soil remediation levels can be
estimated with greater certainty for alternative TSA-l than for
. alternative TSA-3. Excavation and incineration are two unit operations
for which accurate time estimates are available. This information can
be applied to the conditions at the Site to come up with an accurate
estimate of the time required to reach the remediation levels for spill
area soils. Alternative TSA-3, soil vacuum extraction, relies on the
physical properties of the 80il and the compounds being removed to
estimate the remediation time frame. Therefore, the estimated cleanup
time for TSA-3 is subject to greater uncertainty because the physical
properties of the soil at the Site'are non-homogeneous as a result of
previous construction activities at the Site. Xn addition, many of the
chemical properties important to vacuum extraction (i. e., Henry' s
constant) are either calculated or laboratory derived values and not
necessarily representative of site-specific values. Furthermore, it is
likely that not all areas of TCE spill soils would achieve cleanup
levels at the same time using vacuum extraction, thereby requiring an
extended and intermittent operation interspersed with a series of
confirmation sampling rounds. Despite these uncertainties associated
wi th TSA-3, the overall time frame for reaching remediation levels
throughout the spill area is roughly equivalent for both alternatives,
TSA-l and TSA-3, and would take approximately 1 to 2.5 years.
Of the two treatment alternatives, TSA-3 carries the lesser risk to
human health and the environment during construction and operation
Also, alternative TSA-3 would generate fewer waste streams and the on~
principal waste stream that it does generate, spent activated carbon,
can be regenerated off-site and then reused. The fact that the spent
carbon can be regenerated lessens the amount of hazardous waste
generated by alternative TSA-3 which requires disposal. The principal
waste stream produced by alternative TSA-l, bottom ash, may require
treatment consistent with LOR requirements and disposal in a RCRA
landfill.
2.
ComDlianC8 with ARARs
Each alternative was evaluated for compliance with ARARs, including
chemical-specific, action-specific, and location-specific ARARs. A
description of these ARARs is presented in Tables 9 through 11 in
Appendix B of this document. These tables list all potential ARARs
identified for the Site and give brief synopses of the ARARs and
explanations of the actions necessary to meet the ARARs. The tables
also indicate whether the ARARs are applicable or relevant and
appropriate to actions at the site. Alternatives TSA-l and TSA-3 meet
their respective ARARs. Alternative TSA-3 is expected to have less
impact on spill areas that are considered wetlands under the state
definition and the least potential for affecting the water quality of
the adjacent Branch River because of the limited excavation and
construction activities that would take place. Alternative TSA-4 does
not attain the following ARARs: Safe Drinking Water Act (SDWA) Maxi~u=
-------
contaminant Levels (HCLa) and Maximum contaminant Level Goals (HCLGs),
Rhode Island Regulations Pertaining to Public Drinking Water (R46-13-
DWS), Draft Groundwater Classification under the R. I. Groundwater
Protection Act (R.I.G.L. 46-13.1), Clean Water Act Ambient Water Quality
criteria (AWQCs), and R.I. Water Quality Regulations for Water Pollution
Control (~ GL 46-12).
3.
Lana-Term Bffectivene.. and Permanence
Alternatives TSA-1 and TSA-3 would be equally effective in treating and
removing the residual TCE and its breakdown products from spill area
soils. Incineration destroys the source of contamination. Soil vacuum
extraction withdraws the source of .~ontamination: the contaminants are
later destroyed when the spent carbon is regenerated or disposed of.
The levels of TCE and related VOCs left in spill area soils upon
completion of either alternative would .eet cleanup levels. Alternative
TSA-3 . wou.ld not produce a significaDt %emoval of other contaminant
types, such as PARs, altbonqh the levels at which the PARs were found
did not pose a significant risk to the public health and the
environment. Both alternatives would provide for permanent and
irreversible contaminant removal for the contaminants of concern, TCE
and related VOCs. Alternative TSA-4 would not provide any long term
protection of human health and the environment as the source of the
groundwater contamination would be left in place without any type of
treatment or containment. .
4. .
Reduction of Toxicitv. MObilitv. or Volume tbrouah Treatment
Alternatives TSA-l and TSA-3 would both achieve a reduction in the
toxicity, mobility, and volume of contaminants in the soils of the TCE
spill area. Both technologies use treatment as the means whereby
contaminants are siqnificantly and irreversibly reduced. The no-action
alternative, TSA-4, prcvides no reduction in toxicity, mobility, or
volume because no treatment is included.
5.
Sbort-Term Bffectivene.s
The no-action alternative, TSA-4 would take the shortest time to
complete, with an expected duration of 2 80nths. Alternative TSA-l
would take an estimated 1 to 2.5 years and alternative TSA-3 would take
an estimated 1 year to achieve cleanup levels. With respect to
protection of the community, the environment, and workers on-site,
alternative TSA-3 poses the least potential for adverse impacts of the
treatment options. The only potential impacts might result from the
generation of dust during the installation of extraction wells. Air
emissions from the vacuum extraction system would be treated through the
use of vapor .phase activated carbon. Although .lternative TSA-l also
includes air pollution equipment to control air emissions, there would
still be a large potential for air emissions during the excavation,
separation, and processing of soils prior to incineration. Even with
the use of strict engineering controls such as foaming agents to act as
dust suppressants, the potential risks to the community and workers d~e
-------
to air emissions would be siqnificant. In addition, the excavation of
soil from the TCE spill area as part of alternative TSA-l presents a
potential environmental risk to the adjacent Branch River if soil were
to be transported. to the river by wind erosion or surface water runoff.
Alternative TSA-4 would not present any potential risks to public health
and the environment because it would not entail any. remediation
activities.
I.
:rmol.mentability
Althouqh all of the alternatives can be implemented, some alternatives
are technically and administratively easier to implement than others,
based on their simpler d.siqn and iack of complexity.
Of the two treatment alternatives, TSA-3, in-situ soil vacuum
extraction, would be easier to implement. The installation of
extraction wells and operation of extraction equipment require fewer
enqineerinq controls than excavation and incineration. TSA-3 also
produces fewer waste streams. Therefore, fewer substantive requirements
would have to be met by TSA-3. Althouqh both technoloqies are
available, the equipment needed for the .installation and operation of
the vacuum extraction system is easily acquired from many different
sources and would require very little time to construct and have
operatinq. The installation of the mobile rotary kiln incinerator is
much more involved and there are a limited number of sources available
for this type of equipment. Incineration would also require a test bur1"
which miqht prevent the full-time operation of the equipment for.
period of up to one year after initiatinq the test burn. Alternative
TSA-4 would be easily implemented because the equipment for qrading soil
is readily available and this alternative would not have any
administrative requirements.
There is more certainty in the time frame required by alternative T5A-
1 to achieve the remediation levels than by TSA-3. Once the soil has
been incinerated, remediation levels will have been reached. Soil
vacuum extraction will require a series of confirmation soil samples
interspersed between operational periods to make the determination of
when remediation levels will have been reached. The sampling and
operation of the vacuum extraction system will have to continue until
remediation levels have been achieved throughout the spill area.
7.
~
The estimated capital, O&M, and present worth values of each alternative
are as follows:
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COST COKPAJU80H 01' 'tCI: 8PILL ADA ALHRDTIVBS
capital
co.t.
O'K co.t.
Il/vr)
pre.ent
Worth
TSA-1 Excavation and
Incineration $9,994,150 100,000 10,690,620
TSA-3 Soil Vacuum
Extraction $266,465 1,500 280,605
TSA-4 No-action $40,.140 1,500 54,280
8. state Acceatance
The Rhode Island Department of Environmental Management (RIDEM) concurs
with the selection of a soil vacuum extraction system as the source
control alternative for the TCE spill area.
9.
communitv Acceatance
The comments received d~ring the public comment period and the
discussions during the Proposed Plan and FS public meeting are
summarized in the a~~ached document entitled "The Responsiveness
summary" (Appendix C). Varied comments were received from residents
living near the Site and from officials representing the community and
state. The residents indicated that they preferred a treatment
alternative for the TCE spill area but did not declare a preference for
one over the other.
B.
Landfill &rea
1.
overall Pro~.ction of Human Health and the Environment
Alternatives LA-l and LA-3 use technologies that would be protective of
human health and the environment. Alternative LA-l uses excavation and
incineration. LA-3 uses consolidation, capping, and leachate
collection. Alternative LA-5 is not protective because it proposes no-
action to address the response objectives of this area.
Alternative LA-l provides the qreatest long-term effectiveness by
destroying the contaminants present in the landfill. However, short-
term risks posed by air emissions during the materials handling and
operational phases are judged to override the benefits of complete
destruction. Alternative LA-3 provides protection from direct contact
with contaminants, controls further downward and off-site migration of
contaminants in the groundwater caused by precipitation and 60il
leachate, and minimizes dust erosion and surface runoff. However I
capping does not reduce the toxicity of materials or provide the
certainty of protection that incineration does.
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2.
ComDliance with ARARs
. Each alternative was evaluated for compliance with ARARs, including
chemical-specific, action-specific, and location-specific ARARs. A
description of these ARARs are presented in Tables 9 through 11 in
Appendix B of this document. Alternatives LA-1 and LA-3 meet their
respective ARARs.
Alternative LA-3 is expected to have the least impact on areas that are
considered wetlands under the state definition and the least potential
for affecting the water quality of the adjacent Branch River because the
amount of excavation is limited to only those areas of the landfill in
the lOO-year floodplain. The volUme to be excavated during LA-3 is
roughly equivalent to five percent of the total landfill volume.
Alternative LA-l would require the excavation and processing of all of
the landfill wastes. Since both alternatives would require the
excavation of landfill wastes, both will require strict engineering
controls to minimize any potential air emissions. In addition, both
would require engineering controls to minimize potential releases of
contaminants into the Branch River which would violate floodplain and
wetlands ARARs. Alternative LA-S does not attain the following ARARs:
RCRA Landfill Closure Requirements (40 CFR 264, Subpart N), Rhode Island
Rules and Regulations for Solid Waste Management Facilities (R.I.G.L.
23-18.9,23-19,42-17.1), Clean Water Act Ambient Water Quality Criteria
(AWQCs), and R.I. Water Quality Regulations for Water Pollution Control
(RI GL 46-12).
"
3.
Lona-Term Effectivenes8 and Permanence
Alternative LA-1 is the treatment option considered for the landfill
area. Incineration destroys the source of contamination but also
produces a residual ash composed mainly of inorganic elements which
requires disposal. The residual ash may, upon testing, exhibit a
hazardous waste characteristic and therefore require treatment
consistent. with LDRs (e.g., solidification) and disposal in a RCRA
landfill. Alternative LA-l has a higher degree of certainty associated
wi th the permanence of the technology versus al ternati ve LA-3. Once the
wastes have been destroyed by incineration the remediation levels will
have been met.
Under the capping alternative, LA-3, the risk of direct contact and the
risk of release into the environment would be minimized for as long as
. the physical integrity of the cap were maintained. Capping would
provide for long-term effectiveness by meeting RCRA closure
requirements. However, the design life of a cap is subject to some
uncertainty. While proper installation and maintenance will extend the
cap's life significantly, cap replacement may be necessary at some time
in the future. A long term monitoring program, such as the one included
as part of LA-3, would provide sufficient warning ofa potential cap
failure. Alternative LA-S, the no-action alternative, provides very
little, if any, long-term effectiveness and permanence.
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4.
.edue~ioB of ~ozieitv. Mobilitv. or Volume ~hrouah Treatment
Al~ernatives LA-l is the only alternative that provides for the
reduction of toxicity, .obility, and volume of landfill wastes through
treatment. In addition, the incineration process provides for the
greatest reduction of toxicity, _obility, or volume of landfill wastes
of all the alternatives considered for the landfill. A potential
drawback for the incineration process is that it produces a residual
ash which may require further treatment to assure that the toxicity and
mobility of the ash are reduced to a level which are protective of human
health and the environment.
Alternative LA-3 would achieve ~a reduction in the mobility of
contaminants in the landfill but does not use treatment to achieve this
reduction. capping will limit the infiltration of precipitation and
control leaching of contaminants into the groundwater as well as the
surtace migration of contaainants into the Branch River. The no-action
alternative, LA-5, provides no reduction in toxicity, mobility, or
volume since no treatment or containment is included. '.
5.
8hor~-~erm BffeetiveBess
The no-action alternative, LA-S, would be completed in the shortest
time, with an expected duration of 2 months. Alternative LA-l would
take an estimated 2.5 to 3 years and alternative LA-3 would t~ke an
estimated 6 months to achieve cleanup levels. with respect to
protection of \:.he community, the environment, and workers on-site,
alternative LA-3 poses the least potential for adverse impacts. A
potential impact of this alternative may be air emissions and the
generation of dust during the excavation of landfill wastes located in
the lOO-year floodplain.
Although alternative LA-l includes air pollution equipment to control
air emissions, there would still be a potential for air emissions during
the excavation, separation, and processing of soils prior to
incineration. Even with the use of strict engineering controls the
potential risks to the community and workers due to air emissions would
be significant. Alternative LA-S would not present any potential risks
to public health and ~e environment because it would entail only
minimal risk of contaminated fugitive dust. being generated and carried
off-site during .ite grading activities.
,.
ImDlementabilitv
Although all of the alternatives can be implemented, some alternatives
are technically and administratively easier to implement than others,
based on their simpler design and lack of complexity.
Of all the three alternative., the no-action alternative, LA-5, would
be tha easiest to implement since there are only a limited number of
activities to be conducted. The equipment needed for grading soil as
described in the no-action alternative is readily available and this
-------
alternative would not have any administrative requirements. Of the two
alternatives which would achieve the response objectives for the
landfill area, LA-3 is simpler to implement. cappinq has been used on
other superfund sites and is not difficult to desiqn and construct.
cappinq would require the use of institutional controls to limit further
land use of the area. The cappinq alternative would also produce fewer
waste streams than incineration. Therefore, fewer substantive
requirements would have to be met. AI thouqh the expertise and equipment
for both cappinq and incineration is available, the number of sources
of available mobile rotary kiln vendors are more limited. In addition,
prior to full operation of the rotary kiln a test burn would be
necessary to assure the efficiency 9f the equipment in destroyinq site-
specific contaminants and determine optimum operatinq conditions. The
procedures and requirements necessary for a 8uccessful test burn could
postpone the full-time operation of the equipment at the site for up to
one year.
7.
~
The estimated capital, O&M, and present worth value of each alternative
are as follows:
COST COMPARISON OF LANDFILL AREA ALTBRNATIVES
Capital OlM Coata pre.ent
Costs fS/vr) Worth
LA-l Excavation and
Incineration $17,960,700 100,000 18,815,840
LA-3 Consolidation
and cappinq $587,750 62,000 1,172,000
LA-5 No-action $30,140 18,500 204,540
8. state Acc8Dtance
The Rhode Island Department of Environmental Manaqement (RIDEM) would
have preferred excavation and off-site disposal of the material found
in the landfill. However, the Department understands the uncertainty
as to whether any or all of that material is actually hazardous waste
and, if so, the correspondinq difficulty and expense in disposing of
those materials.
RIDEM concurs with the selection of a mUlti-layer cap and leachate
collection system, with institutional controls in place, as the source
control alternative for the landfill area. RIDEM cannot unilaterally
impose the institutional controls necessary to protect the integrity of
the landfill.
-------
t.
communitv Acceotance
The comments received during the public comment period and. the
discussions during the Propo.ed Plan and FS public .eeting are
summarized in the a~ched document entitled "The Responsiveness
summary" (Appendix C). Varied comment. were received from residents
living near the Site and 1rom officials representing the community and
state. The residents ~ndicated that they preferred a treatment
alternative for the Landfill area which permanently remediates the
material there and eliminates any future risks and expressed a
preference for the. excavation and removal of landfill wastes to an off-
site location.
..
.
c.
Groun4vater Bstractioa an4 ~ea~ent
1.
pverall Protection of Human Health and the Bnvironment
Alternatives GW-l, GW-2, and GW-4 use treatment technologies that will
be protective of human health and the environment by reducing the
concentration of TCE and other VOCs found in the groundwater to below
the drinking water standards. The technologies used for alternatives
GW-l and GW-2, air stripping and GAC, have a long proven history for
effectively treating TCE and other VOCs. Alternative GW-4 is considered
an innovative technology and has a more limited history of full-scale
applications. Alternative GW-5, the no-action alternative, is not
protective because it would not reduce the concentration of TCE and
other VOCs found in. the granndwater.
Alternative GW-4, utilizing the ultraviolet (UV) light and hydrogen
peroxide system, provides the qreatest long-term effectiveness by
destroying the contaminants present in the groundwater without producing
any residuals requiring treatment. Alternatives GW-l and GW-2 both
produce spent activated carbon which is a hazardous waste and requires
treatment prior to disposal.
The UV/hydrogen peroxide technology also has the ability to effectively
treat additional contaminants which may be found in the groundwater
including the breakdown products of TCE, .uch as vinyl chloride. The
importance of the potential pre.ence of vinyl chloride is that both
alternatives GW-l and GW-2 use activated carbon and activated carbon is
not effective for the treatment of vinyl chloride. During the RI, vinyl
chloride was detected in only a few groundwater .amples and at very low
concentrations. At this time it is not known whether the natural
transformation of TCE into vinyl chloride, wh~ch occurs in groundwater,
will cause vinyl chloride to become a contaminant of concern in the
groundwater at the Site. In the event that vinyl chloride is found in
the groundwater at higher concentrations in the future, alternative GW-
4, treatment by UV light and hydrogen peroxide, would provide the
greatest protection and effectiveness in treating vinyl chloride to
cleanup levels. Alternatives GW-2 and GW-4 have been shown to be
effective in treating dieldrin which was also found at-very low levels
in a limited number of groundwater monitoring wells at the Site. GW-l
-------
would not be effective in removing dieldrin from the groundwater.
2.
Com~lianc. with ARARs
Each alternative was evaluated for compliance with ARARs, including
chemical-specific, action-apecific, and location-specific ARARs. A
description of these ARARs are presented in Tables 9 through 11 in
Appendix B of this document. Alternatives GW-1, GW-2, and GW-4 all meet
their respective ARARs. Alternative GW-1 would have to meet the
greatest number of substantive requirements because of the air emissions
and the production of two waste atreams which would be considered
hazardous wastes. 'rhese two hazardous waste streams would consist of
spent activated carbon generated d~ring the treatment of air emissions
and polishing of the qroundwater prior to its discharge.
Based upon the information presented in the RI and FS, which includes
a laboratory-scale treatability study for alternative GW-4, all three
treatment alternatives are expected to achieve cleanup levels which
would meet drinking water standards as well as discharge limitations
for all of the disposal options being considered for the treated
groundwater. The disposal options being considered include discharge
to the Branch River, discharge to a sewer line on-site, and subsurface
. discharge to a leaching field. Pilot testing of the groundwater
treatment alternative selected will be necessary to assure that cleanup
level ARARs and groundwater disposal ARARs can be met. Alternative GW-
5, the no-action alternative, does not attain the following ARARs: SDWA
HCLs and HCLGs, Rhode Island Regulations Pertaining to Public Drinking
Water (R46-13-DWS), and the Draft Groundwater Classification under th~
R.I. Groundwater Protection Act (R.I.G.L. 46-13.1).
3.
Lona-Term Zffectiveness an4 Permanence
Alternative GW-l, GW-2, and GW-4 would all achieve the groundwater
response objectives and essentially the same level of cleanup. Air
stripping and GAC are proven technologies for the removal of VOCs such
as TCE. UV/hydrogen peroxide is an innovative technology which has only
in the last few years been used for this type of application. Full-
scale operating systems using the'UV/hydroqen peroxide technology have
been shown to be very effective in destroying VOCs such as those found
at the Site. In addition, a bench-scale laboratory study was completed
using qroundwater from the Site and this demonstrated that the
UVjhydroqen peroxide system could destroy site-specific contaminants to
below cleanup levels in approximately three minutes. Alternative GW-4
also has the flexibility for effectively treating'TCE breakdown products
such as vinyl chloride which may form over time in the qroundwater as
a result of natural biological proc..s... Alternatives GW-l and GW-2
would not be effective in removing vinyl chloride and might not be able
to achieve cleanup leval. for thia compound. Alternatives GW-2 and GW-
4 would be effective in removing and treating dieldrin, a pesticide
found at very low concentrations in a few monitoring wells at the Site.
Alternatives GW-l and GW-2 both produce spent carbon which ~s a
-------
hazardous waste and will require further treatment before disposal or
reuse. The only known byproducts of alternative GW-4 are carbon
dioxide, water and amall quantities of ftee chloride ions (which combine
wi th other mineral. in the vroundwat.er t.o form very amall quanti ties of
simple salt.s). Alt.ernat.ive GW-5, the no-action alt.ernat.ive, provides
very little, if any, long-t.erm effectiveness and permanence.
4.
.e4uctioD of ~ozicit.v. Mobilit.v. or Volume t.brouab ~reat.ment
Alt.ernatives GW-l, GW-2, and GW-4 would all achieve comparable
reductions in the toxicity, mobility, and volume of contaminants found
in the qroundwater. The one exception t.o this is that alt.ernatives GW-
1 and GW-2 are not effective in removinq vinyl chloride. The
concentratioJUI of vinyl chloride found in the qroundwater at the site,-
may increase with time as a result. of natural biological processes.
Therefore alt.ernat.ives GW-1 and GW-2 would not. effect.ively provide for
t.he reduction of t.oxicit.y, mobility, or volume of all known and
potential contaminants at the site. GW-4, however, can effectively
t.reat and reduce t.he t.oxicit.YI 8Obilit.y, and volume of vinyl chloride.
Alternatives GW-l and GW-2 both t.reat the groundwat.er by t.ransferring
the contaminants from t.he wat.er to activated carbon and, as a result,
both alternatives produce a waste residue of spent carbon. The spent
carbon would be transported off-site for treatment and disposal. During
t.reatment. the majority of spent carbon is regenerated for reuse. The
carbon that cannot be reused requires disposal. Al ternati ve GW-4 is the
only alt.ernative which directly dest.roys the cont.aminants and therefore
does not produce any waste residues requiring t.reatment. The no-action
alternative, GW-5, provides no reduction in t.oxicity, mobility, or
volume since no t.reatment. is included.
5.
Short.-Term Effect.ivene..
The estimated t.ime frames for cleaning up the qroundwater for
alternatives GW-l, GW-2, and GW-4 are all approximately 10 to 15 years.
The no-action alternat.ive, GW-5, would require an estimated 70 to 175
years to achieve cleanup, assuming removal of the source of
contamination (i.e., TCE contaminat.ed soil.), and.an estimated 300 years
if the source were not removed. .
EPA is aware that the subsurface conditions found at. the Site (e.g.,
fractured bedrock) present inherent difficulties that may affect
aChieving the cleanup of the 9%'oundwat.er in the time frame estimated for
all treatment. alternatives. In addition the presence of high
concentrat.ions of TCE which may be indicative of DNAPL, further
exacerbates the difficulty in predicting the cleanup t.ime frame.
Therefore, the cleanup t.ime frames propo.ed may be subject t.o revision
upon completing a thorough review of the performance of the treatment
system, five years after the atart up Of the aystem.
All t.hree treatment alt.ernative. would generat.e a small amount of dust
during the const.ruction phase and thereby present a minimal risk to the
-------
community and workers on-site. Alternative GW-l has the potential risk
of air emi.sions. Alternatives GW-l and GW-2 both generate spent carbon
which is a hazardous waste. Alternative GW-4 uses hydrogen peroxide as
one of its treatment components: this compound is a strong oxidizer.
Proper storage and handling of hydroqen peroxide will reduce the risk
to on-site workers. The risks to people off-site due to an on-site
release is expected to be minimal. Alternative GW-5 would not present
any potential risks to public health and the environment because it
would not entail any remediation activities (but as true of all the no-
action alternatives, it would also not eliminate any of the potential
risks that already exist).
,.
%mDl.m.D~abili~v
#
Although all of the alternatives can be implemented, 80me alternatives
are technically and administratively easier to implement than others,
based on their simpler design and lack of complexity.
The two major questions regarding implementability relate to the design
of the extraction system and unknowns associated with the effectiveness
of the extraction system in achieving the cleanup levels in the
estimated time frame. The predesign pump test will help provide the
details needed to effectively design the extraction system. The
implementability and effectiveness of the extraction system will only
be known once the system is operating and its progress can be monitored.
Of all the alternatives, the no-action alternative, GW-5, would be the
easiest to implement since the only activity to take place would be
quarterly sampling of selected existing monitoring wells. For the three
treatment alternatives, off-the-shelf equipment is readily available.
Unforseen technical problems associated with the use of alternatives GW-
1 and GW-2 are anticipated to be minimal since these technologies are
well proven. Alternative GW-4 is an innovative technology and does not
have a long operational history for this type of application.
Therefore, there may be a greater number of unforseen technical
problems. However, the UV/hydrogen peroxide technology has been used
in the last few years at sites with similar types of contaminants and
it has been shown to be very effective and reliable in destroying the
contaminants to cleanup levels this Record of Decision requires. To
insure the implementability of the alternative chosen, a pilot test
would be conducted in conjunction with the on-site pump test as part of
predesiqn activities.
GW-4 has the fewest administrative requirements to meet of the treatment
options because it does not produce any air emissions as GW-l does or
any hazardous wastes as both GW-l and GW-2 do.
7.
~
The estimated capital, O&M, and present worth value of each alternative
are as follows (the cost of extraction is the same for each alternative
and is also included in the total cost):
-------
COST CODARISOIl 01' GJtOUllDD'l'BR 1fUA'l'DN'l' aI.'lBRDTIVES
capi~al 0'. CO.~. pre.ent
Costs fS/vr) Worth
GW-1 Air stripping $1,537,140 139,525 3,190,010
GW-2 Granular Activated
carbon $1,789,425 114,225 3,262,792
GW-4 tTV/hydrogen :
Peroxide $705,890 73,500 1,889,760
GW-5 No-action $6,850 46,200 442,372
8. state AcceDtance
The Rhode Island Department of Environmental Management (RIDEM) concurs
with the selection of a tTV/hydrogen Peroxide treatment system as the
management of migration al ternati ve for the groundwater. It is
estimated that this alternative should achieve the cleanup levels after
ten to fifteen years of operation. 'rhe Department is concerned,
however, with the uncertainties associated with the technical
feasibility and associated costs of aChieving drinking water .tandards
ina bedrock aquifer at ~e Site. RIDEN has emphasized, as specified
in this Record of Decision, that periodic reviews be conducted to
evaluate the performance of the system and, the feasibility and cost
effectiveness of continued operation of the system in aChieving the
clean up levels. Revisions to the remedy should be made as necessary.
I.
communi tv AcceDtanc8
The comments received during the public comment period and the
discussions during the Proposed Plan and FS public meeting are
summarized in the attached document entitled ftThe Responsiveness
summary" (Appendix C). Varied comments were received from residents
living near the Site and from officials representing the community and
state. The residents indicated that they preferred a treatment
alternative for the groundwater but did not declare a preference for
one over the other.
D.
overall site
1.
overall ?rotectioD of Human .ealth an4 ~be Bnvironment
Alternatives 05-3 and 05-4 use technologies that will be protective of
human health and the environment. Alternative .OS-4 affords the most
effective long-term protection by addressing the Whot .potft and sediment
from the raceways. Alternative 05-4 also poses the greatest short-
term risks to human health and the environment because of the potential
for generating dust and air emissions during the excavation of these
-------
same materials.
Alternatives OS-3 and OS-4 would both significantly reduce the risks
posed to on-site workers by reducing the physical hazards at the Site.
OS-3 and OS-4 would eliminate a known migration pathway for contaminants
from the Site to ~e Branch River by sealing and filling the raceways.
They would both eliminate a potential source of. groundwater
contamination by removing the contents of the on-site septic tank and
treating and disposing of the contents off-site. The primary difference
between these two alternatives is that OS-4 includes the excavation of
"hot spot" soils and .ediment from the raceways. Although OS-4 includes
the removal ot "hot spot" soils, the concentrations of PARs detected
there were below levels which would pose a significant risk to public
health and the environment but were considered elevated as compared to
other background areas of the Site. Alternative 05-5 is not protective
since it would not prevent further migration of contaminants from the
Site into the Branch River via the raceways. It would also not remove
the physical hazards existing at the site. Until the physical hazards
existing at the Site were removed, workers could not safely perform
other activities of the remedy, which include addressing the landfill,
spill area, and groundwater.
2.
ComDliance with ARARs
Each alternative was evaluated for compliance with ARARs, including
chemical-specific, action-specific, and location-specific ARARs. A
description of these ARARs are presented in Tables 9 through 11 ir
Appendix B of this document.
Alternatives OS-3 and 05-4 include remedial activities in the lOO-year
floodplain of the Branch River and in an area desiqnated as a wetlands
by the RIDEM. Excavated "hot spot" soils and raceway sediments may be
a hazardous waste as defined by state and federal requlations.
originally it was proposed in the FS to combine the materials excavated
from the "hot spot" and raceways with landfill wastes since they both
exhibi t similar chemical characteristics. Because this would not comply
with Rhode Island Rules and Requlations for Hazardous Waste Generation,
Transportation, Storage, and Disposal, the excavated material will have
to be disposed of off-site in accordance with federal and state ARARs~
All debris which is disposed of on-site would be done so in accordance
with Rhode Island Solid Waste Regulations. Both 05-3 and 05-4 will meet
their respective ARARs.
Alternative 05-5, the no-action alternative, does not attain the Clean
Water Act Ambient Water Quality criteria (AWQCs), and R. I. Water Quality
Requlations for Water Pollution Control (RI GL 46-12). In addition, the
selection of the no-action alternative would hinder the implementation
of other source control and management of miqration alternatives because
of the dangers associated with the partially standing structures at the
Site. These structures, which includes the smokestack, could collapse
on workers implementing remediation activities in the spill area and
landfill area. Therefore, workers could not safely work in these areas
-------
. .
until the physical hazards associated with the on-site structures were
eliminated.
3.
Lona-Tera .ffec~ivene.. and .eraanence
Al~.rnative 05-4 would provide ~e greate.t long-term effectiveness by
removing and treating the contaminated materials from the "hot spot"
and raceways, removing the physical site risks, and sealing of the
raceways. AS a result of the excavation of materials taking place under
this alternative, hazardous materials will be generated and will require
treatment and disposal. Depending on the treatment technology used for
the excavated -.aterial., a vaste .reaidue may })e froduced requiring
further treatment prior to disposa}.
Alternative 05-3 would achieve the .... degree of long-term
effectiveness as 05-4 1n protecting public bealth and the environment
even though 05-3 does not remove -bot spot- .011s and8ediment from the
raceways. The levels at which PASs were fOW1d in "hot spot" soils did
not pose a risk to public bealtb and the environment. The risk posed
by . sediments entering 'the Branch River would be eliminated in OS-3 by
the sealing and filling of the raceways and therefore the removal of the
sediments in 05-4 would not provide a greater degree of protection. As
one of the remedial activities proposed for both 05-3 and OS-4, the
location of the septic tank will be pinpointed and its contents removed,
tested, treated, and disposed of. The exact location of the septic tank
is unknown although it is believed to be under one of the existing
debris piles. Therefore, the chemical nature and quantity of its
contents still needs to be determined. Alternative 05-5 would not be
effective in removing the known risks posed by contaminants migrating
into the Branch River through the raceways and the potential risks due
to the contents of the septic tank impacting the groundwater. In
addition the no-action alternative does not eliminate the physical
hazards presented by the partially standing buildings, deteriorating
smokestack and numerous holes scattered throughout the 5ite. These
physical hazards would increase with time as the standing structures
continue to deteriorate and would prevent the implementation of
construction activities for other aspects of the 5ite remedy.
4.
.eduction of '1'ozWtv. lIobilitv. or Volume throuah '1're.tment
Alternative 05-4 would reduce the toxicity, mobility, and volume of
contaminants from the "hot spot" and raceways. The extent of reduction
would be dependent on the treatment method used for the excavated
materials. Alternative 05-3 would achieve a- reduction of mobility of
contaminants through the raceways but this would be through containment
rather than treatment. Both alternative. would reduce the toxicity,
mobility, and volume of potential contaminants in the septic tank
through treatment. Alternative 05-5 provides no reduction in toxicity,
mObility, and volume since no treatment is included. .
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5.
Short-T8rm Bff8ctiv8n...
The no-action alternative, 05-5, would be completed in the shortest time
(2 months). Alternative 05-3 would take an estimated 3 months and
alternative 05-4 would take an estimated 4 months to achieve remediation
objectives. With respect to protection of the community, the
environment, and workers on-site, alternative 05-5 poses the least
potential for adverse impacts since no remedial activities would take
place. Of the two treatment alternatives, 05-3 would have less impact
during construction and implementation because of the limited excavation
activities. 05-3 would not excavate the "hot spot" soils or raceway
sediments and therefore would not ~ave the same potential as 05-4 to
generate dust and air emis.ions during these activities. There would
be potential air emissions associated with .aterials removed from the
septic tank under alternatives 05-3 and 05-4.
Both alternatives 05-3 and 05-4 would generate noise, heavy equipment
traffic, and particulate emissions during the demolition and removal of
structures and the filling of the raceways. The investigations to date
have not included explorations into or beneath existing structures
because of health and safety concerns. Therefore, there remains a lack
of certainty of what may be encountered during the demolition of the
structures and what potential releases, if any, may occur and effect the
community, workers on-site, and the environment.
I.
%mclem8ntabilitv
While all of the alternatives can be implemented, some alternatives are
technically and administratively easier to implement than others, based
on their simpler design and lack of complexity.
Of all the alternatives, the no-action alternative, 05-5, would be the
easiest to implement since there are no remedial activities to be
conducted other than improvements to the fencing. Alternatives 05-3
and 05-4 are both technically implementable but 05-4 would be the more
complicated of the two with the additional excavation activities
required for the "hot spot" and raceway sediments. The demolition of
the partially standing building and smokestack will require the services
of experts to minimize any potential impacts to nearby residents. Based
on administrative implementability, the most siqnificant difference
between the treatment alternatives is the additional substantive
requirements that will be necessary for the disposal of excavated
materials under 05-4. Both alternatives will have activities occurring
in desiqnated state wetlands of the Branch River and 'will have to meet
the substantive requirements of the Rhode Island Wetlands Protection
Act. In addition, both alternatives 05-3 and 05-4 would require the
implementation of institutional controls to control future land use over
the raceways, and buildings.
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7.
~
The estimated capital, O&M, and present worth value of each alternative
are as follows: .
COST COXPARISO. O:r OVBULI. 8IR aLTBRDTIVES
capital
Costs
O&H Co.t. ~r8s8nt
fS/vr) worth
05-3 Demolition, Sealing
Raceways, Septic Tank,
and Site Grading
05-4 Demolition, Sealing
Raceways, Septic Tank,
"Hot spot" Excavation,
and Site Grading
$715,825
27,400
974,120
05-5 No-action
$910\,475
$42,510
31,400
1,210,480
8,000
116,930
8.
stat. acc8t»tanc.
The Rhode Islana Department of Environmental Management (RIDEM) concurs
with the selection of the combination of demolition of the remaining
structures on the site, sealing of the remaining raceways, location and
removal of the septic tank, and final site grading as the management of
migration alternative for the overall Site. The department has raised
concerns about the potential routes of migration through the sewer line
trench and through potentially uncollapsed sections of the raceway
underneath tne landfill. This issue will be further evaluated during
the predesign, design, and operation of the remedy.
,.
Community aCC8t»tanc8
The comments received during the public comment period and the
discussions during the Proposed plan and FS public meeting are
summarized in the attached document entitled WThe Responsiveness
summary" (Appendix C). Varied comments were received from residents
. living near the site and from officials representing the community and
state. The residents voiced very strong concerns over the present
physical conditions of the site and indicated that they wanted the
physical hazards which have existed there for years addressed as quickly
as possible. However, they did not indicate a preference for which
alternative they thought should be used to accomplish the overall site
cleanup.
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z.
THE SELECTED REMEDY
EPA has selected a comprehensive remedy consisting of the following
al ternatives to address the different remedial areas identified at the
Stamina Mills Site:
TCE S1:>1ll Area
TSA-3:
Soil Vacuum Extraction;
Landfill Area
IA-3:
Capping Including C~nsolidation;
Groundwater Treatment
GW-4:
Ultraviolet Light and Hydrogen Peroxide; and
OVerall Site
Building Demolition, Sealing and Filling of Raceways,
Location of Septic Tank and Removal of Contents, and Site
Grading.
EPA believes this remedy is comprehensive as it contains both source control
and management of migration components which use treatment to address the
principal threats and engineering controls to address relatively low long~
term threats identified at the Site. A detailed description of the cleanu~
levels and the selected remedy is presented below.
05-3:
A.
Cleanup Levels
Cleanup levels have been established for contaminants of concern
identified in the baseline risk assessment. found to pose an unacceptable
risk to either public health or the environment. Cleanup levels have
been set based on the appropriate ARARs (e.g., Drinking Water MCLGs and
MCLs) if available. In the absence of a chemical-specific ARAR, or
other suitable criteria to be considered, a 10.6 excess cancer risk level
for carcinogenic effects or a concentration corresponding to a hazard
index of one for compounds with non-carcinogenic affects was used to set
cleanup levels. In instances in which the values described above were
not feasible to quantify, the limit that could be reliably measured by
analytical methods was used as the cleanup level. periodic assessments
of the protection afforded by remedial actions will be made as the
remedy is being implemented and at the completion of the remedial
action. If the remedial action is not found to be protective, further
action shall be required.
1.
Groundwater
Because the aquifer at and beyond the compliance boundary of the Site
is a current source of drinking water (i.e., it is classified as Class
-------
II, Subclass IIA} MCLs and non-zero MCLGs established under the Safe
Drinking Water Act are ARARs. The compliance boundary established for
groundwater cleanup levels is throughout the contaminated groundwater
plume from the boundary of the waste management area on-site to the edge
of the plume off-site. Cleanup levels will be achieved in each
compliance monitoring well located at or beyond the compliance boundary.
The waste management area for the site is defined as those areas of the
site where wastes will be contained in place and includes the area
delineated by the landfill, raceways, and building structures to be
demolished.
Cleanup levels for known and probable carcinogenic compounds (Class A
, B) have been set at the appropriate MCL because the MCLG for these
compounds iJJ CJ8D8rally set at zero. Cleanup levels for the Class C
compounds (possible carcinogens), Class D (not classified) and Class E
(no evidence of carcinogenicity) have been set at th~ MCLs. When
appropriate (e.g., ~e cuau)a'tive risk i. greater than 10. or the hazard
index is greater than 1), the cleanup levels have been set up at non-
zero MCLGS if MCWs are more stringent than MCLs. In the absence of a
MCLG, a MCL, a proposed drinking water standard or other suitable
criteria to be considered (i.e. health advisory, state standard), a
cleanup level was derived for carcinogenic effects based on a 10.6 excess
cancer risk level considering the ingestion of groundwater.
Cleanup levels for compounds in groundwater exhibiting non-carcinogenic
effects have been set at the MCLG. In the absence of a MCLG, a MCL, a
proposed drinking water standard or other suitable criteria to be
considered (i.e. health advisory, state standard), cleanup levels for
non-carcinogenic effects have been set at a level thought to be without
appreciable risk of an adverse effect when exposure occurs over a
lifetime (hazard index - 1). The hazard index is calculated by dividing
the exposure level by the reference 408e (RfD) or other suitable
benchmark for non-carcinogenic health effects. Reference doses have
been developed by EPA to protect sensitive individuals over the course
of a lifetime. They reflect a daily exposure level that is likely to
be without an appreciable risk of an adverse health effect.
Table I below summarizes the cleanup levels for carcinogenic and non-
carcinogenic contaminants of concern identified in groundwater.
~ULZ 11 GRommnnR CLZunJ1t LBV1!:LS
Carcinogenic
contaminant. of
Concern
Trichloroethylene
Tetracbloroetbylan.
1,1-DicbloroethyleDe
Vin)'l Cblorid.
Cl.uup
Level IDDb)
5
5
,
2
...i.
IICL
DCL (1)
XCL
XCL
LeY.l of
.~
,alO.'
1Zl0-4
1Zl0-4
-------
lton-CarciDoq.nio
Con1:amiD&D1:s of
Concern
1,2-Dichloro.1:hyl.D.
~.1:rachloro.1:hyl.n.
Di.ldrin
Chromium
Cl.anup
Lev.l
Il:»l:»b)
70
5
2
50
Basis
PKCL
DCL
JIA (2)
IlIPDn(S)
lfarq.1:
Bndpoin1:
of Toxici1:v
Liv.r
Liver
Liver
Liv.r
Hazard
Index
0.2
0.01
1.0
0.2
(1)
(2)
(3)
Proposed Maximum Contaminant Level
Health Advisory
National Int~rim Primary Drinking Water Requlation
These cleanup levels must be .et :at the completion of the remedial
action at the compliance boundary, which as described earlier, is
throughout the contaminated groundwater plume, from the boundary of the
waste management area on-site to the edge of the plume off-site.
Cleanup levels will be achieved in each compliance monitoring well
located at or beyond the compliance boundary. The waste management area
for the site is defined as those areas of the site where wastes will be
contained in place and includes the area delineated by the landfill,
raceways, debris piles, and building structures to be demolished.
The location and number of compliance monitoring wells will be finalized
during design; however, at a minimum, a subset of existing on-site and
off-site wells will be selected and may include the installation of
additional monitoring wells. The type and frequency of monitoring will
also be finalized during design. Sampling parameters will include the
following: the target compound list (TCL) volatile organic compoundr
the target analyte list for metals, dieldrin, pH, temperature, specii
conductance, and chloride. Specific parameters may be added or deleted
depending on sampling results and observed trends. EPA has estimated
that these levels will be obtained within 10 to 15 years. Once the
cleanup levels have been obtained, the extraction wells will be shut
down and a monitoring program will be implemented to confirm the
results. This program will, at a minimum, consist of three years of
quarterly monitoring of groundwater quality.
These cleanup levels are consistent with ARARs for groundwater and will
attain EPA'. risk management goal for rem.dial actions. The cleanup
levels for vinyl chloride and 1,1-dichloroethylen. have been .et at the
MCL and MCLG respectively, which is the lowest levels that can be
analytically quantified and therefore the lowest levels that can be
practically set. Given the effectiveness of the groundwater treatment
process for destroying chlorinated solvents and the relatively low
concentrations of hoth vinyl chloride and "1, 1-dichloroethylene as
compared to TCE, the primary contaminant of concern, "EPA believes that
the levels of both of the.. compounds in treated groundwater will be
below cleanup levels. "
It should be noted that the levels of chromium detected in the
groundwater at the site did not exceed the target cleanup level shown
in Table I with the exception of one well in the landfill. As described
-------
in Section V.C., of this Record of Decision, chromium levels which did
exceed the cleanup level were obtained from what is believed to be
landfill leachate. Since the remedy for the Site includes a leachate
collection .ystem, EPA believes that target cleanup levels for chromium
will be met without the need for additional groundwater treatment.
Levels of chromium and other trace metals found in the groundwater will
be monitored during the predesign activities, which includes a pump test
and pilot testing of the groundwater treatment system, to determine if
any additional treatment of metals will be necessary to meet cleanup
levels and groundwater disposal requirements. In addition, an
environmental monitoring program, which will involve the sampling of
sediment and surface water from the Branch River, will be developed
during the remedial design phase t~.assure that the response objectives
of the landfill area will be met..
2.
soil CleaaUD Levels
Cleanup levels in &01ls were established in order to protect human
health, the environment, and the aquifer below the stamina Mills site
from contamination. The Summers Model was used to estimate residual
soil levels that are not expected to impair tU'ture groundwater quality.
ARARs for the groundwater (MCLGs and MCLs) were used as inputs into the
leaching model. In the absence of an ARAR, the level corresponding to
a 10.6 risk level (for carcinogens) or a hazard index of one (non-
carcinogenic effects) was utilized. If the cleanup values described
above were not capable of being detected or were below regional
backqround values, then either the CRQL or a. backqround value .was
substituted. Partitioninq coefficients, and additional inputs to the
leaching model, were either laboratory derived (as in the case of TCE)
or obtained from EPA quidance documents. Table 2 summarizes the soil
cleanup values for the contaminants of concern developed to protect
public health, the environment, and the aquifer.
~LE 2: SOIL CLEANUP LEVELS
1,2-Dichloroethylene
Soil cleanup levels were not established for dieldrin and chromium
soil .a.i. for .e.i4ual
Cleanup K04el Groundwater
Level (ua/Jta) InDut B1U
1'5 KCL 2zl0"
" DCL 1zl 0 ~
11 XCL 1Zl0
.a.i.
soil for !'arqet .e.i4ual
Cleanup K04el 8n4point Groundwater
Level fua/ka) InDut !'osicitv .a.ard Index
151 DCL Liver 0.2
carcinogenic
contaminant. of
Concern
~richloroethylene .
~etrachloroethyl.De
1,1-Dichloroethylene
Hon-carcinoqenic
contaminant. of
Coftcern
-------
because theses compounds were only detected at elevated levels in t~~
landfill wastes which are to be consolidated and capped in place as p
of the remedy selected for this Site. Soil cleanup levels were also r.......;
established for vinyl chloride because this compound was not detected
in any soil samples obtained at the site during the~. Monitoring of
the cleanup levels in the TCE spill area soils will include the analysis
. for vinyl chloride. In the event that vinyl chloride is detected during
the monitoring, a 80il cleanup level will be established using the
Sommers Model and the 8ame procedures used for calculating the soil..
cleanup levels 8hown above.
These cleanup levels in soils are consistent with ARARs for groundwater
and attain EPAls risk management qbal for remedial actions of 10." to "
10.' and a hazard index of 1e.. than one. Furthermore, these soil levels
should be prot:ective of any potential health risks posed by direct
contact or incidental ingestion of the soils.
These cleanup levels .ust be met at the c01Ipletion of the remedial
action throughout the contaminated soils in the TCE spill area and which
are located above the bedrock aquifer. The location and number of
compliance monitoring points and the sampling procedures by which
cleanup levels are to be demonstrated will be developed during the
design. EPA has estimated that cleanup levels will be achieved within
one year.
B.
The following is a list of the major components of the remedy:
De.crl~~ioD of .eme4ial Com~oDeDt.
1.
2.
In-situ vacuum extraction of TCE spill area soils;
Excavation of landfill wastes from 100-year floodplain and
consolidation with landfill wastes above floodplain:
Installation of leachate collection system in landfill:
Capping of the landfill; .
Groundwater extraction and treatment using UV/hydrogen
peroxide system;
" Demolition of on-site structures;
Sealing and backfilling of raceways;
Location of .eptic tank, testing and removal of contents, and
off-site treatment and/or disposal;
Grading of Site,
Long-term environmental monitoring: and
Institutional controls.
3.
4.
5.
6.
7.
8.
9.
10.
11.
The in-situ soil vacuum extraction system will consist of a number of
shallow wells installed to a depth of approximately 10 feet, or far
enough above the water table to avoid the extraction of excess moisture.
These wells are connected to a vacuum pump which pulls air and VOCs with
it through and from the 80il. The air containing VOC8 i8 then treated
with activated carbon filters betore it is discharged to the atmosphere.
Water vapor is sometimes withdrawn trom the soil along with VOCs and if
a collectable quantity is formed it will be combined with extracted
-------
qroundwater and treated accordinqly. During the desiqn phase, the
number, depths, and locations of extraction wells will be finalized.
It is expected that these desiqn details as well as the optimum
operating conditions can be provided through the initial pilot-testing
of a full-scale unit. periodic review and modification of the design,
construction, maintenance, and operation of the .oil vacuum extraction
'system may be necessary over time. A frequency for reviewing the
progress of the system for meeting the goals and desiqn criteria will
be established during the desiqn phase.
Approximately 550 cubic yards of a mixture of landfill wastes and
sediments will be excavated from the lOO-year floodplain of the Branch
River. Tbis material will be redepbsited above the floodplain onto the
existing landfill area before the new cap is installed. As described
in Section XI.B.3., of this Record of Decision, EPA does not believe
these activities constitute placement because of the contiguous nature
ot the materials bein9 excavated. They therefore are not subject to
LDRs. During the excavation of the wastes in the floodplain as well as
the grading and stabilization of landfill slopes adjacent to the Branch
River, appropriate engineering controls will be used to minimize the
migration of landfill wastes into the river as well as to control odors
and air emissions. Upon completion of excavation, a leachate collection
system will be installed along the toe' of the landfill on its southern
side.
EPA believes that the installation of a leachate collection system and
capping of the landfill will address the release of trace metals into
the Branch River and the groundwater. During the RI low levels of trace
metals were detected in monitoring wells near the landfill area and one
compound, chromium, exceeded drinking water standards. The two wells
in which chromium levels exceeded drinking water standards are screened
over intervals which are above the bedrock aquifer but are in direct
contact with landfill wastes. Therefore, the water being sampled in
these shallow wells in the vicinity of the landfill is believed to be
representative of landfill leachate rather than groundwater beneath the
'site. Monitoring wells positioned adjacent to the shallow wells, that
were screened over deeper intervals below landfill wastes but within the
bedrock aquifer, showed much lower concentrations of chromium. The
concentrations of chromium detected in these deeper wells were below
levels which posed a siqnificant public bealthrisk. The results from
the .ampling of these deeper wells, as well a. from other wells
throughout the Site, shows that trace metal. are not impacting the
groundwater beneath the Site and therefore the need for a groundwater
treatment system to address soluble metal ions is not indicated at this
time. An environmental monitoring program con.isting of .urface water
and sediment sampling in the Branch River will be implemented to assure
that the leachate collection system is meeting the response objectives
of this Record of Decision. The details regarding the environmental
monitoring program, including the frequency of sampling, sampling
locations, and parameters to be sampled will be decided during the
design phase.
-------
The leachate collection system will discharge into the on-si te se~r
, system subject to the approval of the Woonsocket Wastewater Treatml
Plant, the Town of North Smithfield, and upon meeting all pretreatment
and monitoring requirements. Based on the chemical characteristics of
the leachate currently being generated in the landfill it appears that
the leachate will meet pretreatment .tandards wi thout requiring any
. additional treatment. In the event that the physical characteristics
of the leachate change as a result of capping or the POTW refuses to
accept the leachate, a laboratory-scale treatability study will be
performed to determine the cost effectiveness of pretreatment of the
leachate and the feasibility of on-site versus off-site disposal.
The landfill cap design will be consistent with the State and Federal
closure requirements for a RCRA facility. At a minimum, the cap will
consist of a mUlti-layer system composed of a vegetative topsoil layer
and a subsurface drainage layer overlying a low-permeability barrier of
clay and synthetic liner material. The details of the materials of
construction, the thickness of the layers, and the groundwater
monitoring system will be established during the remedial design phase.
Capping of the landfill will also require the protection of landfill
side slopes still within the floodplain of the Branch River; the
extension of existing manholes up to the new surface of the cap; and may
require the installation of a passive gas collection system. The gas
collection system, if determined to be necessary during design, will
consist of small-diameter PVC pipe placed in a network of shallow
trenches backfilled with crushed stone. The trenches will be located
within the intermediate cover layer below the final cover. Because ~
the small size of the landfill, the quantity of gases expected to
generated will be minimal. The potential for emissions and necessary
treatment, if any, for any gases collected will be evaluated during the
design phase. Sections of the southern side slope of the landfill which
would still be subject to the effects of Branch River flooding would be
further protected by covering with stone (i.e., rip-rap) once the cap
is in place. The existing manholes which provide access to the sewer
line travelling roughly diagonally across the landfill would be raised
and incorporated into the final design of the cap.
The groundwater extraction 8ystem will consist of a number of wells
installed on-site into the bedrock. Many of the design details of the
extraction .ystem and its associated groundwater monitoring system,
including the .pecific number of well., depth, pumping rates, and
locations, will be defined upon completion of a predesign pump test.
Extracted qroundwater will be treated on-site using the innovative
ultraviolet light and hydroqen peroxide" (UV/hydrogen peroxide)
technology.
Prior to treatment, the extracted groundwater will undergo pretreatment
to remove suspended solids and 80me inorganic metals. Based on the
results of an initial laboratory treatability study conducted with
groundwater from the Site, pretreatment will consist of a pressure
filtration system. Further laboratory bench-scale or pilot-scale
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testing will be conducted during predesign to determine the
effectiveness of pressure filtration for removing suspended solids. In
the event that testing indicates the need for further pretreatment,
either to meet groundwater cleanup ARARS or disposal ARARs for treated
groundwater, additional laboratory bench-scale or pilot testing will be
completed. It is not anticipated that the need for additional
pretreatment will change the selected remedy since this additional
pretreatment would be necessary for all of the groundwater treatment
alternatives that were considered.
The UV/hydrogen peroxide system consists of a self-enclosed unit having
the dimensions of 2x3xS feet and a 300 gallon high density polyethylene
(HDPE) storage tank for bydrogen peroxide. The treatment unit including
the storage bDk will be constructed within a bermed area. This
innovative tec:!tmoloqy uses ultraviolet light to react with hydrogen
peroxide and form hydroxyl radicals which react with and destroy organic
contaminants. The technology bas been proven to be very effective in
destroying chlorinated solvents in a ~i.mited J111mber of full-scale
operations. A bench-soale laboratory test vas performed as well during
the FS using groundwater from the site and it was determined that TCE
levels were reduced to below cleanup levels in approximately three
. minutes. The only residuals produced are carbon dioxide, water, and
small amounts of free chlorides which react with minerals in the water
to form simple salts.
In order to further test the effectiveness of this innovative
technology, a pilot test will be conducted at the Site during predesign
activities. Groundwater extracted durinq the predesiqn pump test will
be treated on-site using full-scale equipment and the results will be
used to make a final determination on the effectiveness of this
technology to achieve cleanup levels. In the event that this innovative
technology is not found to be effective in achieving the groundwater
cleanup levels, EPA will select air-stripping with GAC and vapor phase
carbon as the treatment technology for removal of TCE and other VOCs
from the groundwater.
The results of the predesiqn groundwater treatment pilot test will also
be used to Bake a tinal determination on how treated groundwater will
be disposed of. currently the options being considered are on-site
surface water discharge, disposal via on-site sewer hookup to an off-
site POTW, and on-site subsurface discharge. . EPA prefers the first
option, on-site surface water discharge, but will review the results of
the pilot test and determine if all state discharge requirements which
have been identified as ARARs will be met before making a final
determination.
Although attaining drinking water quality standards within a reasonable
time frame is the desired cleanup goal, groundwater contamination may
be especially persistent in the bedrock aquifer beneath the 5 i te.
Therefore, periodic review and modification of the design, construction,
maintenance, and operation of the groundwater eXtraction and treatment
system as well as the monitoring system may be necessary. A complete
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evaluation of the performance of the system will be made within fi
years of the start up of the groundwater treatment system to determi.
if the goal. and standards of the desiqn criteria are being met. If
the evaluation reveals that the remedy cannot achieve the stated cleanup
levels, or that the cleanup levels cannot be achieved wi thin a
reasonable time rraae, consideration will be given to making changes in
the remedy.
After the cleanup levels have been met and the remedy is determined to
be protective, the groundwater extraction and treatment system will be
shut down. '!'he groundwater monitoring system will continue to be
utilized to collect information qua~erly ror three years after the shut
down date to ensure that the cleanup levels have been met and the remedy
is protective. Once 1:I1ese levels are maintained and the remedy is
protective ror three years after 1:I1e shut down date, an additional
monitoring program for the site in accordance with Rhode Island
Hazardous and Solid Waste rules will be implemented.
The Site, which has remained vacant since a fire destroyed the mill
building in 1977, is covered with rubble, piles of debris, and
foundation remains, including a deteriorating smoke stack. These
structures will be demolished and removed prior to the implementation
of other remedial activities to insure the health and safety of workers
on-site. The wood and metal materials found in the demolition debris
as well as in the existing debris piles will be removed and disposed of
off-site in accordance with Rhode Island Solid Waste Rules.
Construction materials of an earthen nature will be disposed of on-site.
Engineering controls will be used to limit the generation of dust durj
demolition.
The inlets and outlets of both raceways will be sealed with concrete
barrier walls to stop the flow of water across the Site and into the
Branch River. The inlet barriers will be constructed prior to the
backfilling of the raceways to reduce the need for dewatering.
Temporary coffer dams may be installed to allow for the construction of
cast in place concrete walls at the inlets and outlets. The details of
the construction of the barrier walls will be established during the
remedial design phase. The construction of an additional concrete
barriers in the raceway. directly upqradient of the landfill will also
be considered as a means of reducing the flow of water through the
landfill in the event that 1:I1ere i. evieSence ofa continueeS flow through
the old raceway after the raceway entrance has been sealed.
Sections of both raceways will be backfilled using suitable clean fill
material. The roof of the raceways will be collapsed or demolished
using heavy equipment and this material will be deposited in the open
raceway. The material placed in the raceways will be compacted and
brought to the original grade. The old raceway will be backfilled from
the inlet to a point ju.t before it 90es through the landfill.
Information derived from the RI indicates that sections of the old
raceway in the landfill area are already collapsed.' '!'he new raceway
will be backfilled along its full length.
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Once the site is cleared of piles of debris and large vegetation, it is
anticipated that the septic tank can be located. Any materials
remaining in the tank will be tested and the proper disposal will be
determined ,based upon the aampling results. The tank will then be
backfilled or demolished depending on the condition of the tank.
At the conclusion of the remedial activities ~aking place on-site, the
entire five acre site would be qraded and covered with a vegetated soil
covering. A program for increased si~e security and maintenance would
be insti tuted which would 1nvol ve the enhancement of the existing
perimeter fencing and the mowing and maintenance of the vegetative
cover. In addition,~o maintain the overall protection of human health
and the environment believed tic be afforded by this remedy,
institutional control. would be 1.mplemented. The institutional controls
would be in the form of deed restrictions requlating land use at the
Site and would be focused on preven~ing the disturbance of the physical
inte9ri~y of wany of the remedies oo.ponents. EPA has proposed, in a
consent decree lodged in federal court, institutional controls with the
current owner -- Hydro-Manufacturing -- to protect the remedy.
To the extent required by law, EPA vill review the site at least once
every five years after ~he initia~ion of remedial action at the Site if
any hazardous substances, pollutants or contaminants remain at the Site
to assure that the remedial action continues ~o protect human health and
the environment. EPA will also evaluate risk posed by the Site at the
completion of ~he remedial action (Le., before the Site is proposed for
deletion from the HPL).
XI.
STATUTORY DETERMINATIONS
The remedial action selected for implementation at the stamina Mills Site is
consistent with CERCLA and, ~o the extent practicable, the NCP. The selected
remedy is protective of human heal~h and the environment, at~ains ARARs and
is cost effective. The selected remedy also satisfies the statutory
preference for ~reaaent which permanen~ly and 8iqnificantly reduces the
mobility, ~oxicity or volume of hazardous substances as a principal element.
'Additionally, the selected reaedy utilizes al~ernate ~reatment ~echnologies
or resource recovery ~echnologies ~othe maximum extent practicable.
a.
~he Se1ecte4 ...e47 i8 protective of Buaan .e.1th and the
I:nviroDJIent
The remedy a~ this si~e will permanently reduce, the risks posed to human
health and the environment by eliminating, reducing or controlling
exposures ~o human and environmental recep~ors ~ough ~reatment,
engineering controls, and insti~utional controls.
In-situ soil vacuum extraction will be used~o ~reat one of the
principal threats iden~ified at the Si~e, the TCE spill area aoils. The
TCE spill area soils will be treated to levels which will not impact the
groundwater above drinking water standards. soil vacuum extraction VI i 11
remove the contaminants from the apill area which continue to act as a
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source of groundwater contamination by trapping them on activated carD'
filters and then treating and disposing of the spent filters off-sit,
Capping of the landfill will eliJainate .exposure ~o con~aminan~s DY
direct contact and will control exposure from wind blown particles and
surface runoff. Capping will also limi~ infil~ration of precipitation
and control leaching of contaminants into the groundwater and surface
water. A leachate collection system will insure that contaminants from
the landfill do not impac~ the groundwater or surface water. Capping
is appropriate for the landfill wastes as they have been 8hown ~o pose
a relatively low long-term threat.
The ul~raviolet ligh~ and hydrogen peroxide (OV/hydr0gen peroxide)
system will be used ~o ~reat ane of the principal threats identified at
the Site, the contaminated 9roundvater plume. Contaminated groundwater
extracted from the bedrock aquifer will be ~rea~ed using this innovative
~echnolo9Y thereby eliminating future exposure through ingestion by
destroying the contaminants. The extraction system will be designed to
draw the groundwater contaminant plume back within the Site boundaries
and to prevent the further migration of contaminants beyond its current
boundaries. The ultimate goal of 'the groundwater extraction and
~reatment remedy will be to prevent further contamination of the areas
of the bedrock aquifer currently being used as a drinking water source
and to return the areas which have been impacted by the contamination
from the Site to their previous use as a drinking water source.
The overall Site alternative will remove the 8afety risks posed to the
public and workers on-site implementing the remedy by eliminating t' -
physical hazards at the Site. This alterna~ive includes the demoliti
of the partially standing building, the smokestack, the collapsine;
substructures, and the removal of piles of debris. The overall Site
alternative also will reduce the risks to the public and the environment
posed by contaminants migrating through on-site raceways to the Branch
River. Sealing the raceways will prevent exposure ~o contaminants
through direct contact and also indirect exposure through the ingestion
of fish tissue that may have ingested contaminants. The confirming of
the septic, tank location and the testing and removal of its contents
will eliminate the future risks of the ~ank con~aminating the
groundwater. The use of engineering con~rol. ~o addres8 ~hese
activities is appropriate as the condi~ion8 described p08e a relatively
. low long-~erm threat.
A long-term moni~oring program will insure that the selected remedy for
the Site remains protective of human health .nd the environment. This
program will include groundwater moni~oring and 8urface water and
sediment monitoring in the Branch River. Insti~u~ional con~rols in the
form of deed restrictions, will be used to con~rol the future uses of
the Site and will be focused on .-preven~ing the disturbance of the
physical inteqri~y of components of the reaedy.
Finally, implemen~a~ion of the selec~ed remedy will not pose
unacceptable short-term risks or cross-media impacts. The vaCUU::1
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extraction technology will be done in-situ and will not require any soil
excavation. The landfill will only be minimally disturbed during cap
construction and relocation of landf ill wastes from the floodplain. The
innovative technology being used to treat the qroundwater destroys the
contaminants and produces no additional waste streams. During
implementation of the overall site alternative, strict engineering
controls will be used to minimize any harmful releases from on-site
activities.
B.
The .electe4 ...e47 Attains ~
This reme,dy will attain all applicable or relevant and appropriate
federal and state requirements ~at apply to the Si te. The key
environmental laws from which ARARs for the .elected remedial action
are derived, and the specific ARARs include:
Chemica1-Snecific
Rhode Island Rules and Regulations pertaining to Public Drinking Water
(R46-l3-DWS)
Safe Drinking Water Act (SDWA)- Maximum contaminant Levels (MCLa)
Safe Drinking .ater Act (SDWA) - Maximwa Contaminant Level Goals (HCLGs)
Rhode Island Water Quality Regulations for Water Pollution Control
(R.I.G.L. 46-12, 42-17.1, 42-35)
Rhode Island pollutant Discharge Elimination System (R.I.G.L. 46-12,
42-17, 42-35)
Clean Water Act (CWA)- Ambient Water Quality criteria
Location-SDeci~ic
Rhode Island Freshwater Wetlands Act (R.I.G.L. 2-1-18-27)
Resource conservation and Recovery Act (RCRA)'
Clean Water Act, Section 404
Fish and Wildlife Coordination Act
Clean Water Act (CWA)- section 404 (Wetlands Protection)
Action-Snecific
Rhode Island Hazardous Waste Ganeration, Transportation, storage and
Disposal Regulations (R.I.G.L. 23-19-1-10)
Rhode Island Solid Wa.t. Manag...nt Regulations (R.I.G.L. 23-18.9, 23-
19, 42-17.1)
Rhode Island Underground Injection control Program (R.I.G.L. 42-17.1,
46-12 )
Rhode Island Pretreatment Requlations (R.I.G.L. 46-12, 42-17.1, 42-45)
Rhode Island Air Pollution control Requlationr
Resource Conservation and Recovery Act (RCRA)
DOT Rules for Transportation of Hazardous Materials
OSHA Health and Safety Standards '
OSHA Record Keeping, Reporting and Related Regulations
Clean Air Act- National Emission Standards for Hazardous Air pollutants
(NESHAPs)
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To-be-Considered
Rhode Island Draft Groundwater Classification Regulations
13.1)
EPA Risk Reference Doses
EPA carcinogen Assessment Group Potency Factors
Threshold Limit Values
OSWER Directive 9355.0-28
Executive Order 11988 (Floodplain Management Policy)
Executive Order 11990 (Wetlands Protection Policy)
Rhode Island is a RCRA aUthorized state Program.
(R.I.G.L. 46-
A more inclusive listing of ARARs can be found in tables 2-1, 2-3, and
2-4 of Section 2 of the FS. These tables, which are identified in
Appendix B of this Record of Decision, as Tables 9, 10, and 11
respectively, list all potential ARARS identified for the Site and give
brief synopses of the ARARs and explanations of the actions necessary
to meet the ~s. The tables also indicate whether the ARARs are
applicable or relevant and appropriate to actions at the Site. In
addition to ~s, the tables describe standards that are To-Be-
Considered (TBC) with respect to remedial actions.
Tables 5-1, 5-2, and 5-3 of Section 5 of the FS, which are included in
Appendix B of this Record of Decision, as Tables 12, 13, and 14
respectively, list the identified ARARs for each alternative and note
whether the ~s will be attained by the alternative. The July P',
1990 Addendum to the FS adds ARARs for a number of alternatives 1
deletes laws incorrectly described as ARARs for three alternatives. It
is identified as Table 15 in Appendix B of thi8 Record of Decision.
Applicable requirements are federal or state cleanup standards or
standards of control that specifically address a hazardous substance,
remedial action, location or other circumstance at a Superfund site.
NCP at 40 CFR 300.5, Federal Register, Vol. 55, No. 46, March 8, 1990.
Relevant and appropriate requirements are federal or state cleanup
standards or standards of control that, although not "applicable" to
the Superfund site, address situations sufficiently similar to those
encountered at the site that their use i. well suited to the particular
site.~. TBCs are advisories, criteria or CJUidance that were developed
by EPA, other federal agenci.. or stat.. that .ay be useful in
developing CERCLA remedies. 14. at 300.400.
Requirements that EPA found to be not 1.gal1y applicable to remedial
activities at the Stamina Mills Site, but either to be relevant and
appropriate or TBC for these activities are di8cussed below. All other
ARARs listed in the above-referenced table. are applicable to Site
remedial action.
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1.
~b.mical-SDecific .elevant and AODrooriate .eauirements
SDWA MCLs and MCLGs are standards that apply to public water systems.
Because the qroundwater in the vicinity of stamina Mills is used as a
.ource at private residential drinkinq water, but is not a public water
system as detined by the SDWA, HCX. and MCWs are relevant and
appropriate rather than applicable.
The Clean Water Act Federal Water Quality Criteria are non-entorceable
federal guidelines developed under the Clean Water Act which are used
by states to set water quality standards for surface water. Because
contaminants are miqratinq from the Site .to the Branch River, the
criteria are relevant and appropriate to r..edial action at the Site.
In addition, the criteria would be relevant aM appropriate to any
discharge of treated effluent from the Site to the River.
The Rhode 1s~and Ru1es and Regulations Pertaininq to Public Drinking
Water are inteDded to protect public drinkinq water sources. Although
the qroundwater below the Site is not a source of public drinking water
as defined by these regulations, it i. a .ouree of private residential
drinkinq water. The regulations are therefore relevant and appropriate
to qroundwater remediation at the Site.,
2.
Location-Soecific .elevant and ADorooriate .eauirements
RCRA Location Requirements i~ose limitations on the storaqe, treatment,
and disposal of RCRA hazardous wastes in 100-year floodplains. There
are not, to EPA's knowledge, any RCRA hazardous wastes disposed of in
the landfill on-site, including those areas of the landfill within the
100-year floodplain of the Branch River. Nonetheless, RCRA location
requirements are relevant and appropriate because the landfill contains
other hazardous substances. Remedial actions in the landfill should
therefore be consistent with the requirements that RCRA establishes for
activities affecting the lOO-year floodplains and which are designed to
be protective of human health and the environment.
section 404 of the Clean Water Act (Pertaining to Wetlands) is not
applicable because the site in not a federal wetlands. section 404 is
relevant and appropriate, however, because remedial activities will take
place in areas that are wetlands under state law. These activities,
e.q., backfilling the raceways, should conform to the specific
requirement. that section 404 imposes, to protect public health and the
environment, on activities in federally designated wetlands.
3.
Action-8oecific .elevant and Aoorooriate .eauirements
RCRA qroundwater .onitoriDq requirements are applicable for all of the
qroundwater treatment alternatives with the exception of GW-S, the no-
action alternative, for which they are relevant and appropriate. The
no-action alternative would not involve the treatment, storage, or
disposal of the qroundwater and therefore would not trigger RCRA
applicability.
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RCRA landfill requirements are relevant and appropriate based upon EPA
current information. This information indicates that although t..L.
landfill area contains no RCRA wastes, it does contain hazardous
substances. One of the purposes of RCRA is to protect human health and
the environment by providing for the safe storage, treatment, and
disposal of hazardous materials. Because hazardous substances were
disposed of in the on-site landfill, the circumstances at the Site are
similar to those intended to be regulated by RCRA making RCRA landfill
requirements relevant and appropriate. If EPA learns that the landfill
does contain RCRA wastes, then EPA would consider RCRA landfill
requirements to be applicable.
;
4.
Chemical-'Decific ~BCs
The Draft Groundwater Classification System under the Rhode Island
Groundwater Protection Act is a TBC because it has not been officially
promulgated. 1:£ this classification is promulgated, it will be
applicable to the Site. Onder the Draft, the projected classification
of the groundwater beneath the Site, with the exception of the landfill
area, is GAA, non-attainment -- which would require restoration to
drinking water standards. Promulgation of the Draft Classification
would therefore not affect remediation because federal ARARs for the
Site, i.e., SDWA MCLs and MCLGs, already require the groundwater to be
remediated to drinking water standards.
5.
Action-SDecific TBCs
Executive Order 11988 (Floodplain Management) is a TBC because, it t .
no specific requirements that pertain to this Site. The ExecutL -.
Order, however, is a TBC to the extent that is provides general guidance
for remedial activities in a floodplain.
Executive Order 11990 (Wetlands Protection POlicy) is not an ARAR
because no parts of the Site meet the criteria of a federally designated
wetlands. Parts of the Site, including areas where remedial activity
will take place are, however, wetlands under the Rhode Island law. The
Executive Order, therefore, will be considered to the extent that it
provides guidance on wetlands not provided by the Rhode Island wetlands
ARARs.
The Rhode Island Divi.ion of Air and Hazardous Materials Policy on
permitting air strippers is a TBC because it ia not a promulgated
statute or regulation. It 1s a policy which 18 potentially useful to
this CERCLA remedy.
It should be noted that although the Site lies within the Forestdale
Historic District, which i. li.ted on the National Register of Historic
Places, The National Historic Preservation Act is not an ARAR or a TBC.
In the judgement of EPA and the Rhode Island Historic Preservation
Commission, the selected remedy will have no adverse effect on the
Historic District.
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,.
Land Di8~o.al R..trict~
RCRA includes specific provisions restricting the land disposal of
certain RCRA wastes. The land disposal restrictions (LDRs) establish
treatment standards which must be achieved (by specific dates) for RCRA
hazardous wastes prior to their disposal or placement on land. It is
. important to note that LDRs apply prospectively to wastes land disposed
after the effective date of the restrictions but do not require removal
and treatment of wastes land disposed prior to this.
LDRs are not an ARAR for the TCE spill area soils because the treatment
of soils in the spill area will ,solely be an in-situ activity and
therefore will not involve the plaaement of a RCRA hazardous waste.
The LDRs are not an ARAR for the excavation of aediments in the
floodplain of the Brancb River and the consolidation of the sediments
under the cap, because this action does not involve placing of hazardous
waste in a land-based 'Imi t. The area where the sediment is to be
excavated from is located in the floodplain of the Branch River at the
base of the retaining wall which acts as the southern boundary of the
landfill. Sediments found adjacent to the landfill retaining wall
result primarily from the erosion of materials from the slopes of the
landfill. The sediments to be consolidated are contiguous to the
landfill, uninterrupted by roads, paths, or other easements or right of
ways. The landfill and sediments adjacent to it constitute one area of
contamination for CERCLA purposes and thus one unit for land disposal
purposes. Therefore, movement of the sediment adjacent to the landfill
does not qualify as placement but is merely movement within the unit.
The only site activity for which LDRs may be an ARAR is for the removal
of the contents of the septic tank. The septic tank is believed to be
located underneath one of the existing debris piles at the Site. As a
result, EPA has been unable to sample its contents but did find during
the RI elevated levels of TCE in a leaching field pipe associated with
the septic tank. Therefore, a determination cannot be made until the
contents of the tank are sampled as to whether LDRs are an ARAR.
C.
~he 8e1ecte4 ...e4ia1 ActioD ia Coat-.tfective
In the Agency'. judgment, the .elected remedy i. cost etfective, i.e.,
the remedy afford. overall effectivene.a proportional to it. costs. In
selecting this remedy, once EPA identified alternatives that are
protective of human health and the environment and that attain, or, as
appropriate, waive ARARa, EPA evaluated the' overall effectiveness of
each alternative by assessing the relevant three criteria-- long-term
effectiveness and permanence: reduction in toxicity, mobility, and
volume through treatment: and short-term effectiveness, in combination.
The relationship of the overall effectiveness of this remedial
alternative was determined to be proportional to. its costs. The costs
of this remedial alternative are:
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COST OJ' OVERALL UKEDY
Capit:a1 O'M Cost:s Present:
Cost:s lS/vr) Wort:h
TSA-3 Soil Vacuum
Extract:ion $266,465 1,500 280,605
LA-3 Consolidat:ion
and Capping $587,750 62,000 1,172,000
GW-4 UV/hydrogen
Peroxide $705;890 73,500 1,889,760
OS-3 Demolition, Sealing
Raceways, septic Tank,
and site Grading $715,825 27,400 974,120
A discussion of the relative cost effectiveness of each component of
the selected remedy follows. The present worth costs shown are based
on a discount rate of ten percent as recommended in the NCP.
1.
TCE Soi11 Area
COST COKP~SO. 07 TCE SPILL AREA ALTERNATIVES
capit:a1 05M coata Present:
Cost:s (S/vr) wort:h
TSA-1 Excavation and
Incineration. $9,994,150 100,000 10,690,620
TSA-3 Soil Vacuum
Extraction $266,465 1,500 280,605
TSA-4 No-action $40,140 1,500 54,280
Of the two alternatives that are protective and attain ARARs, TSA-1 and
TSA-3, alternative TSA-3 has the more cost-effective components. TSA-
3 provides a degree of protectiveness proportionate to its costs. 50il
vacuum extraction was estimated to be siqnificantly less costly than
excavation and incineration. Excavation and incineration would cost
approximately 4000 percent more than aoil vacuum extraction. The least
expensive alternative, TSA-4, the no-action ~lternative, did not meet
ARARs since it would not remove the contaminants from the spill area
soils which are migrating into the groundwater.
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2.
Landfill a.re,
COST COMPARISON 01' LUDI'ILL DBA &.LTBRNATIVES
capi~al 0'. co.~. ~re.en~
Cos~s fl/vr) .or~b
LA-l Excavation and
Incineration $17,960,700 100,000 18,815,840
LA-3 Consolidation ;
and capping $587,750 62,000 1,172,000
LA-5 No-action $30,140 18,500 204,540
Of the two alternatives that are protective and attain ARARs, LA-l and
LA-3, alternative LA-3 has the more cost-effective components. LA-3
provides a degree of protectiveness proportionate to its costs.
Consolidation of landfill wastes in the floodplain of the Branch River,
construction of a leachate collection system, and capping of the
landfill was estimated to be far less costly than excavation and
incineration of all landfill wastes. Excavation and incineration would
cost approximately 1600 percent more than consolidation and capping.
The least expensive alternative, LA-5, the no-action alternative, did
not meet ARARs since it would not reduce the leaching of contaminants
from the landfill into the groundwater and river, nor would it prevent
the erosion into the river of landfill wastes con~aininq contaminants.
3.
Groundwater Bztraction and ~reatment
COST COMPARISON 01' GROmmDTBR TRBATKBN'l' ALTBRNATIVES
capital 0'. coata pre.ent
Costs 18/vr) .or~b
GW-l Air stripping $1,537,140 139,525 3,190,010
GW-2 Granular Activated
Carbon $1,789,425 114,225 3,262,792
GW-4 UV/hydrogen
Peroxide $705,890 73,500 1,889,760
GW-5 No-action $6,850 46,200 442,372
Of the three alternatives that are protective and attain ARARs, GW-l,
GW-2 and GW-4, alternative GW-4 has the most cost-effective components.
GW-4 provides a degree of protectiveness proportionate to its costs.
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All three alternatives include the estimated costs of an extractir..
system and a pretreatment process to remove suspended solids (e.c;
pressure filtration). The final details of the extraction system Wil~
be decided upon completion of the pump test during predesign activities.
Although extraction costs may therefore change, the cost of extraction
would be the same for each groundwater treatment alternative.
As part of predesign activities, a pilot test of the UVjhydrogen
peroxide system will be performed with groundwater obtained from the
pump test. One of the goals of the pilot test will be to determine the
effectiveness of pressure filtration for removing suspended metals. In
the event that additional pretreatment is needed, EPA will re-evaluate
the costs of this alternative and make a determination of whether the
degree of protectiveness is still proportional to its cost.
Treatment of the extracted qroundwa~er with the UVjhydrogen peroxide
system was estimated to be significantly less costly than the air
stripping and the granular activated carbon alternatives. Air stripping
and granular activated carbon would both cost approximately 170 percent
more than the UVjhydrogen peroxide system. The least expensive
alternative, GW-5, the no-action alternative, doe. not meet ARARs since
it would not reduce the concentration of contaminants found in the
groundwater to drinking water standards.
4.
OVerall Site
COST COMPARISON OP OVERALL SITE ALTERN1TrvBS
capital
Cost.
O'M Co.t.
(S/vr)
pre.ent
Worth
OS-3
Demolition, Sealing
Raceways, septic Tank,
and Site Grading
Demolition, sealing
Raceways, Septic Tank,
"Hot spot" Excavation,
and Site Grading
$715,825
27,400
974,120
OS-4
$914,475
31,400
1,210,480
.OS-5
No-action
$42,510
8,000
116,930
Of the two alternatives that are protective and attain ARARa, OS-3 and
OS-4, alternative 05-3 has the more cost-effective components. 05-3
provides a degree of protectiveness proportionate to its costs.
Demolition of the on-site structures, sealing and backfilling of the
raceways, confirming the location of the septic tank and removing its
cont.nts, and site grading were estimated to be slightly less costly
than alternative 05-4 which requires, in addition, the excavation of
"hot spot" soils and the removal of sediment from the raceways. It
-------
should be noted that EPA has evaluated the risk levels associated with
the "hot spot" soils and has determined that these soils do not pose a
risk to public health and the environment. In addition, the costs for
alternative OS-4 are very preliminary in that the areal extent of "hot
spot" contamination and the quantity of raceway sediment has never been
delineated. Moreover, the cost estimates for OS-4 .hown above assume
that the excavated materials could be disposed of in the on-site
landfill. Based upon state comments on the FS, excavated materials
would have to be tested and, if they contain hazardous substances, would
have to be treated and/or disposed of off-site. The off-site disposal
or treatment of excavated hazardous wastes would .iqnificantly increase
the cost estimates for 08-4 shoWl)" above. . Therefore, EPA does not
believe that the additional activi~ies proposed under alternative OS-4
provide a deqree of protectiveness proportional to their costs. The
least expensive alternative, OS-5, the no-action alternative, does not
meet ARARs because it would not reduce the aiqration of contaminants
through the raceways into the Branch River and it would not eliminate
the potential qroundwater contamination source presented by the septic
tank and its contents.
D.
The Selecte4 aeme4y utili.e. Permanent Solution. an4 Alternative
Treatment or ae.ource aecovery ~echDoloqie. to the Maximum Zztent
practicable
Once the Agency identified 1:I108e alternatives that attain or, as
appropriate, waive ARARs and that are protective of human health and
the environment, EPA identified which alternative utilizes permanent
solutions and alternative treatment technoloqies or resource recovery
technologies to the maximum extent practicable. This determination was
made by deciding which one of the identified alternatives provides the
best balance of trade-offs among alternatives in terms of: 1) long-term
effectiveness and permanence; 2) reduction of toxicity, mobility or
volume through treatment; 3) .hort-term effectiveness; 4) implement-
ability; and 5) cost. The balancing test emDhasized long-term
effectiveness and permanence and the reduction of toxicity, mobility and
volume through treatment; and cqnsidered the preference for treatment
as a principal eteaant, the biaa against off-aite land disposal of
untreated waste, and community and state acceptance. The selected
remedy provides the best balance of trade-offs among the alternatives.
1.
'1'9 8"i11 Area
Alternative TSA-3, in-situ 80i1 vacuua extraction, was selected as the
component of the remedy to address .pill contaminated 80ils because its
long-term effectiveness, permanence, and ability to reduce toxicity,
mobility, and volume of contaminants through treatment was the most
efficient in light of impl..entability, ahort-term effectiveness and
residual risk concerns. Although alternative TSA-l, excavation and
incin~ration, provides for greater certainty in terms of the time frame
required to achieve remediation levels and its ability to reduce
toxicity, mobility, and volume of a wider range of contaminants through
treatment, these advantages are outweighed by the differences between
-------
the two alternatives in terms of short-term effectiveness, cost'
implementabili ty, and residual risks remaining after treatment. A brL
discussion of the advantages and disadvantages of each alternative is
presented below but is discussed in greater detail in Section IX of this
document.
Both alternatives TSA-l and TSA-3 use treatment technologies which are
effective in eliminating the principal contaminants found in the spill
area, TCE and its breakdown products. Alternative TSA-l would achieve
the destruction of additional contaminants such as PAHs, which were
found at low levels throughout the Site, but the removal of these
compounds would not provide greater protection from the primary risks
identified ~or the .pill area. ~
The time frame required to reach the soil remediation levels can be
estimated with greater certainty ~or alternative TSA-l than for
al ternati ve '1'SA-3. Despi t.e the uncertainties associated with the
estimation of the cleanup time frame for TSA-3, the overall time frame
for reaching remediation levels throughout the spill area is roughly
equivalent for both alternatives and would take approximately 1 to 2.5
years.
Because TSA-l and TSA-3 are roughly equivalent with respect to the
primary balancing criteria of long-term effectiveness and pe%1l1anence and
reduction of toxicity, mobility, or volume through treatment, the
differences between the mOdifying criteria as described below formed the
basis of EPA's remedy selection for the spill area.
Alternative TSA-3 poses less potential for adverse short-term effec
on the community, environment, and on-site workers. This alternative,
which relies on in-situ extraction, does not require the excavation of
contaminated soils which contain compounds that are likely to be
released into the air. The equipment needed to construct and operate
alternative TSA-3 is readily available and requires fewer engineering
controls to install and operate, and produces fewer waste streams
thereby making it more implementable than TSA-l. The costs for
alternative TSA-3 are significantly lower and since it achieves similar
long-term effectiveness and permanence through treatment as alternative
TSA-l, it provides the greatest degree of protectiveness proportional
to its cost.
The final difference relates to the residual risks for both
alternatives. Alternative TSA-3 produces spent carbon filters from the
treatment of air emissions which require off-site treatment and
disposal. The spent carbon can be regenerated and once it has been
regenerated it can be reused and would therefore no longer require
treatment and disposal. Alternative TSA-l produces a number of side
waste streams which .ay require treatment. The principal waste is
bottom ash which often exhibits a hazardous characteristic. This waste
requires treatment before its disposal in a seQure landfill. Members
of the community did not indicate a preference for one treatment
alternative over the other. .
-------
In summary, although TSA-l and TSA-3 are roughly equivalent with respect
to the primary balancing criteria of long-term effectiveness and
reduction of toxicity, .obility, or volume through treatment, TSA-3 has
significant advantages with respect to the .odifying criteria,
specifically, short-term effectiveness, cost-effectiveness, and
implementability. Therefore, TSA-3 was chosen as the component of the
.elected remedy for the spill area .oils.
2.
Landfill ar..
Alternative IA-3, which includes the excavation of landfill wastes
within the floodplain of the Branch River, consolidation of the wastes
under a mUlti-layer cap, and the in8tallation of a leachate collection
system, was ael8C'ted as the component of the remedy to address the
existing on-ait. landfill. A~thou9h this alternative doe. not employ
a treatment technology, it prevents direct contact with contaminants,
controls further downvard and off-site migration of leachate, and
minimizes dust erosion and surface runoff. LA-3 therefore meets all the
remediation goals for the landfill. .
Alternative LA-l, excavation and incineration, provides much greater
long-term effectiveness and permanence since it reduces the toxicity,
mobility, or voluae of .ost contaminants through treatment. The
advantages of this alternative are tempered somewhat for this Site
because of the concerns for its short-term effectiveness,
implementability, and costs.
The excavation, separation, and materials handling required by LA-l
prior to incineration has the potential to generate air emissions during
the three-year period of operation. Because of the proximity of
residences, the air emission would potentially create odor problems and
potential health risks to the public and on-site workers despite the
use of enqineerim) controls and air monitoring. The substantive
requirements to be .et for the test burn and disposal of waste streams
associated with incineration would make this alternative less
implementable than capping.
Of these two alternatives that are protective and attain ARARs, LA-l and
LA-3, alternative LA-3 has the more cost-effective components. LA-3
provides a degree of protectiveness proportionate to its' costs.
Additionally, the generation of bottom ash, which potentially requires
further treatment because of the presence of metals in the landfill
wastes, creates another residue requiring di8posal. Some members of the
community voiced their preference ~or . permanent solution eliminating
the contaminants in the landfill. EPA a180 has a preference for a
permanent solution. However, when balancing the overall effectiveness
of incineration with the disadvantages discussed above as well as the
cost-effectiveness of incineration in achieving the protectiveness
objective, EPA has selected consolidation and capping of the wastes as
the remedy for the landfill area.
-------
3.
Groundwater Zztraction and ~reatmeDt
Alternative GW-4, which uses the innovative technology of ultraviolet
light and hydroqen peroxide, was .elected as the component of the remedy
for the treatment of contaminated qroundwater because of its long-term
effectiveness, permanence, and ability to reduce the toxicity, mobility,
and volume of contaminant. through ~reatment. Alternatives GW-l and
GW-2 provide similar long-term effectiveness and permanence in their
ability to eliminate known contaminants, but produce waste streams which
require off-site ~reatment and/or disposal. An additional disadvantage
of alternatives GW-l and GW-2 i8 that the activated carbon used to
supplement ~reatment in GW-l and p~ovide primary treatment in GW-2, is
not effective in rec1ucinq the ~oxicity of vinyl chloride. Vinyl
chloride, a breakdown product. of TCE, bas been found at very low levels
at the Site up ~o now, but due ~o ~ransformations brought about by
natural biological reac~ions it may be found at a grea~er concentration
in the future. Alternative GW~4 destroys vinyl chloride and other known
contaminants in the groundwater, while producing only carbon dioxide,
water and free chlorides which go on to form small quantities of salts.
GW-4 therefore has significant advantages over GW-l and GW-2 with
respect to ~he reduction of toxicity, mObility, and volume of known and
probable contaminants, and cost-effectiveness. In addition, the
community did not indicate a preference for another alternative.
consequently, EPA has selected GW-4, the innovative technology of
ultraviolet light and hydrogen peroxide, as the remedy for the
groundwater.
4.
OVerall sit.
Alternative OS-3, which addresses the physical and health hazards
associated with the conditions of the overall site by demolishing on-
site structures, sealing and filling the raceways, locating and removing
the contents of ~he septic ~ank, and grading the overall Site, was
selected as the component of the remedy for the treatment of the overall
Site. It differs from OS-4 primarily in that alternative OS-4 would
require ~he excava~ion of contaminated soils from the "hot spot" and
raceway sediments. The.. excavat.d ..~erials would be ~ested and
~reated and/or disposed of off-si~e. The "ho~ .po~" con~ains elevated
levels of PABs. Wha~ever the sourc. of PABs, th8 levels de~ec~ed in the
"hot spot" were too low to pose a significant risk to public health and
the environment. EPA believes that the filling and sealing of the
raceways would prevent the further migration of the sediments into the
Branch River. This would eliminate the future risk posed ~o public
health and the environment without the need for excavation of the
sediments.
Another potential problem associated with alternative OS-4 i. related
~o the cost. An impo~an~ a.sumption mad8 in the FS and reflected in
the costs for OS-4 was that the excavated soil and raceway residues
would be managed on-site by combining it with landfill wastes. . Based
upon subsequent comments from the State, it appears that this material
-------
would have to be treated and disposed of off-site which would
significantly increase the costs shown. Since the quantity of material
to be excavated from the Whot spot" and raceways is unknown, a more
refined cost estimate cannot be provided. Because the long-term
protectiveness of both alternatives is very similar and because 05-3
provides the qreater deqree of protectiveness proportional to its cost,
EPA has selected OS-3 as the remedy for the overall Site.
~h. S.lect.4 ....4y Sati.fie. th. Pr.f.r.nc. for ~r.atm.nt Which
p.rmaneDtlr aD4 Significantly r.duc.. ~h. ~ozicity, .o~ility or
Volume of th. B..ar4ou. S~.taDc.. a. . principal 8l...nt
The principal elements of the selected remedy are source control and
management of miqration. These elements address the primary threats at
the Site, contamination of the 80i1 and the groundwater with TCE and
other VOCs. The selected remedy satisties the statutory preference for
treatment as a principal element by ~) treatiDg contaminated soils using
soil vacuum extraction and reducing the concentration of VOCs in soils
to levels which will not: impair drinking water standards and 2) treating
the extracted groundwater using an innovative ultraviolet light and
hydrogen peroxide technology which will result in the removal of VOCs
to levels protective of buaan health and the environment.
8.
%11. DOCUMENTATION OP NO SIGNIPICANT CHANGES
EPA presented a proposed plan (preferred alternative) for remediation of the
Site on July 10, 1990. The source control portion of the preferred
alternative included:
1.
2.
3.
4.
5.
5.
In-Situ treatment of TCE spill area soils;
Excavation of landfill materials in the flood plain:
Stabilization of landfill slopes;
Installation of a landfill leachate collection system:
Capping of the landfill:
Location of the septic tank and removal of its contents.
The management of miqration portion of the preferred alternative included:
1.
2.
Groundwater extraction and treatment;
Sealing of raceway entrances and exists and backfilling raceways.
No significant changes from the Proposed Plan have ~een made to the selected
remedy as detailed in the Record of Decision. However, the following
discussion is presented as a point of clarification.
As part of the Proposed Plan, landfill wastes which are located in the 100-
year floodplain of the Branch River are to be excavated, placed on the
landfill above the flooclplain, and incorporated under the cap to be
constructed. EPA believes that landfill wastes in the floodplain also
includes those sediments found in and along the bank of the Branch River
adjacent to the landfill and along its southern boundary. The western limit
of the sediment to be excavated is the new raceway exit and the eastern limit
-------
is roughly the eastern edge of the landfill. This sediment adjacent to the
landfill has been shown to contain elevated levels of landfill-specif
contaminants such as dieldrin. Additional downstream locations were test
and the sediment .ampled there did not reveal siqniticant levels ot landfill-
specitic contaminants. Therefore, in order to achieve the cleanup goals for
the landfill which includes aitiqating the release ot contaminants to the
Branch River and thereby protecting human health and the environment, these
sediments'will be excavated along with other landtill wastes within the 100-
year tloodplain and placed under the landtill cap. During the excavation of
the sediments appropriate .teps will be taken to minimize the redistribution
of contaminants into the Branch River by installing silt barriers or using
other appropriate engineering controls.
.
.
XIII.
8TATZ ROLB
The Rhode Island Department ot Environmental Management has reviewed the
variou8 alternatives and has indicated its support tor the selected remedy.
The state has a180 reviewed the Remedial Investigation, Risk Assessment and
Feasibility study to determine it the selected remedy is in compliance with
applicable or relevant and appropriate state Environmental laws and
requlations. The State ot Rhode Island concurs with the selected remedy for
the stamina Mills Site. A copy ot the Declaration ot Concurrence is attached
as Appendix D.
-------
APPENDIX A
-------
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-------
Figure 2
Stamina Mills Superfund Site Location Map
G)
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Island
.
North Smithfield
80JJ
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Branch River
Legend
~~ Stamina Mills Site
-------
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ORA WN) TITLE
FIGURE 5
STAMINA MillS SITE FEATURES
PIIO.ECT
GHR ENGINEERING
ASSOCIATES. INC
109 RHODE ISl ANO
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02J"
STAMINA MILLS
FEASIBILITY STUDY REPORT
CUEHT
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o MW-11 y ~/1P;:o/ /MWJ~ '" I. .. ---
MW-lt .-10 MW-~ ..At- ~}d._..... / I. ~~
TP-41" /., ~. "'f' C£.T3 MW-4, 4A~-- -
. =~ \'('''''''I{'>~~ ~
. TP-4~.:::r.W-IZ."" ~ ~
-----___\_202A ,,~ .'
M~~1 ~...f If'
~~
~ ..
----
o
"'..
FORESTDALE
POND
....... '"
.
-1
NOTEI:
LEGEND:
1. T..8C8U... M LAMWIU. DE.III, HTE~D I'IIOM Yl8UAL
O..EIIVATIOII. MADE DUII..G nn "IT UCAVATI01I8 AIIO
MOIIITOII88G WELL ..nALLATIOI88,
. n AM- MILLe 8UI'I'L" WELL
~O'
SCALE IN fEET
T'
'-1 . MONITOII- WELL ..nALLID .., GU, 1881.
L CONTOUR' Of' L-.u. H.II18 TltlCIIIIE.. AilE '''ED UPON WIDELY
'''ACID "0"". ACTUAL 8U..UII'ACE CONDITION8 MAY VAil.,
'"0M T..OIE ...OWII. .
. .
.. THlCII..... 0' LANMlLl DUIl18 'AIED ON 'OTAL '"lellll." 0'
DE.II18 AT lAC" "O"T IIEGAIIDlE8. 0' DE"'" 0' 01.1118.
. .. OIlL., n., I'IT' .. Vlellll'" 0' LAND'lll AilE ...OWN. "."!!" TO 81TE .
"LAII .,,-. '0" lOCATION 0' All EI~lORATION AND SA..PLIIIG ~OINT'.
MW-I' . MONITOII- WELL ..S'ALllD.., GltR, 1881 AND 181..
RI'." TO 'O"IIIG LOG8 .. APPENDII E fOA
LANDfILL DE8AIS T..CII_8SE.
TI'-81'" TIlt PIT IIICAVATED -- REMEDIAL ..VESTlGATlON
AEfE" TO TE8T ~IT lOG8 .. AP~ENOI. A
fOil LANDfILL DEBII18 '..lellNESS
fGJHrR1
DRAWING TIlLE FIGURE 6
AREAL EXTENT AND THICKNESS
Of LANDfILL DEBRIS
eTAMINA WillS sITe
NORTH S.,ITHfIElD. RHODE ISLAND
PROJECT
~10- - CONTOUR Of THlellNE8S OF lANDfILL DE8RIS
(DASHED WHERE -ERREO) REfER TO TEST ~IT lOOS
. IN A~PENOI. A fOil LANDfILL DE8RIS THICKNESSES
GHA ENGINEERING
ASSOCIATES. INC
109 RHODE ISlAND
no lAKEVILLE MA
02347
ST"""," MLl!>
REMEDIAL INVESTIGATION
(ll[""
-------
~
.....
~
p:J
"..-
.a.-
! .~
<1'-'"
\:
.,.--
i1
..!
~i
. ~13.
FWAW.
~32
A-~OO.
cP-
/'
. .
(
lEGfND
ff ACTIW RESIDENTIAL WEllS
FORESTDAlE WATER ASSOCIATION
ACTIVE Rli8IDeNTIAl WEllS
CONTOUR OF TCE ff GROUNDWATER (ppb)
(DASHED WHERE INFERRED)
(G]H~
o'
I
"100'
400'
800'
I
8CALE
GHA ENGINEERING.
ASSOCIATES, ffC.
108 RHODE ISLAND
RD.,lAKEVlllE. MA
023.7
OWO TlTLEFIGURE 7
lOCATION OF
OFF-SrTE GROUNDWATER
ONTAMINANT PLUME 1986 &~~I
PRO.IECT
STAMINA MILLS
FEASIBILITY STUDY REPORT
--
CLIENT
-------
{
N
t
,
\
~\:..
A' ~
O~ ~ IIW-fA
~ '1 IIW-I~'
~ aC![]~ IIW-7
1! " MW-IA ~ \\ ~
~~ ~ Q"O
~~ ..,~
"'~.... . ~ ~O
~~. \,0
1IW-14
0Q[J
0--1 0
~ IIW-ti
C!LJ
C8 "'-1
C![]
(::)
0'
L-
eo'
120'
I
alAIN
NOTES:
t".) VALUEI IHOWN. AAE IUI..ECT TO CHAII... DVEA 'IMI.
'.) CON'OUAI AAE IDEALIZED AND IUI..ECT TO CHAII..E DVIA
liME.
I,) CON'OUAI 10110 lII'EArOLATED IITW..II DATA rO.N'. IN/'EAAED
III O'HEA AAEAI.
SCALE IN FEET
..) TCE COIICIIITAATlOIII AAI PAlllllTED ... OADIA OF OlrTH
IILOW ..AOUIID IUAFACI, FAOM MW-'Ol C.I 'IITI TO IIIW-'O
CUI FEET). IAMrUA "'TEAVAL II A,rAO.IIIATELY .1 FElT.
IAMPUI FAOM ITAM.IIA MILLI WELL AAE AI FOLLOW I : THI!
IHALLOW IAMPLI! CI) II AT THE WATI!A, "'T. IAMrLI CU. '00
'EIT IELOW THI! WATEII TAILE. THI! DEEP IAMrLl! CO). AT
10"OM OF WI!LL C"O FUT).
I.) Tel! COI8CIIITAATlOIII ... ..AOUIIDWATI!II FAOM MW-' THIIOUGH
MW-'Ol!. 1-' THAOUGH I-I AIID THE ITAMHIA MILLI WELL AliI!
IAIID 011 DATA COLLECTED'" MAllett "I.. TCI CONCENTIIAIIONI
FOil WELL' MW-11 THAOUOH MW-" AND ALL IUIIFACE WATIII
IAMrUI AilE IAIED ON ANALYTICAL DATA COLLECTED IN ./UNE
,....
~
~B-2
C8 IIW-4
1'00.0001
MClNI10RING WEll. INSTAl1.EO BY
GZA 118821
MCIN11OA1HO WEll. IN'TAl1.EO BY
GHA 118881 WllH CONCENTRATIONS
OF TeE" OftOU«)WATER Cppbl
.(GJHIRl
DAA WINO TitlE
FIGURE 8
AREAL DisTRIJUTION OF TCE
IN GROUNDWATER IN 1988
PflO.80CT
NOT DETECTED
'CClN1OOR OF TCE CONCENTRATIONS, (ppbl
C 100...... DASHED WHERE INfERRED
-
NO
GHR ENGINEERING
ASSOaIl.TT:S. INe.
109 RHODE ISlAND
RO..lAKEVILlE. MA
02347
STAMINA MILLS
FEASIBILITY STUDY REPORT
ClENT
-------
-
-
--
FOAESTDALE
POND
.
D
~
AACiEWAYS
...... 'JII) 1
[)E!f!S J=---J
-~-
QASSOMETER 0
"HOT SPOTo
D
'.
LEGEND
o
I
8TM8M MI.L8 8UPPL Y WELL
ON-enE QRCUGWATEA REMEDIAL UNIT
TCE 8P8.L NfEA NG LANDfU. REMEOIAL ~
(GJHIRl
OVERALL 8fT£ REMEDIAL &HT
GI~ ENGINEERING
ASSOOAT!":S. IN(.
109 AHOOE 'SLAND
RO.lAKE\IIllE. MA
()2J.~
«Y
8CAL£ .. FI£T
...---
'':'--
-
-
,80'
I
F1GURE 9
R&M<0Ul. INTS FOR THE
8'~ MI.1.S Sf1"E
NOATH~LD.L~_~
CI
8TA"..A MILLS
FEAS.""Y STUDY REPORT
CUENT
-------
SECTION A-A
SCALE: r . 20"
-...
;7..10
110
STAMNA MLLS FEASIBIUTY ST\JD'( REPORT
~#7h~:~~NG CONTOURS AlT=~:E_~-3
<~;1?2i~~~~:;:~,~'''CO.'::''R': = DETAL
UNDFILLDI!8Rt.~~« / 7/~..... PUI~T~
80TTOM 01' LANDFILL ..'::<../ (/)5<.';...
GROUNDWATER TA8LE ~--<'(.b 8RANCH RIVER.
U " " n " " m m m
10
10
30
110
200
110
'-
...
.. Pt.ANTA8U lOlL AND
FILTER FA8RIC
100 YEAR FLOOD Pt.AIN
ELEVAnON-1...1" NGVD
CLEAN STONE
AND lOR FILL
"'P-RAP
(LAROE SlZI!
STONE I
8RANCH RIVER
;- FILTER FA8RIC
2. PLANTA8LE IOIL-
f-10-3 CIilS SAND LAYER -)'-'':'~:~'~'JT-;;'J)'';Ct.
2.-10-7 CMIS SOIL UNER - /) J '/ /"-
40 "L HOPE
RCRA CAP DETAIL
NOT TO SCALE
[@H1R1
SECTION B-B
NOT TO SCALE
FIGURE 10
GHR (NGINfERIN(;
ASSOOAf1eS. INC
'0') Of .00£ ISlANO
110 lAKEVILlLMA
-------
APPENDIX B
-------
TABLE 1: SUMMARY OF CONTAMINANTS
OF CONCERN IN GROUND WATER ZONE 1
AVERAGE HAXIMtJH
CONTAMINANTS OF CONCENTRATION DETECTION FREQUENCY OF
CONCERN CPPB) CPPB) DETECTION
Arsenic 12.2 "13.3 2/25
Chloroform 15.5 25 2/24
l,l-Dichloroethylene 20.1 36 3/24
Phthalate,bis(ethyl- 98.9 420 9/22
hexyl)
Tetrachloroethylene 4.0 5.0 2/24
Trichloroethylene 171219.4 850000.0 34/34
Vinyl chloride 5.5 6.0 2/24
Barium 54.4 169 25/25
Copper 7.2 12 6/25
1,2-Dichloroethylene 7911.2 31000.0 15/24
Lead 3.4 10.5 7/25
Selenium 3.7 5 2/25
-------
TABLE 1A:
CARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTION
OF GROUND WATER Zone 1
CANCER
CONCENTRATION POTENCY EXPOSURE RISK RISK
CONTAMINANT OF (UG/1) FACTOR FACTOR ESTIMATE ESTIMATE
CONCERN AVG MAX MG/KG/d-1 l/MG/d AVG MAX
Arsenic 12.2 13.3 1.75E+00 2.9E-02 6E-04 7E-04
Chloroform 15.5 25 6.10E-03 2.9E-02 3E-06 5E-06
1,1 Dichloroethylene 20.7 36 6.00E-01 2.9E-02 4E-04 1E-01
Phthalate,bis(2 ethyl- 98.9 420 1.40E-02 2.9E-02 1E-04 6E-04
hexy l)
Dieldrin 0.4 0.4 1. 60E+01 2.9E-02 3E-04 4E-04
Tetrachloroethylene 4.0 5.0 5.10E-02 2.9E-02 7E-.Q6 9E-06
Trichloroethylene 171219.4 850000.0 1.10E-02 2.9E-02 6E-02 2E-01
-------
TABLE IB:
NONCARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTION
OF GROUND WATER ZONE 1
CONCENTRATION REFERENCE EXPOSURE HAZARD HAZARD
CONTAMINANTS OF (UG/l) DOSE FACTOR INDEX INDEX TOXICITY
CONCERN AVG MAX MG/KG/d I/KG/d AVG MAX ENDOPOINT
Arsenic 12.2 13.3 1.00E-03 2.9E-02 5E-02 5E-02 Keratosis
Hyperpigmen-
tat ion
Chloroform 15.5 25 1.00E-02 2.9E-02 5E-02 8E-02 Liver lesions
1,1-Dichloro- 20.7 36 9.00E-03 2.9E-02 lE-01 3E-Ol Liver lesions
ethylene
Dieldrin 0.4 0.4 5.00E-05 2.9E-02 4E-01 5E-01 LiW!r lesicn;
Phthalate,bis- 98.9 420.0 2.00E-02 2.9E-02 4E-01 2E+00 Liver
(2 ethylhexyl)
Tetrachloroethylene 4.0 5~0 1.00E--02 2.9E-02 2E-02 2E-02 Hepatotox-
icity
Barium 54.4 169.0 5.00E-02 2.9E-02 3E-02.. 1E-01 Increased
BP
Copper 7.2 12.0 1. 30E+00 2.9E-02 6E-06 9E-06 GI distress
1,2-Dichloro- 7911. 2 31000.0 2.00E-02 2.9E-02 5E+01 2E+02 Increased
ethylene serum alk-
alinephos-
phatase
Lead 3.4 10.5 5.00E-02 2.9E-02 3E-02 1E-02 CNS effects
Selenium 3.7 5.0 2.00E-03 2.9E-02 2E-02 2E-02 Dermatitis
-------
-2-
Hazard Index Sums
Average
Liver Lesions
Increased BP
CNS Effects
Dermatitis
Anemia
5E+OI
5E-02
JE-02
2E-02
9E-OJ
Reasonable Maximum
Exposure
2E+02
5E-02
IE-OI
2E-02
5E-02
-------
TABLE 2:SDMMARY OP CONTAMINANTS OP CONCERN
IN GROUND WATER (ZONE 2 LANDFILL AREA)
AVERAGE MAXIMUM
CONTAMINANTS OF CONCENTRATION DETECTION PREQUENCY OF
CONCERN (PPB) (PPB) DETECTION
Arsenic 9.0 '10.0 2/10
Dieldrin 1.2 4.0 4/8
Phthalate,bis 80.5 100.0 2/7
(2ethylhexyl)
Trichloroethylene 15101.7 100000.0 7/12
Vinyl chloride 131.7 220.0 3/12
Barium 103.2 187.0 6/10
Copper 23.9 56.0 8/10
Cresol,p- 8.0 8.0 1/10
Dichloroethylene, 2922.5 7100.0 4/12
1,2-
Lead 13.8 29.0 7/10
Nickel 29.2 29.2 1/5
Selenium 5.4 5.4 1/10
-------
TABLE 2A:
CARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTION
. OF GROUND WATER Zone 1
CANCER
CONCENTRATION POTENCY EXPOSURE RISK RISK
CONTAMINANT OF (UG/l) FACTOR FACTOR ESTIMATE ESTIMATE
CONCERN AVG MAX MG/KG/d-l I/MG/d AVG MAX
Arsenic 12.2 13.3 1.75E+00 2.9E-02 5E-04 5E-04
Dieldrin 1.2 4.0 1.60E+Ol 2.9E-02 lE-03 3E-03
Phthalate, bis(2 80.5 100.0 1. 40E-02 2.9E-02 BE-05 lE-04
ethylhexyl)
Trichloroethylene 15101.7 100000.0 1.10E-02 2.9E-02 5E-03 3E-02
-------
TABLE 2B
NONCARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTION
OF GROUND WATER
CONCENTRATION REFERENCE EXPOSURE HAZARD HAZARD
CONTAMINANTS OF (UG/l) DOSE FACTOR INDEX INDEX TOXICITY
CONCERN AVG MAX MG/KG/d 1/KG/d AVG MAX ENDOPOINT
Arsenic 9.0 10.0 1.0E-03 2.9E-02 4E-02 4E-02 Keratosis
Hyperpig-
mentation
Dieldrin 1.2 4.0 5.0E-05 2.9E-02 1E+00 4E+00 Li.~ 1esias
Phthalate, bis 80.5 100.0 2.0E-02 2.9E-02 3E-Ol 4E-Ol Liver effects
(2 ethylhexyl)
Barium 103.2 187.0 5.0E-02 2.9E-02 6E-02 lE-02 Increased BP
Copper 23.9 56.0 1. 3E+00 2.9E-02 2E-05 . . 4E-05 GI distress
Cresol,p 8.0 8.0 5.0E-02 2.92E-02 5E-03 5E-03 Reduced body
'weight
. 1, 2-Dichloro- 2922.5 7100.0 2.0E-02 2.9E-02 2E+Ol 5E+Ol Liver effects
ethylene
Lead 13.8 29.0 2.0E-Ol 2.9E-02 lE-Ol 3E-Ol CNS effects
Nickel 29.2 29.0 2.0E-02 2.9E-02 4E-02 4E-02 Reduced body
and organ wt .
Selenium 5.4 5.4 2.0E-03 2.9E-02 2E-02 2E-02 Dermatitis
Zinc 187.9 710.0 ' 2.0E-Ol 2.9E-02 4E-02 lE-OI Anemia
-------
Table 2B Cont'd
Hazard Index Sums Average Reasonable Maximum
Exposure
Liv:r Effects 2E+OO 5E+Ol
Keratosis 4E-02 4E-02
Increased BP 6E-02 lE-Ol
GI Distress 2E-05 4E-05
Reduced body weight 4E-02 4E-02
CNS Effects iE-Ol JE-Ol
Dermatitis 2E-02 2E-O.2
-------
TABLE 3: SUMMARY OF CONTAMINANTS
OF CONCERN IN GROUND .A~ER ZORE 3
CONTAMINANTS OF
CONCERN
AVERAGE MAXIMUM
CONCENTRATION DETECTION
(PPB) (PPB)
Benzo(a) anthracene
Benzo(b)flouoranthene
Phthalate,bis(2 ethylhexyl)
Trichloroethylene
Baruim
Copper
Lead
Nickel
Silenium
Zinc
3.0
7.0
41.0
20.0
49.0
21.4
25.1
16.4
11.2
31.0
3.0
'7.0
41.0
130.0
178.0
57.0
77.0
19.8
14.0
53.9
FREQUENCY OF
DETECTION
1/20
1/20
1/12
5/25
12/20
5/20
7/20
2/12
2/20
-------
TABLE 3A:
CARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTION
OF GROUND WATER Zone 1
CANCER
CONCENTRATION POTENCY EXPOSURE RISK RISK
CONTAMINANT OF (UG/1) FACTOR FACTOR ESTIMATE ESTIMATE
CONCERN AVG MAX MG/KG/d-1 1/MG/d AVG MAX
Benzo(a) anthracene 3.0 3.0 1. 20E+01 2.9E-02 1E-01 1E-01
Benzo(b)fluoranthene 7.0 7.0 1. 20E+01 2.9E-02 7E-01 7E-01
Phthalate, bis(2- 41.0 41.0 1. 40E-02 2.9E-02 4E-05 4E-05
ethylhexyl)
-------
TABLE 3B:
NONCARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTION
OF GROUND WATER
CONCENTRATION REFERENCE EXPOSURE HAZARD HAZARD
CONTAMINANTS OF (UG/1) DOSE FACTOR INDEX INDEX TOXICITY
CONCERN AVG MAX MG/KG/d l/KG/d AVG MAX ENDOPOINT
Phthalate, bis- 41.0 41.0 2.00E-02 2.9E-02 2E-02 2E-01 Liver effa:::ts
2 ethylhexyl
Barium 49.0 178.0 5.00E-02 2.9E-02 3E-02 1E-01 Increased
BP
Copper 21.4 57.0 1. 3E+00 2.9E-02 2E-05 4E-05 GI Distress
Lead 25.1 77.0 2.00E-01 2.9E-02 3E-Ol 8E-01 CNS effects
Nickel 16.4 19.8 2.00E-02 2.9E-02 2E-02 3E-02 ReduC8i body
weight
Selenium 11.2 14.0 2.00E-03 2.9E-02 5E-02 6E-02 Dermatitis
Zinc 31.0 53.9 2.00E-Ol 2.9E-02 6E-03 lE-02 Anemia
Hazard IndexSuas
Average
Reasonable Maximum
Exposure
Liver effects
Increased BP
GI distress
CNS effects
Reduced body wt.
Dermatitis
Anemia
2E-01
3E-02
2E-05
3E-01
2E-02
5E-02
6E-03
2E-Ol
lE-Ol
4E-05
8E-Ol
3E-02
6E-02
-------
TABLE 4:SUKMARY OF CONTAMINANTS OF CONCERN
IN SHALLOW SOILS (ZONE 2 LANDPILL AREA)
AVERAGE KAXIMtJH
CONTAMINANTS OF CONCENTRATION DETECTION FREQUENCY OF
CONCERN (PPB) (PPB) DETECTION
Arsenic 7262.5 -49000.0 15/20
Benzo{a) anthracene 1329.3 5000.0 15/20
Benzo{a)pyrene 1246.1 4900.0 15/20
Benzo{a)fluoranthene 2092.1 8300.0 15/20
Chrysene 1314.8 5100.0 16/20
Dibenzo{a,h) anthracene 277.7 840.0 7/20
Dieldrin 1892.0 10750.0 17/19
Phthalate,bis 173.4 240.0 5/16
(2 ethylhexyl)
Trichloroethylene 24.8 98.0 14/31
Barium 61356.7 247000.0 20/20
Copper 167748.9 213000.0 20/20
Cresol,p 1292.2 4100.0 4/20
Dichloroethylene 12.2 25.0 5/31
Lead 93904.4 457000.0 20/20
Nickel 9313.6 20000.0 14/20
Selenium 800 800 1/20
Zinc 76144.4 244000.0 20/20
-------
TABLE 4A:
CARCINOGENIC RISKS FOR CHILDREN EXPOSED TO SHALLOW SOILS
Zone 2
CANCER
CONCENTRATION POTENCY RISK RISK
CONTAMINAN'l' OF (UG/l) FACTOR ESTIMATE ESTIMATE
CONCERN AVG MAX MG/KG/d-1 AVG MAX
Arsenic 7262.5 49000.0 1. 75E+00 1E-07 1E-06
Benzo(a) anthracene 1329.3 5000.0 1. 20E+01 4E-07 3E-06
Benzo(a)pyrene 1246.1 4900.0 1. 20E+01 3E-07 3E-06
Benzo(a)fluoranthene 2092.1 8300.0 1.20E+01 6E-01 4E-06
Chyrsene 1314.8 5100.0 1. 20E+01 4E-07 3E-06
Dibenzo(a,h) 277.7 840.0 1. 20E+01 7£-08 5E-07
anthracene
Dieldrin 1892.0 10750.0 1.60E+01 7£-07 8E-06
Phthalate,bis 173.4. 240.0 1.40E-02 5E-l1 2E-10
(2,ethylhexyl)
-------
TABLE 4B:
NONCARCINOGENIC RISKS FOR CHILDREN EXPOSED TO SHALLOW
SOILS ZONE 2
CONCBNTRATION REFERENCE HAZARD
CONTAMINANTS OF (09/1) DOSE INDEX TOX.ICITY
CONCBRN AVO MAX KG/KG/d AVO MAX ENDO PO IHT
Arsenic 7262.5 49000.0 1.00E-03 5E-03 3E-02 Keratosis
Hyperpig-
mentation
Dieldrin 1892.0 10750.0 5.00E-05 5E-01 3E+00 Liver lesions
Phthalate,bis 173.4 240.0 2.00E-02 1E-04 2E-04 Liver
(2 ethylhexyl)
Barium 61356.7 247000.0 5.00E-02 6E-03 2E-02 Increased
BP
Copper 167748.9 213000.0 7.40E-05 2E-05 3E-04 GI irritation
Cresol,p 1292.2 4100.0 5.00E-02 3E-04 1E-03 Reduced body
weight
1,2-Dichloro- 12.2 25.0 2.00E-02 9E-05 2E-04 Increased
ethylene serum alka-
line phospha-
tase
Lead 93904.4 457000.0 5.70-04 5E-02 2E-01 CNS effects
Nickel 9313.6 20000.0 2.00E-02 2E-03 5E-03 Reduced body
weight
Selenium 800.0 800.0 3.00E-03 6E-04 6E-04 Dermatitis
Zinc 761:44.4 244000.0 2.00E-01 3E-03 9E-03 Anemia
Ba8ard Index Suas Average Reasonable Maximua
Bxposure
Liver Effects . 5E-01 3E+00
Reduced body weight 2E-03 6E-03
Keratosis 5E-03 3E-02
Increased BP 6E-03 2E-02
GI irritation 2E-05 3E-04
. Anemia 3E-03 9E-03
-------
TABLB 5B:
NONCARCINOGENIC RISKS FOR CHILDREN EXPOSED TO DEEP
SOILS ZONE 2
COIICBIITRA'lIOII
(OG/l)
MAX
71000.0
15.0
17000.0
41000.0
COIITAilINAllTS 01'
CONCBRa
Arsenic
Chloroform
Dieldrin
Phthalate,bis
(2 ethylhexyl)
Tetrachloroethylene 2.5
Barium 99859.9
Copper 59167.6
Cresol,p 7051.6
1,2-Dichloro- 82.5
ethylene
AVG
7093.1
8.5
1462.8
3132.2
Lead
Nickel
Selenium
Zinc
82010.8
19207.1
1752.5
108970.6
...ar4 In4ez Sua.
Liver Effects
Reduced Body wt.
lCeratosis
Increased BP
GI Distress
CNS Effects
Dermatitis
Anemia
3.0
964000.0
452000.0
100000.0
980.0
138000.0
252000.0
2700.0
190000.0
Average
4E-01
7E-03
5E-03
1E-02
8E-06
4E-02
1E-03
4E-03
RBI'ERENCE HAZARD
DOSB INDEX '!OXICITY
MG/KG/4 AVG m BNDOPOINT
1.00E-03 5E-03 5E-02 Keratosis
1.00E-02 6E-05 1E-04 Liver lesions
5.00E-05. 4E-01 5E+00 Liver lesions
2.00E-02 2E-03 3E-02 Liver effects
1.00E-02 2E-05 2E-05 Liver effects
5.00E-02 1E-02 1E-01 Increased BP
7.40E-05 8E-06 6E-05 GI distress
5.00E-02 2E-03 3E-02 Reduced body wt.
2.00E-02 6E-04 7E-03 Increased serum
alkaline phos-
pbatase
5.70E-04 4E-02 7E-01 CNS effects
2.00E-02 5E-03 6E-02 Reduced body wt.
3.00E-03 1E-0'3 2E-03 Dermatitis
2.00E-01 4E-03 7E-02 Anemia
Reasonable Maziaua Exposure
5E+00
9E-02
5E-02
1E-01
6E-05
7E-01
2E-03
-------
TABU' : SIIHMARY 01' CONTAMINANTS 01' CONCERN
IN SHALLOW SOIL (ZONE 3 Other On site Soil AREA)
CONTAMINANTS OF
CONCERN
Arsenic
Benzo(a) anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Chloroform
Chrysene
Dibenzo(a,h) anthracene
Phthalate,bis(2 ethyl-
hexy 1 )
Tetrachloroethylene
Trichloroethylene
Barium
Copper
Lead
Nickel
Selenium
Zinc
AVERAGE
CONCENTRATION
(PPB)
4312.5
850.2
715.0
1074.8
27
659.9
219.5
434.8
MAXIMUM
DBTBCTION
(PPB)
~16000.0
4500.0
2900.0
7500.0
27
3200.0
340.0
1600.0
1.3
11.6
245333.3
24181. 3
102062.5
9687.5
3123.0
32823.5
1.3
32. O.
70000.0
255000.0
2340000.0
1600.0
3700.0
11600.0
I'REQUENCY OF
DETECTION
16/21
7/22
7/22
9/22
1/37
10/22
2/22
7/20
1/39
9/40
20/22
21/21
21/21
6/21
3/22
-------
TABLE 5:SUMMARY OF CONTAMINANTS OF CONCERN
IN DEEP SOIL (ZONE 2 LANDFILL AREA)
AVERAGE MAX I MtJK
CONTAMINANTS OF CONCENTRATION DETECTION FREQUENCY OF
CONCERN (PPB) (PPB) DETECTION
Arsenic 7093.1 71000.0 38/39
Benzo(a) anthracene 1005.9 3200.0 19/38
Benzo(b)fluoranthene 1384.3 8300.0 18/39
Chloroform 8.5 15.0 2/38
chrysene 1124.9 34.00.0 21/38
Dibenzo(a,h) anthracene 247.5 1100.0 11/39
Dieldrin 1462.8 17000.0 17/33
Phthlate bis 3132.2 41000.0 16/39
(2 ethylhexyl)
Tetrachloroethylene 2.5 J 2/49
Trichloroethylene 1207.7 51000.0 24/50
Barium 99859.9 964000.0 38/39
Copper 59167.6 452000.0 39/39
Cresol,p 7051.6 100000.0 10/39
Dichloroethy1ene 1,2- 82.5 980.0 1i/50
Lead 82010.8 1380000.0 39/39
Nickel 19207.1 252000.0 31/39
Selenium 1752.5 2700.0 3/39
-------
TABLE 5A:
CARCINOGENIC RISKS FOR CHILDREN EXPOSED TO DEEP SOILS
ZONE 2
CANCER
CONCENTRATION POTENCY RISK RISK
CON'l'AMINANT OF (UG/1) FACTOR ESTIMATE ESTIMATE
CONCERN AVG MAX MG/KG/d-1 AVG MAX
Arsenic 7093.1 71000.0 1.75E+00 1E-07 2E-06
Benzo(a) anthracene 1005.9 3200.0 1. 20E+01 3E-07 2E-06
Benzo(a)pyrene 1180.7 4500.0 1. 20E+01 3E-07 2E-06
Benzo(b)fluoranthene 1384.3 8300.0 1. 20E+01 4E-07 4E-06
Chloroform 8.5 15.0 6.10E-03 7E-12 2E-11
Dibenzo(a,h) anthracene 247.5 1100.0 1. 20E+01 7E-08 6E-07
Dieldrin 1462.8 17000.0 1. 60E+01 5E-07 1E-05
Phthalate,bis 3132.2 41000.0 1. 40E-02 1E-09 3E-08
(2 ethylhexyl)
Tetrachlorethylene 2.5 3.0 5.1E-02 2E-11 4E-11
-------
TABLE 6A:
CARCINOGENIC RISKS FOR CHILDREN EXPOSED TO SHALLOW SOILS
ZONE 3
CANCER
CONCENTRATION POTENCY RISK RISK
CONT~..MINANT OP (UG/l) PACIDR ESTIMATE ESTIMATE
CONCERN AVG MAX MG/KG/d-1 AVG MAX
Arsenic 4312.5 16000.0 1.75E+00 6E-08 5E-07
Benzo(a) anthracene 850.2 450.0 1. 20E+01 2E-07 2E-06
Benzo(a)pyrene 715.0 2900.0 1. 20E+01 2E-07 2E-06
Benzc(b)fluoranthene 1074.8 7500.0 1. 20E+01 2E-07 4E-06
Chloroform 27.0 27.0 6.10E-03 2E-l1 4E-11
Chrysene 659.9 3200.0 1. 20E+Ol 2E-07 2E-06
Dibenzo(a,h) anthracene 219.5 340.0 1.20E+01 6E-08 2E-07
Phthalate,bis (2 ethyl- 434.8 1600.0 1.40E-02 1E-10 1E-09
hexyl)
Tetrachlorethylene 1.3 1.3 5.10E-02 8E-12 2E-11
-------
TABLE 6B:
NONCARCINOGBNIC RISKS FOR CHILDREN EXPOSED TO SHALLOW
SOILS ZONE 3
CONCBNTRATION REPERENCE . HAZARD
CONTAMINANTS OF (UG/1) DOSE INDEX TOXICITY
CONCERN AVa MAX MG/ltG/4 AVG MAX BNDOPOIN'l'
Arsenic 4312.5 16000.0 1.00E-03 3E-03 1E-02 Keratosis
Chloroform 27.0 27.0 1.00E-02 2E-04 2E-04 Liver lesions
Phthalate,bis 434.8 1600.0 2.00E-02 3E-04 1E-03 Liver effects
(ethylhexyl)
Tetrachloro- 1.3 1.3 1.00E-02 1E-05 1E-05 Liver effects
ethylene
Barium 24533.3 70000.0 5.00E-02 2E-03 7E-03 Increased BP
Copper 24181.3 255000.0 7.40E-05 3E-06 3E-05 GI Distress
Lead 102062.5 2340000.0 5.70-04 5E-02 1E+00 CNS effects
Nickel 9687.5 16000.0 2.00E-02 2E-03 4E-03 Reduced body wt.
Selenium 3125.0 3700.0 3.00E-03 2E-03 3E-03 Dermatitis
Zinc 32823.5 116000.0 2.00E-01 1E-03 4E-03 Anemia
Basar4 In4ex sua. AveraC)e Reasonable Maxiaua Exposure '.
Liver Effects 5E-04 1E-03
Keratosis 3E-03 1E-02
Increased BP 2E-03 7E-03
GI Distress 3E-06 3E-05
CNS Effects 5E-02 1E+00
Reduced body wt. 2E-03 4E-03
Dermatitis 2E-03 3E-03
-------
TABLE 7:SOMMARY OF CONTAMINANTS OF CONCERN
IN SEDIMENT (ZONE 6 DOWNSTREAM)
AVERAGE MAXIMUM
CONTAMINANTS OF CONCENTRATION DETECTION FREQUENCY OF
CONCERN (PPB) (PPB) DETECTION
Arsenic 1865.7 6200.0 8/10
Benzo(a) anthracene 2130.0 10070 13/16
Benzo(a)pyrene 2071.0 9160.0 12/16
Benzo(b)fluoranthene 1422.2 6500.0 10/16
Chloroform 110.5 202.0 2/15
Chrysene 2193.2 7860.0 14/16
Dibenzo(a,h) anthracene 505.0 1470.0 4/16
Dichloroethylene 1,1- 740.0 740.0 1/17
Dieldrin 425.7 1700.0 5/15
Trichloroethylene 129.1 920.0 9/17
vinyl Chloride 170.5 290.0 2/17
Barium 33810.0 174000.0 12/13
Copper 27768.8 93000.0 10/10
Dichloroethylenes 1,~ 114.2 230.0 7/17
Lead 27862.5 56000.0 10/10
Nickel 6225.0 9300.0 9/10
-------
TABLE 7A:
CARCINOGENIC RISKS FOR ADULTS EXPOSED TO SIDEMEHTS VIA RISK
, (ZONE 6) DOWNSTREAM OF SITE
CANCER
CONCBNTRATION POTENCY RISK RISK
COH'l'AMIHAHT OF (UO/1) FACTOR ESTIMATE ESTIMATE
CONCERN AVO MAX MG/KG/d-1 AVG MAX
Benzo(a) anthracene 2130.0 10070.0 1.20E+01 2E-OJ 9E-03
Benzo(a)pyrene 2071.0 9160.0 1. 20E+Ol 2E-OJ 8E-OJ
Benzo(b)fluoranthene 1422.2 6500.0 1. 20E+Ol lE-03 6E-03
Chloroform 110.5 202.0 6.10E-OJ 5E-08 9E-08
Chrysene 2193.2 7860.0 1.20E+Ol 2E-OJ 7E-OJ
Dibenzo(a,h) anthracene 505.0 1410.0 1. 20E+Ol 4E-04 iE-OJ
Dichloroethylene - 1,1 140.0 140.0 6.00E-Ol JE-05 JE-05
Dieldrin 425.1 1100.0 1.60E+Ol 5E-04 2E-OJ..
Trichloroethylene 129.1 920.0 1.10E-02 lE-01 1E-01
-------
TABLE 7B:
NONCARCINOGENIC RISKS FOR ADULTS EXPOSED TO FISH VIA
SEDIMENTS
COIfCBNTRATION REFERENCE HAZARD
CONTAMINANTS or (UO/l) DOSE INDEX TOXICITY
CONCERN AVO . MAX MG/KG/d AVG MAX ENDOPOINT
Chloroform 110.5 202.0 1.00E-02 8E-04 1E-OJ Liver Lesions
Dichloro- 740.0 740.0 9.00E-OJ 6E-OJ 6E-OJ Liver Lesions
ethylene,l,l
Dieldrin 425.7 1700.0 5.00E-05 6E-01. 2E+00 Liver Lesions
!>ichloro- 114.2 2JO.0 2.00E-02 8E-04 2E-OJ Lung & Liver
ethylene 1,2
Hazard Indez Sua.
Average
Reasonable Maximum
Exposure
Liver Effects
6E-Ol
-------
TABLE 8: SUMMARY OF CONTAMINANTS OF CONCERN
IN SEDIMENT (ZONE 8 UPSTREAM OF SITE)
AVERAGE MAXIMUM
CONTAMINANTS OF . CONCENTRATION DETECTION FREQUENCY OF
CONCERN (PPB) (PPB) DETECTION
.
Arsenic 910 910 1/5
Benzo(a) anthracene 898.3 1000.0 4/5
Benzo(a)pyrene 1000.0 1000.0 3/5
Benzo(b)fluoranthene 1100.0 1400.0 3/5
Chrysene 1225.0 1400.0 3/5
Pthalate,bis(2 ethyl 510.0 600.0 2/4
hexyl
Barium 20400.0 21300.0 3/5
Copper 32075.0 54000.0 5/5
Lead 54275.0 79000.0 5/5
Nickel 7450.0 7700.0 3/5
Selenium 740.0 800.0 2/5
-------
'1'ABLE 8A:
CARCINOGENIC RISKS POR ADUL'1'S EXPOSED '1'0 SEDIMEN'l'S VI~ 'ISR
. (ZONE 8) UPSTREAM OF 81'1'E
CANCER
COIICBH'l'RA'1' ION POTENCY RISK RISK
COH'l'AIIINAH'l' OP (OG/l) PACTOR ESTIMA'1'B ESTIMATE
CONCBRN AVG MAX MG/KG/d-l .AVG MAX
Benzo(a) anthracene 898.3 1000.0 1. 20E+Ol 8E-04 9E-04
Benzo(a)pyrene 1000.0 1000.0 1.20E+Ol 9E-04 9E-04
Benzo(b)fluoranthene 1100.0 1400.0 1. 20E+Ol 9E-04 lE-03
Chrysene 1225.0 1400.0 1. 20E+Ol iE-OJ iE-OJ
phthalate-bis(2 ethyl- 510.0 600.0 1.40E-02 5E-01 6E-01
hexyl)
-------
TABLE 8B
NONCARCINOGENIC RISKS FOR ADULTS EXPOSED TO SEDIMENTS
VIA FISH ZONE 8
CONCBlft'RATION REFERENCE HAZARD
. ::ON'l'lUIIHAHTS OP (UG/1) DOSE INDEX TOXICITY
::ONCERIf AVO MAX MG/KG/d AVG MAX ENDOPOINT
Phthalate - bis 510.0 600.0 2.00E-02 2E-03 2E-03 Liver effects
(2 ethylhexyl)
Hazard Index Suaa
Average
Reasonable Maximum
Exposure
Liver effects
2E-03
-------
TABLE 9:
SUMMARY OF POTENTIAL CHEMICAL SPECIFIC ARARS WITH RESPECT TO STAMINA MillS $ITE
REQUIREMENTS
....z..:z===.::....=::-:....:.........................=.=:z.....ac.:=.=.....c.......~..==.......=.:.2..........a[[[
APPLICATION TO THE RI/FS
STATUS
REQUIREMENT SYSOPSIS
.....o~=..===z====..:.==..............................-=====..==.8=8................====...............=_....R[[[
FEDERAL REQUIREMENTS
.........---[[[~....-[[[
RCRA M!xlmum Concentration limits
40 CFR 264 Subpart F
Safe Drinking Water Act
Maximum Contaminant levell
40 CFR 141.11 . 141.16
(MCLI)
Safe Drinking Water Act
Maximum Contaminant levell Goals
(MClGs) '0 CFR 141.50 . 141.51
Clean Water Act
F~eral Water Quality Criteria
51 F~eral Register 43665
AppilCible
Relevant and
Appropriate
MCls have been established for 14 toxic c~s
under RCRA groundwater protection standards. A
cGq)lIance monitoring program Is Includ~ for
RCRA facilities.
MCll have been set for toxic compounds IS
enforceable standards for public drinking ~ater
systems. SMCls are unenforceable goal.
regulating the asthetlc quality of drinking water.
Relevant and MClGs are unenforceable goall under the SDWA.
Appropriate
Relevant and
Appropriate
Effluent limitations 8USt ..et BAT. Water Quality
Criteria for ambient ~ater quality are provld~
for toxic chemicals.
Pertains to identified hazardous .aterials
that are treated, stored, or disposed on-site
Aquifer below the Stamina MIIII Iita II a lource of
drinking wlter. Some contamlnantl In plume belo~ alte
are above MCls and "SMCll.
Aquifer below the Stemlna MIIII alte II a lource of
drinking "Iter. Some cont_lnante In plume below alte.
ar. above HClGI.
Current dllchargel from lite ..y caUie degradation of
Branch River In eXCI.I of AWOCI. Dllchargel to the
8ranch River aSloclated ~Ith groundwater remediation or
other actlvltlel would have AWOCs as potential goal.
STATE REQUIREMENTS
..........-.-.--........-.-..................... [[[-...
-------
TABLE 9
SUMMARY OF POTENTIAL CHEMICAL SPECIFIC ARARS WITH RESPECT TO STAMINA MillS SITE
REQUI.REMENTS
8C.8:..====22==8.....==..............................:a.=~a..2.==.....=....22......C.=.=....2R..=C.=........a.a[[[8
APPLICATION TO THE RifFS
STA TUS
REQUIREMENT SYSOPSIS
a...~.=.==:=========.===..........................=.=.8=.====...=-=====...8===.==..======_._=....=-=-=...==8[[[
1.1. Water Quality Regulations for
Water Pollution Control
I. Gl 46-12, 42-17.1, 42-35
leguiatlons for the R.I. Pollutant
Discharge Elimination System
(RIPDES) R.I.G.l. 46-12, 42-17, 42-35
Draft Groundwater Cla.slflcatlon
unde. the R.I. Groundwater
prot~ctlon ACT R.I.G.l.46-13.1
1.1. Air Pollution Control Regulations
Regulations No. 22, Air Toxlcs
RI Gl 23-23, 42-35
Applicable
Applicable
To Be
Cons I dered
Applicable
Provides water classification for surface waters
In R.I. Sets effluent limitations and RIPDES
Permit requirements for discharges to the
waters.
Sets forth the requirements and applicability
for the RIPOES P~rmlt for discharge to State
Waters.
Classification for R... groundwater. Four
classea of water are designated according .to
suitability for use as a drinking water source.
Stationary air emission sources generating listed
toxic substances shall not exceed given
concentrations of toxlcs at or beyond property
Branch River classified as Ii present condition C.
Effluents to Branch River from site must meet
requirements for class B.
Discharges associated with groundwater treatment or
other remedial activities to off-site outfalls to Branch
River would require RIPDES permit, on-site outfall would
be required to IIIHt .lbst.ntlve requirement. but would
not need a peml t.
The Stamina "Ill. tlte groundw.ter I. prellmlnerlly
designated .. GAA, -... .ultable for drinking water use
without treatment-, Stand.rd. for Cla.s GAA are federal
-------
TABLE 10
SUMMARY OF POTENTIAL lOCATION SPECIFIC ARARS WITH RESPECT TO STAHINA HillS SITE
REQUIREMENTS
c:======a:====S:S2:..za.....c...a.az............a......~........&..2...=..............=......=.......=..=.....a[[[
APPLICATION TO THE RI/FS
STATUS
REQUIREMENT SYSOPSIS
....ac===========8.==:==.................................=-==_......8................====...==.......=..=[[[
FEDERAL REQUIREMENTS
..........-.....-.....-.....-..............................................---....................................-.-.............................................-.-
RCRA location Requirements
'0 CFR 264.18(c)
National HIstoric Preservation
Act of 1966. 16 U.S.C. 470 et
seq. 36 CFR Part 800
Endangtred Sptctes Act
16 U.S.C. 1531 et seq.
50 CFR Part 1,02
Coastll Zone Management Act
16 U.S.C 11,51 et seq.
15 CFR Part 930
FIsh Ind Wildlife CoordinatIon
Act 16 U.S.C. 661 et seq.
Clean W.ter Act, Section 40'
Pert8tntng to Wet lends
J' II. S (. 1;S1 rt seq.
Relevant and
Approprllte
Not AUR
Not ARAR
Not ARAR
Applicable
Relevlnt and
ApproprIate
Sets forth minimum requirements for
design, construction, and operat Ion of a
facility where treatment, .torage, or
disposal of hazardous Maste Mill be
located Mlthln . 100-year floodplain.
Rlqulres that the action not effect or cause hlrm
to registered Historic PIeces or Historic
lardn8rks.
Action must avoid Jeopardizing the continued
existence of listed endangered or threatened
sptcles or modification of their habitat.
Activities affecting land or water uses In a
coastal zone required to certIfy noninterference
Mlth coastal zone management.
Requires actions to protect fish and wildlIfe
from actIons modifying Itreaml or areal affecting
streams.
Prohibits dIscharge of dredged or fill meterlal
Into navigable waterl wIthout a permit.
Treatment, dllposal, and Itorage of hazardous meterlall
mey takl plecl 4Irlng remediation of tha .lte. Some
waste. ara located Mlthln tha 100-Ylar floodplain.
Mone of the alternative. would bave an
adver.e effect on the Forestdale Historic
District . .
No endangered apecle. or habltata arl In Ixl.tanee
on-sltl.
Site not located on or near coastal zone.
on-.lte remediation activitIes mey Include modifications
to the Iranch River adjacent to the site.
-------
TABLE 10
SUMMARY tF POTENTIAL LOCATION SPECIFIC ARARS WITH RESPECT TO STAMINA MILLS SITE
.8===2:................:.......2.......................a=:......:-::=...................................:-[[[
REQUIREMENTS
STATU.
REQUIREMENT SYSOPSIS
APPLICATION TO tHE RIfFS
...........:..:_==2:..==.......=................."..............=...........................&=...............a.a[[[a
portion RUst be met.
E.ecutlve Order 11990
Wetlar~s Protection Polley
To be
considered
Sets forth policy for the' protection of wetlands.
To the extent that the Executive Order provides
additional guidance to state requirements for
wetland activities. they will be considered
E.ecutlve Order '1988
Floodplain Management Polley
To be
considered
Sets forth polIcy for the protection of
floodplains.
A portion of the lite II located In e '00 year
floodplain: however, Executive Order lets forth
polley and II not enforceable.
....a.-.............-.-........-.-.............................................-[[[
STATE REQUIREMENTS
'.
........--[[[
-------
TABIE 11
SUMMARY OF POTENTIAL ACTION SPECIFIC ARARS WITH RESPECT TO STAMINA MILLS SITE
REOUIREMENTS
.....=.2:.=~2..=...........~.....=..=.................8=......=....:...=..............=...........=8=[[[
APPLICATION TO THE RI/FS
STATUS
REQUIREMENT SYSOPSIS
.......CS====2:_:...............................2.......====......................a....:-=-.-[[[0.......
FEDERAL ENVIRONMENTAL ARARS
[[[-[[[
RCRA !dentlflcatlon of
Hlzardous Waste 40 CfR 261
RCRA Identification of
Hazardous Waste 40 CFR 261.]](d)
RCRA Flclllty Standards,
Preparedness Ind Prevention,
Contingency Plan Ind Emergency
Procedures 40.CfR.264,
Subplrtl I, C, D
RCRA Manifest System,
Itecordlceeplng, and Reporting
40 CFR 264 Subpart E
RCRA Croundwater Monitoring
Requirements 40 CfR Subpart f
AppLicable
Applluble
Appllclble
AppLiubl.
Appllceble
Crlterll for Identifying those solid Nastes
lubJect to regulation al hlzardous substances
under RCRA.
A meterlll Is hazlrdoul Nalte If It Is I residue
or contemlneted soil, Niter or other debrla
resulting from the cleanup of a spill Into or on
Iny Iind or wlter of any conmerclal chemlcel
product or Manufacturing chemical Intermediate
having the generic name lilted In the section.
Estlbll.hes minimum Itlndlrds for the
Icceptabll Manlgement of RCRA hazlrdous wastes.
Includel preperednesl Ind prevention measures,
general flcility Itlndards, and contingency and
emergency procedures.
Estlbilihes the rulel Ind recordkeeplng
requlrementl for off-lite transportltlon of RCRA
hazardous materials for treltment and/or disposal.
Establishes minimum requirements for groundNater
monitoring and protection standards for RCRA
facilities.
Suspected hazardous wastel on tha Stamlnl MIIII lite.
Ihould be Identified IS RCRA hlzlrdoul substances or
non-hazlrdoul lubstlncel prior to remedlll activities-
Jurladlctlon II under R.I. RCRA program.
Solla Ind ,roundwater.on the Stemln Mills lite Ira I
result of I Iplll of Trichloroethane, I lilted chemicil
In tha lectlon. Jurlldlctlon II under R.I. RCRA program.
Treatment, Itorlgl, Ind/or dllpoall of RCRA hlzlrdous
waltel ..y occur on thl St.-Ini MIIII lit. during
remedlltlon. Jurlldlctlon II under R.I. RCRA program.
-------
TABLE 11
SUMMARY OF POTENTIAL ACTION SPECIFIC ARARS WITH RESPECT TO STAMINA MILLS SITE
REQUIREMENTS
....:.....S.8.8.......=.........Z8......................a..........ma[[[
APPLICATION TO TME RI/FS
STATUS
REQUIREMENT SYSOPSIS
RCRA Closure
Requl rements
Subpart G
and Post Closure
100 CFR 264
.........::...:......-.....................................=...........................a[[[
RCRA ~torage Requirements
100 CF' 264 Subparts I, J, Ind L
RCRA Landfill Requlrementl
100 CFR 264 Subpart N
RCRA Treltment Requlrementl
100 CFR 264 Subpartl 0 end X
RCRA land Dlsposel Restrictions
40 CFR 268
Clean Water Act Discharge
limitations' NPOES Permit
100 CfR 122, 125, 129, 136
Applicable
Applicable
Releyent Ind
Appropriate
Appllceble
Establishes minimum requirements for closure and
post-closure care of I RCRA facility engaging In
treatment, Itorege, end/or disposal of hazardous
wlstes. Closure requirements Include In-place
wastel and remedlated Ireas.
Establishes minimum requlrementl for the storage
of hazardous wastes.
Eltabllshes minimum requirements for the design
Ind conltructlon, operltlon Ind maintenance,
monitoring Ind Inspection, closure and post
closure care for I hlzardous waste landfill.
Establishes minimum requlrementl for the permit
Ipprovll, operation, end Itendards for
Inclnerltlon and other treatment for hazardous
wastes.
Releyent and Certain classes of waste are restricted from land
Approprllte disposal without Icceptable treatment.
Applicable
Prohibits unpermitted discharge of any pollutant
or comblntalon of pollutlntl to waters of the
U.S. from any point lource. Standards end limit-
ations are established for these discharges.
At the conclusion of a remedlll action Involving the
treatment, Itorlge, dlsposIl, removal of hazardous
wastes, closur. procedures Ind post-closure care would
be required. Jurisdiction II under R.I. program.
RCRA hazardoua wast. mey be Itored on-site prior to
off-site dlspos.1 or on-lit. treatment. Jurisdiction
II under R.I. RCRA progr8m.
RCRA hszardous wSlt. mey be Iindfilled on-lite.
Jurisdiction II under R.I. RCRA progr8m.
..
Remedlltlon NY Include Inclnerltlon Ind/or treatment of
hazardous waltel.
Removil of 10111 Ind other lolvent- containing materials
from the StaMina MIIII lit. for llnd disposal may
-------
TABLE 11
SUMMARY OF POTENTIAL ACTION SPECIFIC ARARS WITH RESPECT TO STAMINA "ILLS SITE
REQUIREMENTS
.....====8.:_:2.................8:.......:.......:....................s.s...a[[[
APPLICATION to tHE RifFS
STAtuS
REQUIREMENT SYSOPSIS
........2[[[=...............................a:..:...8:_[[[
Clean Water Act Wetlands
Regulltlons, Part 404
40 cn 230
t
. Executive Or~r 11990
Wetlands Protection Policy
ExecutIve Order 11988
Floodplain Management Policy
Sife Drinking Water Act
Underground Injection Control
Program 40 CFR 144
Clean Air Act New Source
Performance Standards, Section
111 40 CFR 60.
Nltlonal Emission Standards for
Huerdous Air Pollutants
40 CFA 161
Department of Transportation rules
for the transport of hallrdous
sub$tances 49 CFR
Relevant and
Appropriate
Not ARAR
'0 Ie
Cons ldered
Appllclble
AppllClble
Applicable
Appllclble
Controls the discharge of dredged or fill
materials Into weterl of the U.S. such that the
physical snd biological Integrity Is maintained.
Eltlbllshes guidelInes for Identification and
protection of wetlands.
Eltlblilhes guidelines for activIties conducted
within a 100'year floodpilin.
Regulltel the use of five clesses of underground
Injection weIll for the purpose of disposal of
halardous lubstlncel.
Eltabllshes standards of performance for new air
emission lources.
Establishes emissions Itlnderds, monitorIng Ind
testIng requlrementl, Ind reportIng requirements
for 8 pollutlnts In aIr emlaslons.
Regulltes the labelling, packaging, placarding,
Ind trlnsportatlon of lolld and halardous westes
off-II te.
Remedial Ictlonl mey occur Ilong the Ir.nch River.
No wetllnds ~flned by these guidelines are present on
the Stamlnl "1111 lite.
A 1..11 portion of thl lite II 100Ited within I 100-year
floodplaIn.
Reaedietion of the staaina Mills site .ay include
the subsurface discharge of treated groundwater
llIIIIdlll Ictlons lilY Include technologies that have II r
-------
TABLE 11
SUMMARY OF POTENTIAL ACTION SPECIFIC ARARS WITH RESPECT TO STAMINA MILLS SITE
REQUIREMENTS
..........==....................:8==.................-.............===8=.............:=............8===[[[
APPLICATION TO THE RIIFS
STATUS
REQUIREMENT SYSOPSIS
...............z..................=...................a.a[[[
OccupatIonal Safety and Health
Standards, 29 CFR 1910.120 for
Hazardous Waste OperatIons and
Emergengy Responses, Part 1926 for
General Safety and Health Standards,
and ReportIng Requlrementl
ApplIcable
Sets lImits on exposure to workers on hazardous All activities takIng place on the StamIna Mills site
site or emergency responses, sets forth minimum Including remediatIon, constructIon, and monitorIng
health and lafety requlrementl such as personal are subject to OSHA health and Safety regulatIons.
protection and traInIng, and reportIng requirements.
STATE OF RHODE ISLAND ENVIRONMENTAL ARARS
.........-[[[-.-..-.
.................-...........-.............-[[[-[[[-
R.I. .ules and Regulations for
",zardOus Waste Generation,
TransportatIon, Storage and
Disposal R.I.G.L. 23-19-1 - 10
R.I. Rules and Regulations
for Solid Waste Management
Facilities R.I.G.L.23-18.9,
23-19,1,2'17.1
R.I. Underground Injection
Control Program R.I.G.L.
42-17.1, 46-12
-R.I. Water QualIty Regulatfons
for Water Pollution control
R.I.G.L. 1,6-12, 1,2-17.1, 42-35
Appl fcabl.
Applicable
Applfcabl.
Appl fcable
EstablIshes mInImum requfrements for the
generatIon, transportatIon, atorage, treatment,
and dIsposal of hazardous vastes.
Establlshel mInimum requIrements for the
operation of solId wast. management facilIties
and the specIfIcations for design and
constructIon of new facIlItIes.
EstablIshes the minImum requIrements for the
locatIon, desIgn, constructIon, maIntenance and
operatIon of InjectIon vella and other lubsurface
disposal systems to prevent groundwater
ClassIfIes surface waters In R.I., and lImIts
discharges to such waters.
On 01/31/1986 R.I. was granted authorIty to admlnllter
-------
TABLE 11
SUMMARY OF POTENTIAL ACTION SPECIFIC ARARS WITH RESPECT TO STAMINA MillS SITE
REQUIREMENTS
STATUS
........a==...............................................z...c..c:.c............~.......=..................a....a.................................:..............8
APPLICATION TO THE RllfS
REQUIREMENT SYSOPSIS
R.I. Pollutlnt Dlschlrge
EI.lnltlon system (RIPDES)
R.I.G.L. 46-12, 42-17.1, 42-35
Applicable
ac[[[a[[[
Remediation of the Stamina Milil lite may Include I
surflce ~Iter dlschlrge.
R.I. Pretreltment Regulatlonl
R.I.G.L. 46-12,42'17.1, 42-45
Applicable
~.I. Air Pollution Control
ilegulltlons:
No.1 VIsible Emissions
Applicable
No.5 fugitive Dust
AppllClble
No.7 Emission of Air
Contaminants Detrimental to
Person or Property
AppllClble
N~.9 Approvil to Construct,
Instill, Modify, or Oper8te
AppllClble
Estlbllshes the requirements for the Ipprovil of
a RIPDES surflce wlter dlschlrge permit.
Controll the pollutlnts IIhlch plSI through or'
Interfere with treatment processes In POTY or
which lilY contlllllinate lellige .ludge.
No perlon Ihall emit Into the atomosphere from
any lource any air contllllnint for a period or
periods aggregating 80re than 3 minutes In Iny 1
hour which Is grelter thin or equll to 201 opacity.
Re8sonable preclutlons shall be tlken to prevent
particulate matter from becoming Ilrborne ~rlng
materials hlndllng, storlge, building construction,
demoll tt on.
No perlon Ihlll emit any contemlnant which,
either alone, or In combination with other
contaminants, by reason of thel r concentrlt Ion
and durltlon, may be InJurous to hunen, pllnt, or
animal life, or CluSt dlnege to property or which
unrellonably Interferes with the enjoyment of
life Ind property.
Eltl~llshes the minimum crlterll for Ind
procedure In obt81nlng Ipprovei to Instill,
modify, or operlte 8n emllslon source.
Remedlltlon of the St_lna Mills sltt IIIIY Include
dischlrge to the Woonsocket POTY.
Remedlltlon of tht Stamina Milil site may Include Ilr
emlulons.
. .
Remediation of the St_lna Mills site lilY Include
materials hlndllng, construction, Ind demolition.
Air emissions lilY be produced ~rlng the remedlltlon of
-------
TABLE 11
SUMMARY OF POTENTIAL ACTION SPECIFIC ARARS WITH RESPECT TO STAMINA MillS SITE
REQUIREMENTS
~=:=~============:======2=Z=&==&za==.............S8SZZ.==,.=c::a~..:==S&c...........cca.=.:......=[[[
APPLICATION TO THE RIIFS
STATUS
REQUIREMENT SYSOPSIS
....~...====s=.==.==.=.....s..........................8.............:C8:..........-.....8=.......==..........a[[[
No.14 Record Keeping Ind
Reporting
No.15 Control of Orglnlc
Solvent Emissions
No.16 Operltlon of Air Pollution
Control Systems
No.17 Odors
~o.22 Air To.les
Division 0' Air end Hlzlrdous
Meterlels polley on Permitting
Air Strippers, April 20, 1989
Appllclble
Not
AUR
Appllceble
Appllclble
Appllclble
To be
considered
The owner or operltor 0' Inv source of Ilr
contemlnlnts shill provide operltlonll dati
Ilr ~Isslon source.
Remedlll Ictlons It the Stemlne Mills site mey Include
on the Ilr emissions Ind pollution control equipment.
Regulltes ~Isslons from Instlilitions using
orglnlc solvents or VOCs.
Requires thlt Iny Ilr pollution control system
shall be operlted Iccordlng to the design
lpeclflcltlons whenever the source on which It Is
Installed Is In operltlon or Is emitting air
contamlnlnts.
Restricts emissions of Iny Ilr contaminant or
combination of contaminants which crelte In
objectlonlble odor beyond the property line.
Air emission limits Ire estlbllshed for
stltlonary source using or generating I
to.lc substance.
Iny
listed
Establishes submittal policy prior to the
Instlilition of an Ilr stripper.
The Stamina Milli site would not be cltegorlzed IS In
Instlilition using lolventl or VOCs.
Air pollution control lyatems NY be used ~rlng
remedlltlon of the Stamina Milil lite.
Remedlll Ictlvltlel on the Stamina Mill lite mey cluse I
rei else of obJeetloneble odorl, luch II dlsturbence of
the Iindfill Irel.
-------
TABLE 12
ATTAINftENT OF POTENilAL CHE~ICAL SPECIFIC ~RA~S WITH RESPECT TO ALTE~N~TlvES
[[[=============--========================================================
REGUiREIlENiS
Y = WILL 8E ATTAINED
N = WILL NOT BE ATTAINED
ON-SITE 6ROUNDWATER : TCE SPILL AREA: LANDFILL AREA
RE~EDIAL UNIT: REIIEDIAL UNIT: REIIEDIAL UNIT
: 611-1 6W-2 6W-4 6W-5: TSA-l TSA~3 TSA-4 : LA-l LA-3 LA-5
OVERALL SITE
REIIEDIAL UNIT
: 05-3 OS-4 05-5
======================================:===--====================:=======--===========:===================:===================:
FEDERAL REGUIREIIENTS
"
,
--------------------------------------:------------------------:-------------------:-------------------:-------------------:
RCRA lIalilul Conc!ntration Lilits
40 CFR 264 Subpart F
. ,
I
Y Y
Y Y Y N ~ Y N
Saf! Drin~ing Wat!r Act
lIalilul Cont.linant l!v!ls
40 CFR 141.1J - 141.16
(IICls)
Safe Drinking Wat!r Act
lIaxilul Conta.inant L!v!1s 60a1s
(ftCL6s) 40 eFR 141.50 - 141.51
Y
y
Y
N
y
Y
N
Clean lIater Act
Federal Water Quality Criteria
51 Federal Register 436t5
y
y
Y
y
Y
: y
.y
Ii
----------~---------------------------:------------------------:--------~----------:-------------------:-------------------:
STATE F.EaUIRE~EliTS
--------------------------------------:------------------------:-------------------:-------------------:-------------------:
R.i. Rules and Regulations Pertaini~q :
to Public DrinKin~ Nater
R4b-13-DWS, Amended January, 1983
y
y
y
N
y
y
~
R.I. Water Duality Regulations for Y y Y
Water Pcllution Control
Rl 6L 46-12, 42-17.1, 42-35
Regulations for the R.I. Pollutant
Discharge Eli.ination Systel
(RIPDES) R.i.5.l. 40-12, 42-17, 42-3~ :
Draft 6roundwater Classification y y Y N
under the R.I. Sroundwater
protection 'ACi R. I.6.L. 46-13.1
R.I. Air Pollution Co~trol Regulations: y
Regulations N~. 22. Air TOI1CS
~i 6~ 23-23, 42-35
y
y
y
Ii
'(
y
Ii
Y
y
y
y
y
y
y
y
v
y
v
i
y
y
y
y
y
------------------------------------------------------------------------------------------------------------------------.---
-------
TABLE 13
ATTAIN~ENi OF POTENTIAL LOCATION SFECIFiC ARA~S WiiH RESPECT TO RE~~DIAL U~ijS
==============================================::============:=====--=======================================================:
REQUIREIIENTS
Y = WILL BE ATTAINED
N = WILL NOT BE ATTAINED
ON-SITE 6ROUNDWATER : TCE SPILL AREA: LANuFILL AREA
REIIEDIAL UNIT: REftEDIAL.UNIT : REIIEDIAL UNIT
: 6W-1 6W-2 6W-4 6W-5: TSA-1 TSA-3 TSA-4 : LA-1 LA-3 LA-5
OVERALL SITE
REliED I AL UN IT
: OS-3 OS-4 OS-5
========::========::==================:=====--=====~============:===--===============:~===::=============:==--================:
FEDERAL REQUIREIIENTS
--------------------------------------:------------------------:-------------------:-------------------:--------------------
RCRA Locition Requirelents
40 eFR 264.181cl
y
Y
y
y
y
y
Nitionil Historic Preservition
Act of 1966. 16 U.S.C. 470 et
seq. 36 CFR Part BOO
Endangered Species Act
16 U.S.C. 1531 et seq.
SO CFR Part 402
Coastal lone "anagelent Act
16 u.S.C 1451 et seq.
15 CFR Part 930
Fish and Wildlife Coordir.atio~
Act 16 U.S.C. 661 et seq.
Clean Water Act. Section 404
Pertaining to Wetlands
33 U.S.C. 1251 et seq.
y
y
Executive Order 11990
Wetlands Protection Policy
Executive Order 11988
Flood~laln lIanage.ent Folicy
Y
y
Y
y
Y
y
--------------------------------------:------------------------:-------------------:-------------------:-------------------:
STATE REQUIRE"ENTS
--------------------------------------:------------------------:-------------------:-------------------:-------------------;
State 01 Rhode Island DE" Rules
ind Regulatio~s Governing the
Enlorcelent of the Fresh Water
Wetiands Act RI 6L 2-1-18 - 27
y
y
y
y
y
y
y
y
y
y
y
-------
'rABLE 14
ATTAINftENi OF POTENTIAL A~IION SPECIFIC ARAR5 WITH RESPECT TO ALTER~~TIvcS
========================:======-----=========-------=========--===========--=--===========--=====================================
REGUIREftENTS
Y = MILL BE ATTAINED
N = MILL NOT BE ATTAINED
ON-SITE 6ROUNDMATER : TCE SPILL AREA: LANDFILL AREA
REftEDIAL UNIT : AE~DIAL UNIT: AEftEDIAL UNIT
: 6W-l 6M-2 6M-4 6W-S: TSA-1 TSA-J TSA-4 : LA-1 LA-3 LA-S
: OYERALL SITE
REftEDIAl UNIi
: OS-3 OS-4 05-5
======================================:========================:===================:==============--====:===================:
FEDERAL REDUIREftENTS
--------------------------------------:------------------------:-------------------:-------------------:-------------------:
RCRA Ider.tification of
Hizirdous Waste 40 CFR 261
y
y
y
y
y
y
y
RCRA Ficility Stindards.
Prepiredr.~s5 ar.d Prever.tio~,
Contingency Plin and Elergency
Procedures 40 CFR 264,
Subparts 8, C, D
y
y
y
y
y
y
, .
,
RCRA ftanifest Systel,
Recordkeepi~g. ind Reportin~
40 CFR 264 Subpart E
II
Y
I'
y
Y
I'
y
RCRA 6round.ater ftonitorir.g
Requirelents ~o CFR Subpart F
y
y
Y
y
y
N
RCRA Closure aod Post Cla~ure
Requirelents 40 CFR 264
Subpart G
y
y
y
y
RC~A Storage Requirelents
40 CFR 264 Subparts I, J, and l
y
I'
I'
~CRA landfill Requirelents
40 CFR 26~ Suboart N
y
y
y
RCRA Treatlent Require1ents
40 CFP. 264 Subparts 0 and 1
y
I'
I'
RCnA land Disposal Restrictions
~O CFR 268
y
y
y
Clean Water Act Disc~arop
lilititions- HPDES Perlit
40 CFR 122, 125, 129, 136
y
y
y
y
.
,.
.,
,
Clean Mater Act W!tlands
Regulations, Part 404
40 CFR 210
Executive Order 11990
Metlands Protection Policy
I'
I'
,
,.
Executive Order 11988
Floodplain ftanagelent Policy
y
I'
y
y
y
-------
TABLE 14
ArTAIN~ENT OF FOTENiIAL ACTION SPECIFIC ARARS WiT" RESPECT TO ALTERNATIVES
=================================================:=========:::=----===================================:::::===================
REOUIREI'£NTS
Y = WILL BE ATTAINED
N = WILL NOT BE ATTAINED
ON-SITE GROUNDWATER: TCE SPILL AREA: LANDFILL AREA
REIIEDIAL UNIT: RE"EDIAL UNIT: REI'EDIAL UNIT
: SW-l SW-2 SW-4 6W-S: TSA-l TSA-3 T5A-4 : LA-l LA-3 LA-S
OVERALL 5 ITE
REIIEDIAL UNIT
: 05-3 05-4 05-5
======================================:========================:===================:===================:===================:
Safe Drinking Water Act
Underground Injection Control
Progra. 40 CFR 144
Clean Air Act New Source
Pertorlance Standards, Section
111 40 CFR 60.
Y
y
Y
National Elission Standards tor
Hazardous Air Follutants
40 CFP. 161
Y
Y
Y
Y
Departlent ot Transportation rules
tor the transport of hazardous
substances 49 CFR
Y
y
~
y
Y
y
Y
Occupational Safety and Health
Standards 29 eFR rart 1910.120 Hazard-:
ous Waste Operations and Elergency
Respor,se
Y
Y
Y
y
'i
y
Y
Y
Y
Y
Y
Y
y
Occupational Safety and Health Y Y Y Y Y Y Y Y 'i Y Y
Standards 29 CFR Part 1926 Safety
and Heal th Standards
Occupational Satety and Health Y Y Y Y Y Y Y Y Y Y 'i Y Y
Reporting an.~ Related Regulations
--------------------------------------:------------------------:-------------------:-------------------:-------------------:
STATE,REDUIRE"ENTS
-~------------------------------------:------------------------:-------------------:-------------------:-------------------:
R.I. Rules and Regulatior.s tor
Hazardous Waste 6en~ration.
Transportation, Storage and Disposal
F..I.S.L. 23-19-1 - 10
Y
y
Y
y
Y
y
y
R.I. Rules and Regulations
fer Solid..ast~ "anaq!lent
FacIlitIes F..1.6.L. 23-18.9,
23-19, 42-.17.1
Y
Y
Y
Y
y
y
R.I. Undergr~un~ I~Je:tior.
Contrel Progra. ~.I.E.L.
42-17.1. 46-12
y
y
Y
R.I. Water Quality Regulations
tor Water PollutIon control
n.I.6.L. 46-12. 42-17.1. 42-3~
y
Y
Y
y
-------
TABLE 14
ATTAIN~E~T CF ?OiENTIAL ACTIO~ S?ECIFIC ARAR5 WITH RESPECT TO ALiERNA:!v£S
==========================================================================:==================================~==============
REDUIRE"ENTS
Y : WILL 8E ATTAINED
N : WILL NOT BE ATTAINED
ON-SITE 6ROUNvWATER :
RE"EDlAL UNIT
: 6W-l 6W-2 6~-4 6W-S:
TCE SFiLL AREA: LANDFILL AREA
RE"EDIAL UNIT: RE"ECIAL UNIT
TSA-l TSA-3 TSA-4 : LA-l LA-3 LA-~
OVERALL SiiE
RE"EDIAL um
: OS-3 OS-4 05-5
======================================:========================:===================:=====--=============:===================:
R.I. Pollu!ant Discharge
Eilination Systel (RIPDES)
R.1.6.L. 46-12, 42-17.1, 42-35
Y
y
y
Y
y
y
y
Y
y
y y
.'
y
y y y
y y
y
y
Y
Y
R.I. Pretreatlent Requl.tio~s
R.I.6.l. 46-12,42-17.1, 42-~5
R.I. Air Pollution Control
Reguhtions:
No.1 Yisable Elissions
y
y
No.5 Fugitive Dust
Y
Y
y
Y
y
No.7 E.ission of Air
Contalinants Detrilental to
Person or Property
y
No.9 Ap~roval to Construct.
Install, "odify, or Operate
y
Y
y
y
Nc.l~ Record Keeping and
Reporting
y
y
y
y
~o.15 Control of Organic
Solvent E.issions
N~.:: Air Toxies
y
y y \'
Y Y \ Y
I Y Y Y
,I
No.16 Operation of Air Pollution
Centrel 5ysteos
y
N~.17 Oders
»ivision of Air and Hazardous
"aterials Policy on Perlitting
Air Strippers, April 20, 1989
y
----------------------------------------------------------------------------------------------------------------------------
-------
/(0 'f.~..
'ft '
t~)
4(:7
TABLE 15
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
".F. KENNEDY FEDERAL BUu.DING, 80STOH. MASSACHUSETTS 02203-2211
ADDENDUM TO THE FEASIBILITY STUDY REPORT FOR THE STAMINA MILLS
SUPERFUND SITE, NORTH SMITHFIELD, RHODE ISLAND
Lloyd Selbst
Office of Regional Counsel
USEPA, Region I
July 10, 1990
In addition to the ARARs discussea in the text and tables in
sections 4 and 5 of the Feasibility Study, the following are
ARARs for remedial alternatives at the site:
- The Rhode Island Pollutant Discharge Elimination System
(RIPDES) requirements are applicable to GW-1, GW-2, and GW-4.
- The Rhode Island analogues of the RCRA facility requirements
at 40 CFR Part 264, Subparts B, C, and D are applicable to OS-3,
OS-4, and LA-3.
- The Rhode Island analogues of the the RCRA groundwater
monitoring requirements at 40 CFR Part 264, Subpart Fare
applicable to
GW-l, GW-2, and GW-4i they are relevant and appropriate to GW-5.
- The Rhode Island analogues of the RCRA location requirements
at 40 CFR 264.18(c) are applicable to OS-3 and OS-4; they are
relevant and appropriate to LA-3.
- The Rhode Island analogues of the RCRA treatment
requirements at 40 CFR Subparts 0 and X are applicable to GW-l,
GW-2, and TSA-3. They are also an ARAR for OS-3.
- The Rhode Island analogues of the RCRA storage requirements
at 40 CFR Part 264, Subparts I, J, and L are applicable to GW-l,
GW-2, and TSA-3. They are also an ARAR for OS-3.
- The National Pollution Discharge Elimination System
requirements are applicable to GW-1, GW-2, and GW-4.
- The Rhode Island Pretreatment Regulations are applicable to
GW-l, GW-2, and GW-4.
- The Occupational Safety and Health Standards at 29 CFR Part
1926 are applicable to GW-5 and OS-5. '
The following laws were incorrectly described in
Study as ARARs:
- The RIPDES requirements are not ARARs for
- The Rhode Island Pretreatment Regulations
TSA-3.
the Feasibilty
TSA-3 or LA-5.
are not ARARs for
:t. f."
, ....-.', ,'-
\
-------
APPENDIX C
-------
United States
Environmental Protection Agency
Region I
SUPERFUND
J
Responsiveness Summary
Stamina Mills Site
North Smithfield, Rhode Island
-------
Table of Contents
Preface
............................................ 1
I. Overview or Remedial Altel'D8tives Con.idered In the
Feasibility Study, IDcludlDl the Preferred Alternative. . . . . . . .. 2
~
D. Backpound on CommnDity IDwlvement aDd Concerns
....... 4
m. Summary or Comments Received Durine the Public
Comment Period and EPA Responses. . . . . . . . . . . . . . . . . . .. 6
Pan I - Otiz.en Comments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Pan n - State Comments
Comments Regarding Groundwater Remediation. . . . . . . . . . . . . . . .. 8
Comments Regarding the Landfill. . . . . . . . . . . . . . . . . . . . . . . . . .. 10
Comments Regarding the OveraU Site. . . . . . . . . . . . . . . . . . . . . . .. 11
Comments Regarding the TCE Spill Area ........'............. 12
Comments Regarding Applicable or ReleY8Dt and
Appropriate Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 13
Comments Regarding Operation aDd Maintenance
Responsibilities and CostS .............................. 14
Comments Regarding the Future Use of the Site. . . . . . . . . . . . . . .. 15
Pan m - Potentially Responsible Party Comments. . . . . . . . . . . . . . . . . . .. 15
IV. RemaiD.iDl Concerns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Attacbment A:
Commumty Relatioas AaMties CoIIduaed at the
SWD.ina Mills SuperfuDd Site
Attachment B:
-------
Preface
The u.s. EnvIrorim8rUI P.CftCdon ~ (EPA) held 8 3O-d8y corM18f'It
period from 11 July 1890 to 8 AuguIt 1880 to prcMd8 an opportunity for tra8t8Sted
parties to convnert on the FeasIbiJity Study (FS) and the proposed plan prepared for
the StamIna Mills Superfund Site (the Site) In North SmIthfield, Rhode Island. The FS
examined and evaluared various options, called remedial altemativ8s, to address each
area 01 contamination. the Site. EPA jderdied Ita preferred alternative for
addIessing each 8188 01 $Ie corunnIion In the Propo88d Plan iaued July 10,
1990, before the 8tart 01 the public ccxnnert period.
The pu'pOS8 01 this Responsiv8nesa Soovnary II to document EPA responses
to the questionS and comments raiSed during the public comment period on the FS
and Proposed Plan. EPA consider8d 811 01 theSe questions and comments before
selecting a final remedial alternative to address the contamination 81 the Stamina Mills
site.
This Responsiveness Summary Is organized in the following sections:
I.
Overview 01 Remedial AJternlltiveS Considered in The Feasibility Study,
Including the Prefe"ed AJternalive - This section briefly outlines the
remedial attemativ. lYlluated In the Feasibility Study and the
Proposed Plan, including EPA'. prwferred alternative.
Background on Community Involvement end Concerns - This section
provides 8 brief histOlY 01 community Interests and concems regarding
the Site.
Summ81Y of Comments Received During the Public Comment Period
end EPA Responses - This section aummarizes and proYides EPA
responses to the oral and written comments received from the public
during the public c:ommert period. In Pan I, the comments received
from citizens are presented. In pan II, comments from. the atate are
organized b'/ ..1bjeCl PIIIt HI aummartz. COINn8f1tS received from
PRPI.
Remaining Conc."" -1NI18CtIon desCrtb8ll18ue1 that may
canIIrUt to be 01 COIIC8n\ to the c:arnnU1Ity CUIng the design and
ImpIern8nt8tion 01 EPA'll8Iected remedy for the Site. EPA will
8ddr8SS these concemI cUing the R8m8diaI Design and Remedial
ActIon (RO/RA) phase 01 the deanup process.
II.
III.
N.
In addition, tWO srtad'm8nt8 .. Induded In this ResponIIveness Summary.
Attactvne,. A provId88 8 1st 01 the c:arnnU1Ity p8IticIp8tJon actJvtieI that EPA has
conducted to date . the Site. Attachment B CCXUlns 8 copy 01 the transCript from the
Infonnal public hearing held on 31 July, 1990.
Stamina Mi", Superfund Site: Respor1$ivefJfJ$S Summ81Y
-------
1.
lherview of RenudUU AJumativu Considered in the
Feasibility Study, Incbuling tJu Pnferred AJu17Ullive
Contamin8tion _the Site II dMded Irfo four 8r88S: 1) trichIor08IhyIe (TCE)
apill area. 2) landfill area. 3) grou-dwater, 8nd 4) cweraII Site. U8ing WormatIon
gathered during the Remedial kwestJgation. EPA IdIrdied tp8CIic de8nup obiedJves
for each area ~ the Site that wtI be prat8Cdve ~ pdc health d the envtronmenl
The remedialaltemativ8l8tected for the Site rnJIt 8Ct1ieY8 EPA', cIunJp I8Y8Is for
80iI and groundwater and 8Chi8ve EPA', goal ~ 8Iimin8Iing phy8icaIand chemical
risks to public health and the envIroriment.
In the Feasibility Study (FS) EPA has ICr8808d ~ 8Y8IU8Ied aeveraI potential
cleanup altemativ81 for 8IICh ... ~ corumnadon . the StarnnI Mils lite.
Addltionallnformadon on each ~ the rwnediaI 8It.".,. can be fou1d In the Record
~ DecIsion (ROD), copies ~ which 81'8 located In the North Smllhfteld Public UbraIy .
20 Main Street, In North Smithfield, Rhode Island (the Information repository that EPA
has established for the Site), and the EPA Records Center. 90 Canal Street In
Boston, Massachusetts. The treatment alternatives are desCribed briefty below by
contamination area.
TCE Spill Are. (TSA)
.
TSA-1: On-site Incineration. SoIls In the TCE apiU area would be
excavated and Incinerated In . rotary kiln Incinerator that would be
const~ed on-slte specifically to treat contaminants from the Stamina
Mills site. All air emissions from the Incinerator would be treated to
ensure that air quality standards are met and that pubDc health and
the environment are protected. Beca'1$8 incineration may not destroy
all contaminants, ash resulting from the IncIneradon process would be
tested and disposed of In compliance with _e and federal
regulations.
TSA-3: Soil Vacuum Extraction. TCE and re1a18d compounds would be
, removed by Installing. runber ~ ahaJIow wells thrOUghout the spill
area soils. A pump attaChed to the wells would 8Xtr8Ct air containing
TCE from the IOiI by creating . V8CWm. The air would be coIJected
through one cernI pipe and the TCE and oIh8r volatile organic
~ (V0Cs) would be C8ptLIId on ICtIvItId CIrt)on filters.
The tr88Ied air would then be released to the IItmOIpher8 and the
8P8"I activ8t8d carbon tilt.. would be tr8WpOrted off"'e for
tr88bn8nt and dispoPI.
.
.
In the Proposed Plan II8u8d prior to the public cornrTMn period, EPA
recommended this 8It81'N1dv8 .. Is pnlf8lT8d r8m8dy for addressing
the teE apIII... ~ .
TSA-4: No-ActJon. No treatment ~ TCE api11 area lOlls would be
conducted. Instead, the 81'88 would be graded to encourage surface
run-df, covered with clean flU, and aeeded with grass.
2
Stamina Mills Superfund Site: ResponsiveMSS Summary
-------
LandfIll Ar.. (LA)
.
1.4-1: 0n-Sit8 Incinetadon. Soland waste In the landfill area would be
8ICCIIV8Ied 8nd lnci18r8ted to destroy the cxnaminantS. Incinerator
emiaian8 WCUd be trUted prier to r8Iease to the 8tmO$ph8re.
Incnntor ash WCUd be t88ted for residual corumin8tiOn and
~ d In ~ wIh ... 81d I8d8r8I regu&arJons.
LA-3: CappIng. LMdIII area cc:nanWItIon would be treated by
consIrUCting 8n Impermeable cap over the landfill 8t88 to prevem
rall'1WIIter and snow melt tram ruching the wastes and corumlnating
grooodwater 8nd 8UIface water. Landfill wastes located In the
floodplain WCUd be ~ 8nd pI8C8d W1der the IandfiU cap. A
l8achaIe collection IyIt8m woUd 8Iso be 1nItaIIed. 8nd any leachate
collected would be piped to the editing on48 88W8I' for treatmem at
the Woonsocket WBStewaler treatment plant.
.
In the Proposed Plan issued prior to the public commem period, EP A
recommended this alternative 8S Its preferred remedy for addressing
the Landfill Area contamination.
.
LA-5: No-Action. The landfill area would be graded, coyered with
clean fill, and planted to stabilize the area.
(lroundw8t8r
.
GW-1: Air Stripping. Groundwater would be DtraCted through
bedrock wells and pumped to the top d an air stripping tower, where
contaminants would be tranSferred from the groundwater Into air being
forced up through the tower. Both the contaminated air stream and
the treated groundwater would be further treated by passing them
through separate 8Ctivated carbon filters to prevent the emission of
contaminants Into the air and remove residual contamination in the
groundwater. Spart carbon would be transpOrted oft-aite for treatment
8nd dispo-~
.
GW-2: Camon Tl'88tm8nt GrtKnt.vII. woUd be 8X!r8tted ttvough
bedrock weill 8nd pumped through . -- d t8nIc8 coruinJng
8Cdv8Ied carbOn. CorUrrin8r'ds woUd be adsoIt)ed onto the
8Ctivated carbon and ~ from the groundwater. Spert carbon
would be nnsport8d oft-slte for tr88tI'nIIrt and disp0s8l.
GW"': UItnMolet Light (UV) end Hydrogen Pero1dde. CortaminaIed
groundwater woUd be 8Idr8Cted thrOugh b8drodc W8II8 and treated
on-eIte U8ing . W 8nd hydrogen perDDdd8 8ySt8m. EPA wII monitor
ayltem pertormanc8 and make an 8'I8IuatIon d the pertormanc8 d the
ayltem ~ to detennine the 1Iftec:tiv8neSS of extracting and
treating the contaminated bedrock grounawater.
.
Sfamine Mills Superfund Site: Responsiveneu Summary
............, ...,
-------
ll.
.
In the Proposed .PIan Issued prior to the public COfTVT)8r'i period, EPA
recommended this alternative as Its preferred remedy for 8ddr8ssing
the groundwaler COfUn'1in8tjon.
GW.5: No-Action. No groundwater tnNIb'n8nt woutd be conduded.
Groundwater would be sampled 8MU8l1y to determine the remaining
level cI contamination 8nd to d8fin8 the .n cI the coraminant
plume. Institutional co. ~uI$ would be lrrIpIem8raed to ImIt future use
cI the Site end groundwater.
Overall Site (OS)
.
05-3: Demolition, Sealing R8cew8p, LOcation 81Jd RemtN81 d s.ptic
T81Jk Contents, Site Grading. On-8IIe IINCt1nS Including the mm
building ruins 8nd the smokestack would be demOlished and disposet1
of in accordance with Rhode Island Sofld Waste Regulations. The
entrance and exits of the old and new raceways would be sealed with
concrete, and. then the raceways would be backfilled with building
debris from the Site or other suitable fill material. The septic tank
would be located and Its contents tested and disposed cI off.slte. The
overall Site would be graded (except for the capped landfill area) and
planted with vegetation. In addition, institutional COIIb oIs in the fann of
future land use restrictions would be placed over the entire Site.
In the Proposed Plan Issued prior to the public comment period, EPA
recommended this alternative as Its preferred remedy for addressing
the overall Site contamination.
.
05-4: Demolition, Excav8ling 81Jd Sealing RaC8WllyS, Location 81Jd
Removal of Septic T81Jk Contents, Site Grading, Excavation of PAHs.
This alternative is Identical to alternative 08-3, with the addition of
excavation cI racfNIIly sediments and excavation cI an area of
elevaled PAH concentrations referred to as the -hot spar. Excavated
sediments would be treated and dlspos8d cI off.slte.
0S-5: No-Action. The Site would be 18ft rt lis current _e.
InstItI.Cional \NIl ~011 to ImIt I8nd 81d groundwater &88 8nd tighter Site
88CUtty ......... In tIrmI c11r'nprowd f81dng would be
Implemented.
.
Background on CAmnwnity In~ol'~1MnI and CAnc~mS
The S-acie Stamina Mills Superfund lite is located rt the VUlage cI Forestdale,
within the Town cI North Smithfield, Rhode Island, approximately 1 mile south cI the
Rhode Islandl MassachusettS border and 14 miles northwest cI pRMdenCe, Rhode
Island. Between 1824 and 1975, the Stamina Mills site operated as . textile weaving
and finishing facility. A ma;or fire at the Site destroyed the mill complex In 1977, and
..
Stamina Mills Superfund Site: Responsiveness Summary
-------
the d8briHtr8Wn Site was 8bandoned. Rubble, plies at debris, and foundation
remains (Including. det8bllting lrnOkestaek), curentIy occ:up'J the Site. Waste
dIspn-I practiceI . the Sit. Induded uN at an 0048 IandfiU, which 18 believed to
haYe conb1but8d to lIte-rel8red c:orumNtIon problems.
ShofUy after . n8W 8OIv8rt~ accutng 8y11tem was lnltalled In 1969. a
.pll at the IOIverC TCE occured cUing the filling at an abcMt ground .orage tank.
The area wh4n the 8PII oc:cun8d II ,eI8rr8d to .. the -rcE ipIII .88". Based on the
advice at the Rhode IIIand ~ at Health (RIOOH), the Stamina Mills Company
dIsCOndnu8d L88 at .. well .. . 0\ IIdng "81' 1CUC8. .
Du1ng . ltatewlde groundwater 8XY8y conducted by RlDOH In 1979. TCE
was detected atr-slte In the Fcnstdale W8I.er AssociBtInr1 well, . convnunlty water
8yStem 1oc8I8d north at the Sit. and ..,mg appc0ldmlll81y 25 hom88. M. result of
theSe ftndlngs, AlDOH ccpanded the 8811PfIng p.0QI8m and t81t8d 51 prMIte
resId4niaI wells In the Fcnstda18 .... the Forestd818 W8I.. ~ weD, and the
Stamina Mills weR. AlDOH bm TCE In 18 residential wells. AI. that time. RIDOH
advised ar88 residents to boil water used for drinking and cooking.
In 1981, the State at Rhode Island Water Rasources Board and the Town of
North Smithfield financed the construction at . municipal water main to serve the
residential area north at the Site that had been affected or had the potential to be
affected by contamination from the Site. Between 1981 and 1984, only seven of
approximately 50 affected or potentially affected residenc88 had COM8ded to the new
municipal water supply, reportedly due to costs lISSOCiated with ~ng to the
water main.
In 1983, the Stamina Mills Site was placed on EPA's Final National Priorities
List making It eligible for Federal cleanup funds. In September 1984, EPA began to
supply bottled water to resIderdS not connected to the municipal water supply. Later
that year EPA funded an extension at the existing water line as weD as the costs for
the connection at homeS to the muniCipal water suppty. All affected or potentially
affected residenCeS are now receiving municipal water.
CommunIty interest In the StamIna Mills lite has been moderate during the FS
and public cornmert period. Appraxim8IeIy 20 r8Iident8 attended. public
Informational meeting held on 10 July 1890 by EPA. The principal community
concerns ~ _ad . thai meeting .. unmartzed below.
.
0per8II0n at EPA', PrfIIerred AIt8mtIIN8. R8sId8ntI' m&Ior concerns
~ the ImpaCt at the remediation on the aquifer, the diseharge of
the tr88Ied WBler, and the eftectN8M18 at the tr88Im8nI tect.-,oIogies
proposed.
.
SelectIon allhe Remedial AItemIIIive. RelId8nt8 ql8tion8d why EP A
hid not Included rwnoY8I at the IandftI cart... In the preferred
altematJve, whether PAPa woutd h8v8 InpUt into the final setection
process. and whether comments from the _e would be published.
Stamina Mills Superfund Site: Responsiveness Summary
........ ......, ---
-------
111.
.
Project Schedule. R88id8n18 went COIIC8m8d with the amount d time
taken by the deanup process 8nd the lCheduie for the It8It and the
completion d the Ste ~
F/n8nCJng of the Cleanup. R_Ident8... COIIC8m8d ~ who would
pI6f the COlt d ~ and wh8th8r the town ~ bear eny d the
cosa.
.
.
FinIIJ DiapoaItion d SIami". "i'" Propettf. R.Id8nt8... COIIC8m8d
~ the potential ~erm UI88 d the property 8nd who would
control the Site', fWn d8Y8Iopment.
GtfJuntJnler 0u8J1ty. R8IIdenI8... cOncem8d CMN' the possibility or
homeowner8 In the COIUI11inIIri pUn8 .r88CtiY8tIng their well, wh8d1er
these homeowners could ever use IheIr wells again. and whether
homeowners could recover COStS assodated with the loss or their wells
from potentially responsible parties (pRPs).
.
Summary 0/ Comments Received During the Public Comment
Period and EP A Responses
This Responsiveness SummaJy addresses the comments received by EPA
during the public comment period concerning the FS and EPA', Proposed Plan for the
Stamina Mills site. Two setS or written commen18 were received during the public
comment period (11 July 1990.8 August 1990), one from the Rhode Island
Department d Environmental Management and one from the K8yser-Roth Corporation,
a named PRP. Five persons submitted oral commentS . the Informal public hearing.
The individuals commenting. the public hearing were either govenvnent oIficiaJs or
representatives d the PRPs. A copy or the public hearing transCript illncluded as
Attachment B. CopieS are also available at the North Smithfield Public Ubrary at 20
Main Street, Slatersvtlle, Rhode Island, and . the EPA RecordS Certer . 80 Canal
Street In Boston, Mu,achuseas, .. part or EPA', Ac:tministrativ Record for the Site. .
Partl-Cltlz8nC0mment8
ComrnIrtora . the pWIIc hIartng ... Slnltor Pu K8IIy Ind North
Smithfield Town CouncIlor Lynda Masnyk. No wrtIten COI'Nn8nI8 -- submitted from
the general public.
Comment (11: Senator K811y _ed that . prtnctpaI concern or area homeowners is
that EPA, RlDEM, or the Town or North SmIthfield take It8pI to ensure that .
homeowners whoI8 wells wn 1If8Ct8d by the corumin8tiOn pUne wII net r88Ct1v8te
their wells and potentially CIIUI8 the plume to begin again to move ftW'/ from the Site.
EPA Response: EPA'. authority under CERCLA does net allow EPA to prohibit the
use d private wells that are located off.slte. EPA does, however, strOngly recommend
that wells previouSly Identified as coraminaIed by the Stamina Site not be reactivated.
6
Stamina Mills Superfund Site: Responaivenesa Summary
-------
Comment (12: Senator Kelly asked EPA or RlDEM to 8ddress whether residents who
had lost the L88 of their wells due to Site t81ated c:orumNtion had any legal rights
by which they could r1ICCMW th8Ir ftn8nCiaIloss88, 8nd whether EPA or RlOEM could
88Sist them In any effort to r8CCMW 8UCh Ioa8s.
EPA Reaponse: EPA Ia not aahortzed 11) COUW8IIndMdua1a 8bcU their private rights
of recoIfKy against PAPa. EPA C8n 8ISisI r8SId8rU by providing Information
requested by r'8IId8nt8 th8I11 coruined In EPA', Admini8tnItIv8 Record for the
Stamina Mills Site.
Comment #3: CouncIlor Masnyk _ed th8t, while the 8gI'88S that the preferred
8ItematMt would ~ EPA', goaII tor atw Site. .. would llee the Site returned to 8
prI8t8w ccncItJon. 8h8 -.d thII thI8 Wo&8t requn the rwncMII r8Iher than the
capptng rib IIIndfiI ~ a...
EPA Response: EPA believes thai remcMng the I8ndfiII -- from the Site would
not be protective of human health and the envtronment bec811SB of the short-term risks
posed br air emIssian8 cUing 1M materials handling and operational phases and
would not provide . degree of protectiveness proportionate to Its cost. The excavation
d landfill wastes. would only transfer these wastes to another facility and location
which WDUId require similar containment and monitoring as proposed for the Site.
Therefore, EPA has selected capping of the landfill as the landfill remedy becauSe It
limits the extent of short-term risks, II II more cost4ffective and II is protective of
human health and the environment.
Comment #4: Councilor Masnyk wged EPA to proceed toward . total deanup of the
aquifer, noting that the Branch River groundwater lIquifer II considered . potential
water supply for the Town of North Smithfield. She also requested that the
groundwater quality be monitored as the cleanup progresses.
EPA Response: EPA's goaIla to rwturn the groundwater within the contaminant plume
to Its ben8ficiaI use (drinking Wlter quality) as rapidly IS technically practJcable. EP A
will monitor the groundwater quality during the cI88nup process to assess the
perfonnance 01 the cleanup system In reaching the drinking Wlter quality goal.
Comment #5: Councilor Masnyk _ed th8I the editing SII8 condition constituted an
8'j8S0r8. She requeated tha the buildings be tom down8nd the Site', appearance
hpRMd 81 quIcIdy 81 poaibIe, prIf8r8bIy In .... than the two y88'8 that EPA
811imated . would tak8 to begin rwnediation WOftc . the Site.
EPA Response: AI part 01 the overall remedy for the St8mna Mills Site, the buildings
will be torn down. EPA will pwIU8 the IrnpIemerUtion -01 the remedy within the
8hortest possible time fr8m8. Also, durtng the d8IIgn 01 the remedy EPA will consider
the feasibility 8t1d nec8ISIty 01 d8moIiIhing the ItnCnI tIrIt. B4a11p 01 the
potential negotIatlonl with the r8IPOIlIIbIe pII'Iy, EPA II W\IbI8 to predict with any
accuracy when Site remediation may begin.
Stamina Mills Superfund Site: Responsiveness Summaty
....,.. ...... .....,
-------
Part II - State Commenta
The Rhode Island Depanmert of EnvtronrnerUI Managernert (RIDEM)
pnMded oral COI'I'II1'I8lU . the public hearing 8nd WIllen comment8 In . leUer from
James Fester, Assistant Director for Regul8tion, d8ted 31 July 1990.
Comments Raprdlng Groundwater R8medI8fIon
Comment 1: RlDEM _ed ttw the ROD 8houId: 1) Include . performanc8 I"8Yiew of
the groundw8ler rwnediation to be condIlCted wIhin fN8 years of the InIti8tIon of the
remedy, 2) Ip8Cify an".-native or CCdiig8R rwnedy to be lmpI8rn8rtad I the
performance r8YIew Indicates that the pntwIIer rwnedy .. not making l8tisfactory
progtBSS tow8'dl meeting the r8m8di8I abj8ctIv8. and 3) _e1hll the ~
otIjec:tJv8 .. Irterim In nature and may be C08-.i IQ«d an the ~ of th8 petfonnance
review.
()
EPA Response: EPA will conduct periodic review and evaluation of the groundwater
extraction and trWbuent system to determine the cleanup system's contaminant
removal efficiency. A complete 8V8Iuation of the system will be made within five years
of the start up ~ the extraction and treatment system. If the evaluation r8Y88Is that
the remedy cannot achieve the stated cleanup levels, or that the cleanup levels cannot
be achieved In a reasonable time frame, consideration will be given to making
changeS In the remedy. The remedy selected In this Record of DecisIon Is meant to
be a pennanent and complete groundwater cleanup remedy. EPA realizes that the
groundwater pump and treat system may not be able to achieve the final Incr8ment.oI
the cteanup goals In the estimated time frame (10-15 years). In recognition of the
system Iimitations,.EPA will conduct periodic evaluations of the system petfonnance as
deSCribed above.
Comment 2: RIDEM stared that the groundwater remedy should be Jmptemented In .
staged process that defines the parameters needed to optimize the operation of the
system as more Information becOm8S available. DurIng the design phasa and pump
test, the number, locations. pumping rates. and constnJCtian specIficationS of the
extraction wells shOuld be chosen to achI8Ye cleanup objedIves - quickly as Is
technically practicabI8, preferably In less than 10 years.
EPA Response: EPA II In ~ wtIh this ~,.,... EPA Irtends to use the
Worm8tion get....-d cUtng the ~ign. d8Iign and oparI8ioNII pha88S of th8
lYStem to optimIzI the 8fficienCy cf thllXtrICticn 1yItem. The goal wID be to 8ChieYe
the cleanup ot)I8ctIv88 - r8PidIY - t8Ch.1iaIIIy pr8Gticabie.
Comment 3: RlDEM questioned the 8bi11ty and appropriater8S 0I18aching galleys to
disCharge .mud - the proposed rites of 8X!r8CtiOn.
EPA Response: Th8,..".. of the pra.d8SIgn p.mp ... and pIIaIl8Sting 0I1he
groundwater treatment system wJI be used to 8V8IuIIe the 1PPI'OPfI8t- lndIor
feasibility of the ttvee discharge options being consid8r8d by EPA for the treated
groundwater. The options being consid8r8d Include subSurface cfispoP' through 0o-
lite leaching galleries, on-site surface water discharge, and discharge to an on-slte
sewer Une with oft-lite treatrnert . the Woonsocket publicly owned treatment wor1cs
8
Starni,. Mills Superfund Site: Resp0nsJven8SS Summary
-------
(POTW). Dwtng the FS, the 0MIte aaurtace discharge using leaChing galleys was
eetected as the Initial disposal option, bA EPA b808ves . this time thai the on-site
eurtace water discharge may be the mast tppI apriIte n f8asibI8 alternative. The
ftn8I decision on which ~ option wi be U88d for tr88I8d ~er will be
made during the design Itage using Wonn8tion abtained cUIng pre-deslgn 8Ct1v1ties.
Comment 4: AlDEM qu8Itb led the 8XdI1IIot1 of m8t8II tI'88tm8nIln 1he FS and
Proposed Plan given the occurence of metals In COI--Ib~ 8bcMt ~CLs.
EPA Response: Ctvor'IUn was detected In 2 Cd of 32 on-8Ite monitoring wells at
cor-.Ib aIJon8 8bcMt the MCL The occurence of chromium In 1heSe two wells, which
are In the vicinity of the I8ndfiI, II beIi8Yp8d to be 88Ioc:i8t9d with the migration of
Illndflllle8ch8te. The propoMd r'81'I8CMtion of the IIndfIIIIndud88 capping and
coUection and ~ oIl88ch8te from Ih8 I8ndIiIL The propoMd remedy 18
designed to mitigate the further migration 01 ch. omUn rao the Branch RIver and
groundwater. ChromJum I8Y8Is 8bov8 the MCL haYe naI been detected In 81T'f other
morAufng wells across the Site. Ther8fore,. separate 1r8atmeI'It system for the
removal at chromium from the groundwater II not b8Ii8Y8d to be required for
remedialion of the Site. One ather traC8 metal, lead, has been detected at
concentrations slightly exceeding MCLs In the groundwater from lC8!tered locations
across the Site. It Is not anticipated that the ~ntrations of lead or ctvomium In
groundwater extracted for treatment willlncr8aS8 or exceed MCLs during the
operational period of the groundwater extraCtion and treatment system. Rather, these
concentrations are expected to decr8aS8 during extraction as 8 result of the reduction
In leachate generation due to the RCRA capping and Installation of a leachate
collection system In the landfill and the natural dilution that wiD occur as groundwater
from the entire Site Is extraCted. Further monitoring 0I1he l8vels of m8CaIs found In
the groundwater wiD be conducted during pre.deslgn. In the event thai the monitoring
Indicates the need for additional pretreatment of metals, 8Ith8r to meet g~er
cleanup ARARs or disposal ARARs for treated groundwater, then further laboratory
bench-scale or pilot testing wUl be completed during pre..deslgn and design phases.
Comment 5: RlDEM asked whether the potential for added treatment of groundwater
prior to discharge had been consider8d In 1he 8V8Iuation of the groundwater treatment
alternatives.
EPA Response: M d8Icrtb8d In EPA', response to ~ 4, above, pretl'88b'n8nt
tor IOIubI8 m8ta11onI II not nicipated to be needed . this time. MonItoring of the
groundwater for lOIubIe metal IonI wID be completed cUing the pre-deslgn pump test
and pilot testing of the UV/hydrogen peroxide system. -In the evert that the monitoring
Indicates the need for further ~ 0I1dubIe metals, either to meet
groundwater cleanup ARARs or ~ ARARa for treated groundwater, additional
labOrBIexy benCh-8c8I8 or pilat t8ItIng wi be ~ CUing pre.delign and design
phaSeS.
Comment B: RlDEM asked whether the costS 0I1nstaIJing and operating the
proposed pressure ftltration I.d n the Iron and manganese removal units had been
Included In the COSt estimates for each groundwater alternative, and . not. what these
added costs would be.
Stamina Mills Superfund Site: Responsiveness Summary
...... .. ."". ,.,." .
-------
EPA Response: Costs for Iron and mangat88 r811OV8I L8ing . pressurized filtration
lyStem were indIlded In all of the gl'OU1dw8ter Ir88tJ'n8tt 8Item8dv8S evaluated.
Further pre- or poII-tr8abn8nt requirements will be dltennWaed cUing the pre-design
and design stagel for the final r8m8diaI 8It«rI8dv8. 8ign11c81'f.C08t dIIf«8l1C8S
between the alternatives for grcudw8ter tr'8IIb1W'a would not r88Uft from the
8ddItionaI ~ nor wcuk:t the ovwaI COlI be IigIIIIc8ntIy 8It8r8d giYen Ihe
. 8V8IIabIe Information.
Comment 7: RlOEM qu8Ition8d wh8ttw the W/hydrog8n.-C»dd8 C»Cidadon 8yStem
would affect the dissOMKt rnICaI8 bn:t In the Site grooodwater. RlOEM IP8CificaIIy
qu8Ition8d whether trtvaIent chrc:ImUn would be Clllddized to hec8Y8Iert chromium.
,
EPA Response: EPA dilQlIIionI with the d8signerI d the W/hydrogen peraIdde
aystem n:tic8te that the ayst8m would h8ve IttIe 8ft8ct on dissoIY8d IMt8Is In the
groundwater. Specifically, Irtv8Ient chromium would not be CDddiZed to h8xavaJent
chromium during the treatment process. AlsO, EPA believes that the chromium
detected In the monitoring wells In the vicinity of the IandfiU 18 associated with leachate
migration from the landfill and 18 not r8fIectIye of levels that would be found In
extracted groundwater. The remediation of the landfill should effectively eliminate any
further migration of chromium Into the grooodwater and the Branch River.
Comment 8: RIOEM questioned how EPA will address the potential for drawing
contaminated groundwater during the Site pump teSt from IOUI'C8S other than Stamina
Mills.
EPA Response: The prlHSesign pumping test will be designed to gather the
Information necessary for designing and evaluating the recovery lyStem which
Includes delineating the draw down distribUtion and the capture zones. The recovery
system will be designed to minimize the extraction of clean grooodwater 8nd any
Induced Infiltration from the Branch River. The design 8IsO will seek to minimize the
potential for causing the migration of any corumin8ntS from off-site.... such as the
Industrial area south of the Branch River. this wiU be done by evaluating the
predicted draw down distribution. Monitoring of weD water levels will also be
conducted during operation of the r8CCMtfy aystem to V8rIy that capture zones are
being maintained to minimiZe the InfiItr8tIon of at. from 08 aide of the capture zone.
Commentl RtpIfI/nf CII8 L8ttdllII
Comment 9: RlOEM qu8Ition8d whether the l88ch8te caIection system discharge
would be continuoUS or In balcheS.
EPA Response: Bec8' 1M of the dIIficuIty In predicting the precise effectS of . RCRA
cap on the quantity 8nd physical ch8r8Ctert1tic8 of .-rt l88chate that would be
generated. . 18 Ikely th8I1h8 initial quardieI of INch8Ie g81--ect, Ifter the
construction of the cap, will be collected, tested, .ored on-IIte, Ind treated if
necessary I until . has been established that the l88chate wtU meet pre.treatment
requirements of the P01W. Therefore, the initial discharge from the leachate
collection system is likely to be In . batch mode but this may be changed to a
10
Stamina Mills Supet1und Site: Responsiveness Summary
-------
continuouI discharge . . ..er date, pending the ch8r8cterization c:A the landfill
leaChate.
Comment 10: RIDEM qll88tbw wh8t measures will be n8C9Mt"Y to prevent
InftItr8tion from the rtv8r during ftood conditionS.
EPA R8$pOI1$8: The CCf1IINCtian d the cap and the NItur8 c:A tt:- C8A)ing material
(40 mil hign-denSlty polyethylene) will minimize InftItnItion d water from precipitation
8rtd/Ot ent poaIbIe ftood..... Much d the landfill maaeri81 wIhIn the 100-year
flood plain wtI be 8XC8V8t1d and ~ wII be placed on top d the cap In the ftood
~n II88S to prcMde ICOUring protection CUing ftooding.
. .
Comment 11: AlDEM qll8StioMd whIIt. EPA II prqx8Ing to 1m18CC8SS to the
8INIflIIne LRier the IIndfiII for malntln8nC8 Ot repI8c8m8rt d the Ine and thef8by
prcrecr Ih8 1r1egr1ty d the cap.
EPA Response: EPA proposes to alloW IICC8SS to 1h8 manholes cumtntty existing In
the \andf~1 by Including In the cap deSign provisions to 8Xtend the manholes to the
new surface d the cap. The manholeS would allow 8CC8SS to the Bne tor repairs In
the future. The remedy must remain protecttve; therefore, the Integrity 01 the cap must
not be Impaired by 8t'ft wor1< performed by the Town on the aewertine.
Comment 12: RlDEM questioned why the feasibility 01 excavating the landfill was not
evaluated in-depth other than In the oft.sltelncineratOt alternative.
EPA Response: The alternative for excavation and removal c:A landfill wastes to an off.
site facility did not receive detailed analysis b8ca'1$8 It was determined by EPA to not
be protective 01 human heaItn 8nd the envtronment bec~'1Se 01 the shof1-term risks
posed by air emIssionS during the materials handling and operational phases and
would not provide a degree d protectiYen8SS proportional to Its cost. The excavation
at landfill wastes would only transfer th8s8 wastes to another facility and location
which would require similar contaInm8rt and monitoring as proposed for the Site.
Commentl Regarding the Onra" sne
Comment 13: AIDEM 8Iked whIItw EPA h8:t ...Iaped cocaillQ8nCY plans to
8ddr8sS IITf - d 1he r8C8W8Y8 bni to be r&8ct CUing rwnedi8tion.
EPA Response: The exits d the old and new nIC8W8yS wID be 888Ied with concrete
8M then the r8C8W8YS wID be b8cIdIIed wIIh .*a~ ftI materIaL St. ~
1ncf1C8t8 that the ra&INIa'f beneath the IIIndfiD h8I coIIapIed. F~ t8It pit 8CtMty
during the design phase 01 remediation will be necea''Y to determine the Integrity of
the I'8C8W8Y& Proc:8dLI8s for fUIing thll8CtionI c:A 1he r8C8W8y8 thai ant found to be
rtact wII be d8v8loped CUing deSign 8nd ~ed CUi1g conItNCtIon.
Comment 14: RlDEM stated thai EPA'. teflt8l1C8l to coal gasIfic8!ion operationS at
the Site are Nppropriate, given that semi-YOIatile cortamiMnts found in an area
referenced as a -gasometer" ant not consistent with coal gasification operationS.
- -
sram/ne Mills Superfund Site: Responsiveness Summary
....... .....,.."
-------
EPA Response: EPA'. references to coal gasIicatjon operationI_the Site are based
upon the 1899 plan 01 the Stamina Mills (Forestdale MarUacturing Company) (Site
Plan SP-1 01 the RI) which Ihows the location 01. 34' ciameter, onHtOlY lIone
"gasometer-. The plan Ihow8 the gaIOm8ter to be loc8Ied near the banks 01 the
Branch RNer between the raceway Inlet and the lDttension 01 MID Building No.1. A 6'
x 16' coal shed II also indicated on the plan. The type 01 COf1'IpCU'dI det8Ct8d In this
area. polycyclic aromatic hydrocarbons (PAHa), .. 8IIOCiated with. variety 01 natural
and synthetic processes, one 01 which II COllI gasIficadon. EPA 8gf88S with RlDEM
that the levels 01 PAHs detected In the area near 1M fonner gasometer .. lower than
those typically assodated with . coal gasification f8d1ity. The lower I8Y8Is 888n In this
area may be the result 01 the tint which took place In 1 rtJ7 or IOm8 ather lIte-ntl8ted
1ICtIvIty. In addldon, ather COI'I'1pCUD which .. typically bn:t 8IIOd8ted with . coal
gaslf'lC8tion facility, 8UCh as Iron, and whose presence . alev8ted I8v8Is are used to
confinn a coal gasificatJon openIIlon, were not detected In this area.
Comment 15: RIDEM suggested thai grouting 01 the sewer lne trench could
significantly Umit contaminant migration along the trench and would enhance the
effectiveness of the groundwater remedy for the bedrock aquifer.
EPA Response: Grouting 01 the seweriine trench may limit contaminant migration
along the trench. However, EPA believes a more effective way 01 Umlting this
migration' pathway would be by maintaining groundwater levels below the bottom of
the trench. Groundwater elevations are expected to be lowered as . result 01 the
operation of the groundwater extraction system. During the pnHMsign and design
phases, the use of the groundwater extraction system will be considered to help
eliminate the sewer1ine trench as a potential migration pathway.
Comment 16: RlDEM asked whether the Installation 01 physical barriers . the points
where raceways enter and exit the landfill had been evaluated.
EPA Response: EPA has evaluated the installation of physical barriers at 1M entrance
and exits of the raceways. These locations will be 88aIed using a concrete barrier and
areas of the raceways which are not already collapsed will be back filled with suitable
fill material. EPA believes that these remedial activities along with 1M landfill cap
construction win minimize the migration of ground and aurface water "0 1M landfill.
The construction of an addItIon8I COlla ete bani8r In 1M old ~, directly
upgradient 01 the landfill wII also be considered as . means of reducing the flow 01
water through the IIndfUI In the ... that th8r8 II 8YIdence of . corcwed now
through the old r8I::8W8y after the nIC8W8y entrance has been 888Ied.
Comment. Aegaldlng the TCE $plll Area
Comment 17: RlDEM questioned whether . lowered groundwater table ~ng from
the operation of the groundwater extraction lyStem would allow pI8c:em8r1' of the vent
systems so that the entire overburden In the TCE lpill area could be treated.
EPA Response: Measurements taken during the remedial investigation Indicate that
only a small zone of seasonally saturated OYerburden soils exist It the Site
(approximately the lower 2 feet of 1M OYerburden). The cone 01 depression which will
12
St8mine Mills Supeffund Site: Aesponsiveness Summary
-------
ultimately result from the punpIng ~ groundWater from the bedI'oC* aquifer at the Site
wOI ikely C8&.M the ~er ~ i1 ~ IOiIs to be lowered. The wells
InIt8II8d 8S part ~ the vaa.un 8dr8Ction tyIIem would be placed above the bedrock
M8c8 and the seasonally 811tur8ted ~ to nan that they 81'8 aboYe any
po&sible aannted conditions. Should this 2' zone b8com8 d8w8!ered. the zone of
WIu8nC8 for the IDdr8dion 1YIIem. . propo88d. would Ik8Iy remove vOCa from the
are CJII8rtud8n 8OiII1ncIuding the lower few feet.
Comment 18: ADEM quesdo.l8d what II the maximum time ecpeded to meet the
objectJYes for the TeE IpiII ... given the ecpect8d d8a ease i1 coruminart removal
r8t. and the pcaibiDty f1 pulsed flow ~ the vnIng tyStem.
EPA Reaponae: . II 8ItIm8t8d IhIII Wm take appcOlClm8lely one year to 8Chi8Ye the
8011 cleanup levels i1 the TCE 8PiI area using the 101 venting system. Monitoring of
the system" performance during the openItIonaI period will den'.o.... ~e the
effectiveness ~ the vaaun 8XII'8Ction system i111Ch1eving the cleanup goals and the
need,' any, b extending the period ~ operation. It II 8I1tidpated that initially during
the cleanup period the soil venting syaem woutd be operated on . continuous basis.
As cteanup levels In the IOiI are approached, It may be men effective to change to an
Intermittent type of operation to allow for the equllibnltlon of 1011 and alr-pore
concentrations. The estimate of one year II believed to reflect. . present. EPA's best
estimate for the total time to achieve cteanup assuming both . continuous and
Intermittent operation ~ the I0Il venting system. Further terM I8In8t'1t of the cleanup
time wo~ld only be 8V8i1able after the operation of the system had been initiated and
field data was available.
Commentt Reglrdlng Appllclble or Rel8V8llf and Appropriate Requirement.
Comment 19: In discussions of the overall Site remedy the Rhode Island Rules and
Regulations for Solid Waste Management FaciUties are net consiStently referenced.
These regulations win govern the aorting and disposal of the building debris during
this stage of the remedy. RlDEM asked I the extensive sorting and char8Cterization
operations anticIp8ted . the SIte were conskSer8d In the estimates of the costs for the
overall Site cIe8rHJp alternatives
EPA Response: The IOI1ing Ind 8IP8f8dng of buDding debris were conaider8d during
the prep8f'8Iion for cost 8StIm8I8S for the overall SIte remedy.
Comment 20: ADEM stated that EPA should r'lfentnC8 EPA uf8c8 water discharge
lImItationS on total residual chIortn8 when evaluadng campIIance.
EPA Responae: Infonn8Iion 8V8IIIbIe from the d8sIgnerI of the UV/hydrogen peroxide
treatrnera tyIIem Indicates that very ImIIIImCUU of he c:hIorid8 Ions are generated
during the Ir88tm8r1t proc 8n which Ikely go on to form 8ImpIe 88ItS. The vendor has
Indicated that no r8SiduaI chIortn8 is produced by the process. Therefore, residual
chlorine levels i1 the eftIuent from the groundwater treatJ!18"I unit are net expected to
change for IeY8tI found in the InftuenL Any discharges from the system to surface
W8tera will meet all applicable discharge limitations.
sr,mif\P Mill' .~uperfund Site: Responsiveness Summary
. . . . ".,~.
~.~ .', ,'", ,"" ..' '.., !It''';< ..,
-------
Commena Regarding Operation and llalntenance R8.pomIbII1ll8. and Colt.
Commem 21: RlDEM questioned the ICOp8 8nd br88dth 0I1ong-t&nn umpIing,
Inspection, and maintenance programs for the Site 8nd the cost 8Stim8tes for those
programs.
EPA Response: The C08I8 lISSOCiMed wkh oper8don 8nd mainten8nC8, which Indude
aampIing, nspectior.. 8nd other malnt8n8nC8 8CtMti88, 8nd which .. ~8d In the
Feasibility Study are preliminary In nah.n 8nd will be refined during the ~
design phase. The COItI and costing procedc.nI were deY8Iop8d from the 88lected
references tabulated on thelall page of AppendIx C to the F..1bR1fy Study. Annual
O&M COlt and present worth O&M COlt .. enum81'8184 In AppendIx C, along with
aarnpIe cab IlatIOrW. The COlt 8Stim8tIng aunpdor8 we 1It8d In the Basic Column
of each table In AppendIx C. For example, qu8I18rty monitoring II 8IU'n8d and
groundwater monitoring sampling parameters IncllIded the target compound 1st for
YOIatile organic compounds, the target anaIyte list for metals, dieldrin, pH, temperature,
specific conductance, and chlorides. The O&M contingency costs for each alternative
were assumed to be 1 percent of the capitol cost. Equipment, labor and material cost
estimates are detailed In Appendix C.
Comment 22: RIDEM questioned what type 0I1nsuranc8 would be ~''Y and/or
Is planned for the remedial activities.
EPA Response: In general, the contractor should procure and maintain the following
types 01 Insurance:
Workmen's compensation Insurance In amounts to ..!sty State law;
Comprehensive genera/liability Insurance for bodily Injury, death or
loss of or damage to property of third persons In the minimum amount
at $1,000,000 per occurrence.
Subject to certain restrictions, Section 119 of the Superfund Amendments and
Reauthorization Act 011986, authorizes EPA to provide Indemnific8tion to response
action contractors working at Supetfund lites for EPA, States and potertJally
responsible parties. Response IICtion comactors must demoIAIt).e to EPA that they .
have made diligent efforts to obtain InIur8nc8 CCMng8 from non-F8d8r8l1OUrC8S to
COY8I' pollution lability b8for8 they C8n receive F8der8l1ndernnIIicatio
8
8
Comment 23: ADEM liked whII dIgrII of proJICt II\INIg8fIWt II ~Id and
noted that the COlt .aim8ted for project management ~ EPA 888m8 high.
EPA Response: EPA anticipates thai during construCtIon and It8rtup d the rM18dy,
day to day on-sae prci8c:t management by EPA', oversight oo.~-.tor or prtnctpaI
\iOt~actor wI1l be nee.sary. The cost 8Stim8ted for project management II .
8PPfOPriate for the cost comparisonI candllCted dLI1ng the F..~1ty Study 8nd falls
below the 8Yerage annual CMKSIght cost for remedial design and construetion proIedS
conducted In Region I.
14
Stamina Mills Superfund Site: ResponsNen&$$ Summary
-------
Commena RegatrIIng Future U.. fII the SIt.
Commem 24: RlDEM questIG18d the ... to which the ~ use d the Stamina
MUll propeny would be restria8d, 8nd vm. Ip8Gfic 8dmInistnItive \iOI ~ oIs were
envisioned for the Sle end/Ot ano&.nding 81'88.
EPA Response: ~ COtf)08 MUd belmpl8m8rUd to rnaIrUin the owrall
protection d tunan health 8I1d the erMCM""" believed to be 8fforded by this
remedy. EPA h8I propcI88d, In . ccnn d8cr88 lodged In F8d8r8I Court. Institutional
co.lboll with the CUT8It owner - Hydfo.MarU8cnn1g - to protect the remedy. It
8houId also be noted that the local ~ may h8v8 the authority to Implement
. and ~ natb.aioNd oo.lbollt 1UCh. deed 1'8Ib1ttIDc8, natiC8S, 81d building
permit I"~ IlL ..
Part 111 - Summary of Potentially Ruponalble Party Commenta
Kayser-Roth, the principal PAP 81 the Sle, provided written and oral comments
which are summarized below:
1.
ex-situ bioremediation was not addr8s18d during the anatysis d possible
groundwater treatment alternatives. Kayser-Roth recommended that
bioremediation be formally analyzed as . tr88Im8nt alternative.
EPA Response: EPA, consistert with the NCP, d8Y8Ioped . Imlted number of
remediation alternatives that would 8Itain aite-spedfic remediatiOn levels for the
groundwater response ICtion. ex-situ bIontm8dIatlor\ wa not one of the technologies
considered In the FS as . potential alternative because . would not IttaIn site-specific
remediation levels. Pilol testing completed. ath8r 8ft. h811hown that ex-situ
bior8mediation 18 not 8If8Ctiv8 In degrading TCE 8nd ath8r chlorinated aotvents which
were the principal contaminants found In 1M groundwater plume . the site. In these
studies, chlorinated IOIY8nt8 went found to be primarUy removed through uncontrolled
YOIatllizatlon r8Iher th8n through treatment. R8centJy piIat-8C818 studies have been
completed using . vart8Iion of ec-altu bIodegr8d8tIon. In which an anaerobic
envtronmert II maIrUIned 8nd . ~. II addId. 1NI prGClII hils been
ahown to be IftICtIva In d8ItrOytng TeE and ath8r chIor'.88d 8dv8ntS hough
biodegradation for ec-8ltu and In-8Iu appIic8tIoI8. 88C8I.. the anaerobic ex-situ
bIor8mediatJon ItDI requires extensive piIat-work b8for8 . would be 8V8I1abIe for a full-
8C8Ie operation . the Site, It was not consider8d for ttw.8ft..
2.
Slllction of the IN/peraxIde t8CI'i1oIogy for the ....tl8IT8d ahrn8dve 18 based
on .-bemely limited t81ting. No plat Ibdel... condIlCt8d tor pretreatment.
No provision for pH adjuItm8nt . either the Inftuert or 8fIIuent has been
made, nor have the costs lISSOCi8ted with these 8djlAtments been considered.
EPA Response: Costs estimated for the IN/hydrogen peroxide groundwater
treatment system were c:aJcul8ted using the high end 01 the range 01 treatment COStS'
prcMded tJ'f the vendor lifter conducting a treatability ItUdy for this purpose. Pilot
StamifJIJ Mills Superfund Site: . Responsiveness Summary
15
-------
testing would be conducted prior to full scaJe start-up to assure that groundwater
ARARs and disposal option ARARs for treated groundwater would be met using the
recommended pressunHiltration system for prElUeatment. The pilot test would occur
during pr~n and would use the UV /hydrogen peroxide system to treat
contaminated groundwater generated during the on-site pump test. The costs for pH
adjustment were not considered In the total costs esdmaIed for the UV/hydrogen
peroxide system bec~1 1M the results aI the treal8bi11ty test, using groundwater from
the Site, indicated thai the system would meet groundwater cleanup I8vets In a
reasonable time frame without the need for pH adjustment. Cost estimates In the
Feasibility Study are judged to be within the +50 percent to.3() ~ accuracy
range, recommended In EPA'a Guidance for Conducting Remedial Investigations end
Feasibility Studies Under CERCLA (EPA/54C/G-89/(J(U) fOr alternatives under
consideration.
3.
Preliminary groundwater modeling used to determine groundwater cleanup
times may be inaccurate and result in Significantly underestimated costs.
EPA Response: A pump test, conducted using a community well system near the Site,
Indicated that a maximum yield of 10 gallons per minute (gpm) could be obtained from
the existing well located In the bedrock aquifer on a long term basis. This flow rate of
10 gpm was used in the preliminary modeling effort to estimate the cleanup time for
the groundwater contaminant plume. The groundwater extraction system has been
conceptualized to consist aI more than one extraction well with combined pumping
rates that may exceed 10 gpm. Because aI the subsurface conditions existing at the
Site and the difficulty they present in obtaining a high groundwater yield over an
extended period of time, a short duration-high yield pumping activity, known as
pulsed-pumping was also considered for the Site. Using a pulsed-pumping scenario,
a combined pumping rate aI as high as 40 gpm was considered feasible for the Site
for short durations. Therefore, for costing purposes, It was assumed that the
treatment system should be designed to handle a potential maximum combined
pumping rate, assumed at this stage to be 40 gpm. EPA believes that the information
used to estim~e the cteanup time frame and the cost aI the groundwater extraction
and treatment system is reasonable given the Information currently available. EPA will
update its estimates for cleanup time and cost as more Information becomes available
upon completing the prHJeslgn pump test.
4.
A risk assessment should be undertaken to determine If air discharges from
the proposed treatment technologies which have air emissions are In
compliance with Applicable or Relevant and Appropriate Requirements before
a decision is made on whether to use or not to use control devices.
EPA Response: A risk assessment 18 net necnnry to determine I air emissions will
meet the RI ARARS without the use 01 air emission control devices (e.g., vapor phase
activated carbon) because the acceptable limits for air emissions are dearly Identified
in these regulations and untreated air emissions from an air stripper would exceed
them. Calculations for air emissions from an air stripping tower are Included in
Appendix B aI the FS and are based upon the levels at which TCE and other VOCs
16
Stamina Mills Superfund Site: . Responsiveness Summary
-------
found in the groundwater on-site would be diseharged to the atmosphere. The
disCharge levels exceed AI ARARs established to regulate the emissionS 01 these
compounds and require the use 01 some type 01 control device to reduce discharge
levels. Art additional State ARAR requires that a "new SOUrce" 01 air emissions use
beSt available control technology (BACT) to control 8nJ emissions. As the air stripper
would be considered. "new source" . would be required to use BACT which at
present time Is . vapor phase carbon filter as proposed In the FS.
5.
The soil vacuum 8Xb'action aystem proposed for the TCE spin area should be
readdr8SSed lifter pilot study data are available to estimate the operation time
~ If. longer operation time is required, more operations and
maktenance funds need to be 8aocaIed.
EPA Response: Site-specific technical data wiD be obtained as part 01 the soil vapor
extraction system design. The shak&-down operational period 01 the system prior to
full scme operation will better define the estimated time to reach the cleanup goals
and help optimize the system. During the time frame the system is to be operated, its
perfonnance will be evaluated and the time to achieve cleanup levels will be re-
examined as operational data becomes available.
6.
All potentially hazardous on-site demolition debris and excavated material
should be placed under the cap for the landfill, unless they are subject to the
landfill ban, In order to reduce 1he expenses 01 oft.site transport and disposal.
EPA Response: As suggested in this comment, disposing 01 r\lbble and other
potentially hazardous matkia8 in the landfill could result In lower disposal costs than
off-site disposal. However, the State solid 8\d hazardous waste regulations place
limitations on what disposal may take piace at the Site. Movement and disposal of the
hazardous waste from outside the landfill Into the landfill area would constitute
designation as a new land disposal facility and would be prohibited under the State
hazardous waste regulations. Rhode Island Solid Waste Regulations allow for rubble.
consisting 01 materials 01 an earthen origin (I.e., bricks, cona ete) to be disposed of
on-site. However, all other non-hazardouS debris must be disposed 01 oft-site at a
RJDEM approved facUity.
7.
A higher Interest rate than recommended In EPA guidance documents was
used for calculating the net presera worth 01 operation and maintenance,
thereby resulting In an undet estimate 01 the cost.
EPA Response: The Feasibility Study cost estimates are expected to provide an
accuracy 01 +50 percent to -30 percent and fall within the range recommended in
EPA's Guidance for Conducting RemfK1isJ Investigations and HJ8sibility Studies Under
CERCLA (EPA/540/G-89/()(u) for alternatives under consideration. Although EPA
Guidance dated October 1988, recommends a discount rate 01 5 percent, It also notes
that a rate 01 3 percent to 10 percent may be used to compare alternative costs. EP A
in this case followed OMB Circular A.94 as specified In the National Contingency Plan.
effective April 9, 1990. OMB Circular A.94 prescribes . standard discount rate 01 10
Stamina Mills Superfund Site: Responsiveness Summ81Y
.....,.. ~ ~..,
-------
percent which represents an estimate of the average rate of retum on private
Investment before taxes and after inflation. Since the ten percent discount rate was
used in the cost estimates for each alternative, the relative estimated costs are
appropriate for comparison of alternatives. .
8.
ConduSions drawn from the results of the 8qulfer testing were vague and
contradictOfY. No water.-vellnforrn8tk)n W88 obtained from thelOUth side of
the Branch River to demoI '5b &te ~bIe hydraurlC Interconnection. The
aquifer test results were used In groundwater modeling for 88tJmating pumping
rates and cteanup times. These misleading conclusions may affect the overall
cost of the cteanup.
.
EPA Response: EPA believes that the conclusions drawn from the I'8SUIIs of the
aquifer test were not vague. contradiday 01 misleading. EPA also believes the results
of the aquifer testing ""'" 611111 the hyc:lr8u\ic comection between the Site and the
residential area to the north of the Site.
For the preliminary evaluation of the remediation system, It was assumed that a
continuous pumping rate of 10 gpm or total daily withdrawal of 14,400 gpd would not
result in river water being captured by the recovery system and undergoing treatment.
A simplified analysis of the potential downgradient stagnation Point for a single well
pumping at 10 gpm was conducted. This analysis suggested that the capture zone
for a well positioned. the location of MW-2 would not extend to the Branch River.
The fineD design and operation of the recovery system will be based on the results and
analysis of the pre-design pump test. The system will be designed to maximize the
volume of contaminated water extracted and minimize the capture and treatment of
clean water, thereby minimizing cleanup times.
w.
Remaining Concerns
Issues raised during the public comment period that will continua to be of
concem as the Site moves Into the RDIRA phase are listed below. EPA will continua
to address these issues as more Information becomes available during the RD/RA.
1.
'The effectiveness ~ the groundwater monitoring program.
Site appearance and future potential use of the Site.
2.
3.
Treatment of leachate at the local wastewater treatment plant and
potentiallmpadS on the local sewer line on-site.
Effectiveness of the remediation and any effects of the remediation on
the aquifer.
4.
5.
Tming of the start of the remediation and the time to meeting the
deanup goals for the Site.
18
Stamina Mills Superfund Site: Responsiveness Summary
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Attachment A
Community AeI8tIon8 ActIvItI.. Conducted at the Stamina MIII8 Superfund Sit.
14 September 1984
24 September 1984
27 November 1984
,. February 1986
.. March 1986
10 March 1986
.. May 1986
.. December 1986
.. February 1990
21 February 1990
29 June 1990
5 July 1990
10 July 1990
31 July 1990
11 July 1990 -
9 August 1990
28 September 1990
Pr... Ael.... announcing 24 September public meeting
Public MHUng' announcing availability of bottled water and
weU test results
Pr... Aele... on alternate water supply and EPA funding
Pre.. Aele... announclr.g 10 March public meeting
F.ct Sheet on start of Remedial Investigation
Public Meeting on start of Remedial Investigation
F.ct Sheet on progress and continuing activities of Remedial
Investigation
Community Aelatlona PI.n completed
F.ct Sheet on results of Remedial Investigation
Public Meeting on results of Remedial Investigation
Public Notice of Proposed Plan and Public Comment Period
PropoMd PI.n published
Public Meeting on Proposed Plan and Feasibility Study
Inform.1 Public H..rlng on Proposed Plan and Feasibility
Study
Public Comment Period
-------
Attachment B
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UNITED STATES OF AMERICA
I
1 i
1 - 221
I
I
2
ENVIRONMENTAL PROTECTION AGENCY
3
BOSTON REGION
4
5
In th~ Matter of:
6
INFORMAL PUBLIC HEARING
STAMINA MILLS SUPERFUND SITE
7
8
9
10
Municipal Annex
575 Smithfield Road
~orth Smithfield, Rhode Island
11
12
Tuesday
July 31, 1990
13
14
The above entitled matter came on for hearing,
15
pursuant to Notice at 7:35 p.m.
16
17
RICHARD C. BOYNTON
NEIL HANDLER
U.S. Environmental Protection Agency
BEFORE:
18
19
20
21
22
23
24
25
TERRENCE GRAY
R.I. Department of Environmental Management
APEX REPORTING
Registered Professional Reporters
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;-
l~QE~
2 f~g5
3 Richard Boynton 3
..
4 Neil Handler 5
':
5 Terrance Gray 10
6 Deming Sherman 12
7 Mich..l Hauptman 13
8 Paul Kelly 16
9 Lynda Masnyk 18
10
11
12
13
14
15
15
17
18
19
20
21
22
23
24
25
APEX REPORTING
Registered Professional Reporters
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3
e8gc;~~Ql~g~
2
713~ P.",.
3
MR. BOVNTON.
Good ev.ning.
My na~ i. Richard C.
4
Boynton, and 1'. the chief of EPA Rhode l.l~ndSuperfund
5
S.ction.
1 hay. supervi.ory responsibiliti.s for EPA
6
.r.spons. actions at Sup.rfund sites in Rhode Isl~nd.
7
Tonight w. ar. h.r. to conduct .n informal public
8
hearing, to r.ceive all comm.nts on the Stamin~ Mills
9
f..sibility study .nd propos.d cl.~n up grant for the site.
10
I will ..rv. a. a h~aring officer.
Also on the he~ring
11
pan.l with m., to my far right.N.il Handl.r, the EPA project
12
m~nager for the Stamina Mills .it..
And to my immediate
13
right T.rry Gray of the Rhode I.land Depar~ment of
14
Environ~.ntal Management.
I would also like to introduce Jim Saba.tian, our
15
16
Office of Public Affairs Community Relations Coordinator,
17
who i. 1n the r.ar of the room.
And also Nancy Andrews of
18
the Army Corps 01 Engine.rs, sitting in the front right.
19
EPA held an informational m..ting on Tuesday evening,
20
July 10th in this room, to pre..nt infor.ation about the
21
evaluation of alternative. 10r the clean up of the St~mina
22
Mills .it., and the pr.ferr.d plan for the cl.an up of the
23
site.
24
Th. public comment period began on t~ next day, July
11, and will run for .30 days, and .close on August 9th.
2S
APEX REPORTING
Registered Pr01.ssion~1 R.porters
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4
Now I would like to de.cribe the hearing format for
2
vou.
We will be~in with a brief presentation bV Neil
3
Handler, de.cribing the propo.ed clean up plan.
Following
4
Neil'. pre.entation we will accept all comments, anV and all
5
comment. you wi.h to make for the record.
The panel ",ay
6
Also ask some que.tion., ~n order to clarifv the comments.
We will prepare. written respon.e to each and every
7
8
comment received tOrt.i...,:.t, 1"""" i.ncl,",- the written re.pon..s
9
with EPA'. final deci.ion.
10
When 811 comments have been heard I will clo..
11
tonight's hearing.
If you wish to submit written com..nts,
12
you may submit them until Augu.t 9th, to the addre.. on p.ge
13
two of the proposed clean up plan document.
Copies of the
14
plan are available at the r.ar of the r~~m, if you need
15
them.
16
At the conclusion of the hearing pleas. feel free to
17
address any que.tion. you may have about the cle.n up plan
18
or the decision making proc.ss to the EPA repre.entative.
19
that are here tonight.
20
For those of you wi.hing to ",ake . comment tonight, you
21
.hould hay. filled out an index card, available at the rear
22
of the
room.
If you have not completed. card and wish to
23
make a comment, plea.. see Jim Seba.tian at the rear of the
24
room, and complete an index
card.
25
I will call upon tho.e who wish to make a comment in
APEX REPORTING
Registered Profe..ional Reporter.
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5
"the order in which they filled out the index cards.
When
2
called upon, please come forward to the ~icrophone on the
3
podium, and state your name and affiliation.
I ask you to
4
do this because we are transcribing the hearing for the
5
record, and this will help our recorder to keep an accurate
6
record of the proceedings.
7
If you have a prepared statement with you, please
8
submit it to the panel.
9
The tY~n.cript of tonight's hearing will be mad.
10
available, with the administrative record, at the North
11
Smithfield Public Library at 20 Main Street, and at the EPA
12,
Record Center, 90 Canal Street, Bo.ton, "a.5.
A transcript
13
will be available in one or two weeks after tonight's
14
hearing.
15
As I mentioned, EPA will prepare a response to all
16
written comments received during the comment period, and
17
will include the response summary with a record of 'decision.
18
Now I'd like to ask Neil to give an over of the
19
propu..u c'~~~ up plan.
Neil.
20
MR. HANDLER.
As Dick mentioned, .y name i. Neil
21
Handler, and I'm the project .anager for EPA, for the
22
Stamina "ills Superfund site.
And I'd like to briefly
23
d.scribe to you just what the EPA'. proposed preferred
24
alternative, which addre.se. dealing with the clean up of
2S
this Stamina Mills Superfund site, is.,
APEX REPORTING
Registered Professional Reporters
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6
80 I gUess the pl.ce to st.rt then is just to briefly
2
identify the are.s that EPA focu5ed in on during th.ir
3
remedial inv.stigation and feasibility study, .nd ca.e up
4
with cle.n up altern.tives for.
5
First of all, th.re are pri..rily four are.s of the
A
~ite.
The first are. is a spill .r.a, which was located
~
7
directly east of the former mill building number
one.
In
8
that location an unknown quantity of TCE, or
9
trichlorethylene, wa. spilled.
10
Another area that i. addressed as part of this
11
preferred alternative is the landfill area, which is located
12
in the eastern section of the site, adjacent to the Branch
13
River there.
14
And the third area of the site is the overall site
15
it.elf, which consist. of rubble piles, partially standing
16
buildings, deteriorating smokestack adjacent to the river,
17
and two physical structures known as race ways, which run
18
through the site, and used to convey water through the site
19
for hydro-mechanical power.
20
In addition to those thr.e area., the final area which
21
ha. b.en impacted by the .ite i. the groundwater beneath t~le
22
site, which the TCE which was spilled at the site, ended up
23
infiltrating through the soil, .nd getting into the bedrock
24
aquifer beneath the site, and ended up being pulled offslte
25
by the pumping action of some of the residential wells north
APEX REPORTING
Registered Prof.ssion.l Reporters
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7
of the .it..
2
So, with th@.e area. identified, EPA put togeth.r a
f.a.ibility .tudy, and from the f.a.ibility .tudy .„Al~~~
3
4
all the alt.rnativ.. for the .ite, and came up with a .erie.
5
of f1nal alt.rnativ.. that w. .valuated 1n d.tail.
And
6
these alternative. addr... the different ar.a. that I just
:
7
And I'd lik. to bri.fly go through th.m, to give
m.ntioned.
8
you .om. idea of what alt.rnative. we looked at.
9
On this overhead you will... that some
Ju.t one not..
10
of the alternativ.. have. little a.teri.k n..t to them, and
11
that'. to indicat. that tho.. ar. the propo..d preferred
12
alternative. that EPA ha. preYiou.ly mentioned, and we'r.
13
int.r..ted in your comments on.
14
For the TCE, or the trichlorethylen..pill .r.a, EPA
15
looked at on-.ite incin.ration for this ar.a.
Th. final
16
alternative. that were .valuated for this area came down to
17
these two alternative., and the.e included the on-.ite
18
incineration and the .oil treatment by vacuum extraction, as
19
well as the no action alternative, which ..rv.s as a
20
b...line alternative, which we compare all other
21
alternative. to for thAt treatm.nt.
22
For the landfilled .rea, we considered on-site
23
incineration.
And again the pref.rred alt.rnative that i~
24
being proposed by EPA is an impermeable cap for the landfl11
25
area.
APEX REPORTING
Registered Prof.s.ional Reporter.
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8
In addition, ag~n, for each one 01 these alternative.
2
we are required by the statute~ to carry through a no-action
3
alternative.
4
For the groundwater at the site, the treat~ent
5
technologies that EPA eyaluated in detail were air-
6
stripping, carbon treatment, and then, again, the propoBed
:
7
preferred alternatiye was treatment by ultra-violet light
8
and hydrogen peroxide.
And then the final, the no-action
9
for the groundwater.
10
For the oyerall site, in dealing with the buildings and
11
rac. ways, and the septic tank at the site, the alternatiyes
that EPA considered were to demolish the-site structures,
12
13
s.al and 1111 the race ways, and backfill the race ways.
T~
14
locate the septic tank and treat its contents, and then
15
grade and. seed on the 8ite, and improve the fencing.
This
16
was EPA'B proposed preferred alternative there.
17
And the other final alternatiye for dealing with the
18
overall site pretty much follows the first overall site
19
alternative, except 1n addition we would look at addressing
20
an area where there were some eleYated leyels of PH's, which
21
are poly-cyclic aromatic hydrocarbon., which are a compound,
22
which we found some elevated levels, in an area adjacent to
23
the dam.
And then there is the no-action.
24
So, to briefly summarize EPA's preferred alternative,
25
and what it's attempting to deal with, we haye tor the
APEX REPORTING
Registered Professional Reporters
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9
trichlorethylene spill .re., which has been identified a. .n
2
area which i. the .ource of cont.min.tion to the groundw.ter
3
bene.th the .ite, .. well a. off-site.
EPA i. propo.1n9 to
4
u.e soil treat~ent by vacuum e~traction.
And this would
5
cons1.t of 1n.ta111ng a number of well. into that are., and
6
t~en withdrawing the .ir from the soil, the air th.t's in
7
cont.ct with the soli, and tre.tin9 this air, which would
8
contain the compound trichlorethylene.
9
And for the landfill area, EPA
is proposing to use an
10
imperme.ble c.p in th.t area, to prevent the migration 01
11
cont.min.nt. from the landfill into the Branch River, a.
12
well .5 to reduce the amount 01 groundw.ter, which i.
13
infiltr.t1n9 through the landfill, and impacting the
14
groundw.ter ben..th, the site.
15
For the 9roundwater itself, on-site and off-site, EPA
16
is proposing to install. number of extr.ction wells, in the
17
vicinity of the site, and the exact number and location will
18
be determined once we've completed a pump test at the site.
19
But this technology, ultra-violet light,. and hydrogen
20
peroxide, completely destroy. the compound. that we're
21
.eeing at the .ite, and ba.ically would Just leave carbon
22
dioxide and water, and chloride salt~ a. the residue f,unl
23
the chlorinated solvent., trichlorethylene and .0Me of 1t~
24
bre.kdown product., that we are seeing at the site in the
25
groundwater.
APEX REPORTING
Registered Profe.sional Reporters
(617)426-3077
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1('1
For the over.ll site, EPA'. preferred .lternative
2
considers demolishing all the sit. structures, se.ling .nd
3
b.ckfilllng the rac. ways, and loc.tlng the septic tank at
4
the site, and tre.ting its contents.
5
I gu.ss I shOuld just point out that the s.ptic tank,
6
the re.son why we h.ven't loc.ted it, it's beneath one of
..
7
the l.rg. pil.s of rubble at the site.
We bttlievtt it's
8
beneath th.t pile.
9
In addition, once all the activities at the site are
10
completed, we would grade the.e areas and seed them, and
11
improve the site fencing.
12
And the tot.l cost for the proposed preferred
13
alternative is approxim.tely .4.3 million.
14
As I s.id,
I briefly just tried to present this.
Mor\!
15
details can be found in the feasibility study and in the
16
remedial investigation,
which are available at the
17
Smithfield Public Library.
18
MR. BOYNTON.
Thank you, Neil.
19
Now I would like to begin comments with Terry Gray,
20
representing the Rhode Island Department of Environmental
21
f'lAna;em.nt.
22
MR. GRAY.
Good evening.
Hi.
My name is Terrance
23
Gr.y.
I'm a principal engineer with the Dep.rtment's
24
Division of Air .nd Hazardous M.terials.
25
Initially, I would like to state that the Department
APEX REPORTING
Registered Protes.ional Reporters
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1 1
agree. that EPA'. preferred remedial alternatives have
2
addre..ed the different aspects of .ite cont~min~tion, and
3
will be protective of human he~lth in the environment.
4
w. do, however, h~ve .ome issues which we'd like to .ee
5
addre..ed a. p~rt of the record 01 this h.aring for the
6
.ite.
7
Our primary con~.rn i. directed at the implementation
8
~f the pro~osed groundw.ter remediation.
The Department
9
agr... that groundwat.r remedial action .hould progres.
10
toward achieving appropriate groundwater qu~lity st~nd~rd..
11
In the ia.e of the Stamina Mills .it., attainment of
12
drinking water quality .tand~rds is our desired initi~l
13
However, b~sed on the inform~tion presented to
objective.
14
date, there are many uncertainties a..ociated with the
15
technical feasibility and associated costs 01 achieving
16
drinking water quality stand~rds in the bedrock aquifer at
17
this site.
18
Specifically, the uncertainties here a..ociated with
19
the technical ability to reach ~nd maintain drinking water
20
quality standard., and the time frame that may be necessary
21
to achieve that cl.an up go. 1.
22
We believe the pr.f.rred alternative, and record of
23
decision, .hould reflect th..e uncertainties by specifically
24
including. performance review to be conducted sometime
2S
within five year. of the initiation of the cho.en
APEX REPORTING
Regi.tered Professional Reporters
(617)426-3077
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, ...
groundwAter remedy.
And an alternate or contingent remedy
2
to be implemented if the performance review indicates thAt
3
the initiation of the chosen groundwater r..edy is not
4
making satisfactory progress towards ",eeting the remedial
5
objective.
5
This is consistent w~th language proposed in the RIDEM
draft groundwater regulations, which allow for the
7
8
reclassification of an aquifer, should it become apparent
9
that it is not technical feasible or financially beneficial
10
to continue actively tre~ting the groundwater.
11
Given the aforementioned uncertainties, this Department
12
will commit state resources, provided there is ~n ~dequate
13
degree of flexibility to amend clean up goals, as additi~nal
14
information is obtained.
15
We also have specific comments and questions on the
16
alternatives evaluated in the feasibility study in the
17
preferred alternative,
included in a letter submitted to the
18
EPA for the administrative record.
I have copies of that
19
letter available ~unAgh~. ~f anyone wishes to see one.
20
Thank you.
21
MR. BOYNTONI
Th.nk you, T.rry.
Now I'd like to call
22
Deming Sherman.
23
MR. SHERMAN:
Yes.
My name is Deming
-------
13
This evening I have with me Mr. Michael Hauptman
2
(H-a-u-p-t-m-a-n) of the consulting firm of Gerrity and
3
Miller, who has b.en retain8d by Kays.r Roth Corporation to
review the proposed clean up plan, and c~mment on it.
..
5
It is our intention tonight for Mr. Hauptman to make
6
certain comments.
The.e comments will be followed by a
7
formal written pre.entation to the EPA on or before August
8
9, t 990.
9
I wish to state at the outset that Kayser Roth
10
Corporation has been held liable for past and future clean
11
up costs relating to the Stamina Mills site.
Kayser Roth
12
ha. appealed the Judgment of the district court in which
13
liability was found, and that appeal is pending.
14
By making the comment. tonight, on or before August ~,
1S
Kayser Roth Corporation is not in any way conceding its
16
liability for the expenses for this plan.
$0 that these
17
comments are offered without prejudice to our legal position'
18
that is being asserted in the court..
However, we thought
19
. it would be prudent and useful to pre.ent our comments on
20
the proposed plan, despite the fact that the final
21
adjudication is not complete.
22
So, with that caveat, I would like to pre.ent Mr.
23
Hauptman, who will make some comments at this point.
24
MR. HAUPTMAN.
Thank you.
Good evening, everyone.
My
25
name is Micl".ael "'uptman frc.m Gerrity 'Miller, and on be~lal f
APEX REPORTING
Registered Profes.ional Reporters
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14
of ~.yser Roth Corporation I'd like to give you a few
2
technical
These are just the highlights.
comments.
We will
3
~ ~~:!.wn"ing
the formal written comments at a later d.te.
4
:.
First of all, in general, I'd like to say that there
are. lot of data gaps in the fe.sibility study, which we'd
5
6
like to see filled at some time.
.
7
Now specifically one of the technologies that w.s not
8
considered, and we didn't understand why, for the
9
groundw.ter, was bio-remediation, ex situ bio-remedi.tion,
10
which me.ns you would withdraw the groundwater from the
11
.quifer.
And instead of treating it with carbon or with the
12
UV system, you would tr..t it with. biologic.l reactor.
13
As f.r as the UV/peroxide, this is where one of the
14
.dat. g.ps occurred.
We weren't sure why the recommended
15
.ltern.tive proceeded with this particular p.rt, because
16
there was only one sample sent to the laboratory in the
17
pilot test.
The Tucson Labor.tory only performed their
18
testing on one s.mple.
19
Another .spect to. the UV/peroxide system. is that there
20
will be pre-treatment required to remove iron and manganese,
21
And other metal. occurring naturally.
And the feasibility
22
study, .s well as the report by the Tucson firm, stated
23
this.
But there was no pilot testing or pre-treatment
24
testing done for this.
And we feel that the costs may be
25
under-estimated because of that.
APEX REPORTING
Registered Profession.1 Reporters
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15
Moving on to the overall site, the preferred
2
alternative says that the rubble will be carted off-site.
3
And we think that there i. really no reason not to put it
4
into the landfill.
5
Another comment, as far a. clean up time is concerned.
6
The modelling that was do~e in the FS was an analytical
7
model. It was very simplistic, and we think that the time
was too .hort, because they used an exponential model that
went to zero. In ~ost cases we've seen that those
8
9
10
concentrations become asyntotic at some level.
And if this
11
level is above ARARs for example, then carbon treatment
12
woyld have to be continyed.
And we didn't see this
13
reflected in the cost estimate.
14
As far as turning to the cost estimate, the feasibility
15
e+....y used a ten percent discount factor in calculating the
16
present worth of the operation and maintenance costs.
I
17
believe it's true that EPA recommend. using a five percent
18
discount factor.
The effect of u.ing at ten percent is that
19
the actual cost is much lower -- I ",e.n, tt.e estimate of U.e
20
actual cost i. much lower than it will be.
21
Continuing with the groundwater.
Tt.e pumping rate that
22
was used in tt.e feasibility study, to deter~ine the clean up
23
time, was at ten gallons. minute.
We feel that that is tuo
24
low for this situation.
And again it probably led to a
2S
lower cost estimate.
APEX REPORTING
Registered Professional Reporters
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16
The other thing that wasn't considered was potential
2
induced infiltration from the 8~anch River.
3
Lastly, as far as the carbon treatment of the air
4
emissions, this was eliminated.
But it seems that the
5
feasibility study assumes that 100 percent of the emissions
6
for an air stripper would have to be removed.
Rhode Island
#
7
allows a certain amount of .missions, and we thought we
8
would see at least a preliminary risk assessment, .s to what
9
the effect would be i1 some of what was stripped was allowed
10
to enter the atmosphere.
11
And that's all the comments I have.
Thank you.
12
MR. BOYNTONI
Thank you, Mr. Hauptman.
I'd 1 i ke to
13
call on Gerry Chrisman to make comments.
14
MS. CHRISMAN:
I have no comments.
15
MR. BOYNTON I
Senator Paul Kelly.
16
MR. KELLYI
I'm Senator Paul Kelly.
I represent North
17
Smi H,f ield.
18
The comments I have to ~ake are not a. technical as ~he
19
comments we've heard, but they do represent some concerns
20
that the residents have.
I'm not sure whether to place
21
these in the form of . que.tion or comment.
So I'll try to
22
place them both ways.
23
At the last hearing it was our understanding that the
24
capped wells, that the contaminant. that were emanating f~vm
25
the site, had receded back toward the site because the well~
APEX REPORTING
Registered Professional
(617)426-3077
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17
had been capped, and the affected homeowners had been tied
2
into the water system.
3
At the time I asked the question, what steps were being
4
taken, or what steps should ~ taken to assure that these
5
wells are not reactivated, because it was our understanding
6
that night that if these wells were reactivated, that the
7
contaminant. could then reactivate themselves.
And it was
8
my impression that night that no steps had been taken.
9
So again, gentlemen,
I don't know whether to put this
10
in the form of a question or Just make it as part of this
11
report.
12
I think the concern on ~he part of the homeowners
13
surrounding the contaminated sites is what steps would be
14
taken, either by EPA, or DEM, or by the town, that would not
1S
cause this site to erupt again.
16
The second is more of a legal question.
We have
17
several people in town who spent many thousands of dollars
18
to sink wells.
And these aren't wells that have been in
19
existence for twenty years or more, these were new wells.
20
And found that they could not use the wells.
They are
21
finding that EPA siting a culprit to pay for the clean up.
22
And from a very local point of view, these people are
23
wondering if there is any way, either .s . class,
or as
24
individuals, that EPA or DEM could assist them in some sort
25
of ability to recoup their financial losses.
APEX REPORTING
Registered Professional Reporters
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22
23
24
2S
18
Bec~use they sunk wells, and found out that the wells
2
had to be c~pped, and they couldn't use them.
Their out of
3
pocket expenses, from a person~l point of view, were
4
proportion~tely every bit ~s gre~t as the town, or as EPA is
S
looking at through k~yser Roth.
6
So these Are comments thAt I would like addressed, or
7
at le~st like to be considered.
And if we could receive
8
some Answers,
A. far AS wh~t steps would or should be taken,
9
~n~ U~ the people h~ve Any rights to recover losses they
10
had, we'd be more thAn gr~teful.
11
MR. BOYNTON:
I think we'll hQld the questions until
12
~fter I close the he~ring.
Th~nk you, Senator.
13
LyndA Masnyk.
14
MS. MASNYka
My nAme is lynd~ (L-y-n-d-A> M~snyk
1S
(M-A-s-n-y-k>. .
And I'm on the town council in North
16
Sm i t 1", fie 1 d .
17
And after reviewing several times the feasibility study
18
that EPA ~nd the preferred Altern~tives that EPA has come
19
up, not being an expert, and listening to the comments from
20
DEM, I certainly wOl.!ld agree that for both what EPA and DEM
21
hope to Achieve in that Ar.a, certainly would b. covered by
the ~lternative that was chosen.
My only problem with the AlternAtive, specificAlly in
the land fill
area,
is that like the other site th~t we have,
that's a Superfund site in North Smithfield, lR and R, we
APEX REPORTING
Registered Professional Reporters
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(
\
20
Smithfield in the future.
2
We have heard that this has not done anything to our
3
particular water SOurce now, that ..rves the municipal
4
system, but knowing that there is a possibility that the
5
groundwater could be cleaned up in this area, certainly
6
would be the best alternative to me.
7
1 notice that all three different alternatives, results
8
Are not particularly promised that everything would be
9
cleaned up in the tim~ frame, and it's about the same,
10 to
10
15 years.
11
So, as the gentleman from DEM said, J certainly would
12
like that situation monitored as time 90e5 on.
13
As far as the overall area, one of the comments I made
14
the last time was that the people in this are. have been
15
living with the rubble that'. pre.ent there for quite some
16
That particular area of town, as far as the Branch
time.
17
River and the Slatersville Reservoir, could be a beautiful
18
part of North Smithfield, and yet they've had to look at
19
these buildings.
20
So I would certainly hope that that particular part of
21
the clean up i5 achieved as soon a. pos.ible, and we did
22
di.cus. how lon9 a time frame it would be, as far as
23
beginning this project, and the comment was made that it
24
would be possibly two years.
25
-
I, as a town council member, would like to see that
APEX REPORTING
Registered Professional Reporters
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?1
period speeded up, so that at least the structures on the
2
site would be taken care of, so at least they wouldn't have
3
to look at the buildings they've been looking at for the
4
lAst fifl...." yP~.~..
I
I
"
5
MR. BOYNTON,
Thank you.
Are there any further
6
comments for the record?
Doe. the hearing panel have any
7
comments they wish to make?
8
Thank you for attending this hearing, and for your
9
comments.
I'd like to remind you that EPA will Accept
10
wr i tten comments postmarked before Augl.lst 9th at the address
11
in the proposed plan.
.12
Also, if you have any questions about the decision-
13
making proce.., you can call Jim Sebastian.
Jim'. phone
14
number and address are in the proposed plan.
15
Thank you aga1n for your comments and for attending the
'6
hearing.
This hearing is closed.
17
(Whereupon, the hearing in the above captioned matter
18
ended at 8:05 P.M.)
19
20
21
22
23
24
~5
APEX REPORTING
Registered Professional Reporters
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221
CERTIFICATE OF REPORTER AND TRANSCRIBER
2
3
This i8 to certify that the attached proceedings
before: U.S. ENVIRONMENTAL PROTECTION AGENCY
4
in the Matter of:
5
6
INFORMAL PUBLIC HEARING
STAMINA MILLS SUPERFUND SITE
7
8
9 Place:
10 Date:
Horth Smithfield, Rhode Island
July 31, 1990
11
vere held as herein appears, and that this 1s the true,
12
accurate and complete transcript prepared from the notes
13
and/or recordings taken
of the above entitled proceeding.
14
15
16
Lester Marshak
Reporter
8/10/1990
Date
17
Pamela Sullivan
Transcriber
8/10/1990
Date
18
19
20
21
22
23
24
25
APEX REPORTING
Registered Professional Reporters
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APPENDIX D
-------
Do..Nt I
I-
\~
State of Rhode Island and Providence Plantations
Department of Environmental Management
Office of the Director
9 Hayes Street
Providence, RI 02908
27 September 1990
Ms. Julie Belaga
Regional Administrator
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, MA 02203
Dear Ms. Belaga:
The purpose of my writing is to express the State of Rhode Island's
concurrence with the remedy detailed in the Record of Decision,
dated 28 September 1990, for the Stamina Mills Superfund site.
This concurrence is based upon all aspects of the abovementioned
Record of Decision being adequately addressed and implemented
during the design, construction and operation of the remedy. The
Department wishes to particularly emphasize the following aspects
of the Record of Decision:
The remedy as proposed and implemented must meet all
applicable and relevant and appropriate State and federal
statutes, regulations and policies.
The ground water remedial objective is to restore the
ground water to federal and state drinking water quality
standards as rapidly as possible. Should the clean up
obj ecti ve not be met wi thin ten years of the
implementation of the remedy, EPA will reevaluate the
technical feasibility and associated costs of continuing
the remedial action. Based upon that evaluation, EPA
will consider making ch~~~~~ ;n th~ remedy~
In order to maintain the overall protection of human
health and the environment believed to be afforded by the
remedy I institutional controls, in the form of deed
restrictions regulating land use, will have to be
implemented. These institutional controls, which are
necessary to protect the long-term integrity of the
remedy, must be put in place prior to the completion of
construction of the remedy. This Department cannot
unilaterally impose the necessary controls on a
landowner. Also, it is the Department's understanding
Telephone 401-277-2771, TDD 277-6800, FAX 274-7337
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that should the installation or operation of any off-site
wells adversely impact the operation of any portion of
the remedy, the EPA will take action within the scope of
their authority to correct the problem.
Also included with this letter are the state Acceptance sections
for each of the four areas of the site. Please include these
sections in the final Record of Decision.
Finally, I urge EPA to make every effort to ensure that the
responsible parties in this case will implement the remedy in a
timely and efficient manner.
Management
cc:' Merrill Hohman, Director, EPA Waste Management Division
Richard Boynton,EPA, RI Superfund 'Section
James Fester, Assistant Director for Regulation
Thomas Getz, Chief, Division of Air and Hazardous Materials
-------
state Acceotance (TSA-3.): The
Rhode
Island
Department
of
Environmental Management (RI DEM) concurs with the selection of a
soil vacuum extraction system as the source control alternative for
the TCE spill area.
state Acceotance(LA-3):
The
Rhode
Island
Department
of
Environmental Management (RI DEM) w~uld have preferred excavation
and off-site disposal of the material found in the landfill.
However the Department understands the uncertainty as to whether
any or all of that material. is actually hazardous waste and, if so,
the corresponding difficulty and expense in disposing of those
materials.
RI DEM concurs with the selection of a multi-layer cap and
leachate collection system, with institutional controls in place,
as the source control alternative for the Landfill area.
RI DEM
has informed the EPA that the Department cannot unilaterally impose
the institutional controls necessary to protect the integrity of
the landfill.
state Acceotance(GW-4):
The
Rhode
Island
Department.
of
Environmental Management (RI DEM) conCUT~ ~ith the selection of a
UV/Hydrogen
Peroxide
treatment
system
as
the
management
of
migration alternative for the ground water.
It is estimated that
this alternative should achieve the clean up levels after ten to
fifteen years of operation.
The Department is concerned, however,
with the uncertainties associated with the technical feasibility
-------
bedrock aquifer at the site.
RI DEM has emphasized, as specified
in the Record of Decision, that periodic reviews be conducted to
evaluate the performance of the system "and,
the feasibility and
cost
effectiveness
of
continued
operation of
the
system
in
aChieving the clean up levels.
Revisions to the remedy should be
made as necessary.
state AcceDtance(OS-3):
The
Rhode
Island
Department
of
Environmental Management (RI DEM) concurs with the selection of the
combination of demolition of the remaining structures on the site,
sealing of the remaining raceways,
location and removal of the
septic tank and final site grading as the management of migration
alternative selected for the overall site.
The Department has
raised concerns about potential routes of migration through the
sewer line trench and through potentially uncollapsed sections of
the raceway underneath the landfill.
This issue will be further
-------
APPBNDIX B
-------
Stamina Mills
NPL Site Administrative Record
Index
Compiled: February 12, 1990
Updated: July 10,1990
ROD Signed: September 28, 1990
Prepared for
Region I
Waste Management Division
u.s. Environmental Protection Agency
With Assistance from
AMERICAN MANAGEMENT SYSTEMS, INC.
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Introduction
This document is the Index to the Administrative Record for the Stamina Mills
National Priorities List (NPL) site. Section I of the Index cites site-specific documents, and Section
n cites guidance documents used by EP A staff in selecting a response action at the site.
The Administrative Record is available for public review at EPA Region I's Office in Boston,
Massachusetts, and at the North Smithfield Public Library, 20 Main Street, Slatersville, Rhode
Island 02895. Questions concerning the Administrative Record should be addressed to the EPA
Region I site manager.
The Administrative Record is required by the Cumprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
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Section I
-------
ADMINIsTRATIVE RECORD INDEX
for the
Stamina Mills NPL Site
1.0
Pre- Remedial
Please refer to the 1984 -1985 Removal Administrative Recordforadditionai
docUJ1lents which are included in this section by reference only.
1.18 FIT Technical Direction Documents (fDDs) and Associated Records
L
2.0
utter Report from Mark Radville,.NUS Corporation to Donald Smith, EP A
Region I (July 28, 1986). Concerning Halliwell Boulevard Site Discovery.
Removal Response
Please refer to the 1984 -1985 Removal Administrative Recordforadditionai
documents which are included in this section by reference only.
2.4
Pollution Reports (POLREPs)
1.
POLREP 1, EPA Region I (August 28,1990).
2.5 On-Scene Coordinator Reports
1.
"On-Scene Coordinator's Report," EP A Region I (March 6, 1990).
3.0
Remedial Investigation (RI)
Please refer to the 1984 -1985 Removal Administrative Recordforadditionai
documents which are included in this section by reference only.
3.2
Sampling and Analysis Data
1.
"Attachment 1- Final Volatile Organics Sampling and Analytical Plan," GHR
Engineering Associates, Inc. for U.S. Army Corps of Engineers
(August 14, 1987).
''Memorandum Report on Results of Ambient Air Monitoring for Volatile
Organics," GHR Engineering Associates, Inc. for U.S. Army Corps of
Engineers (January 29, 1988).
The map associated with the record cited in enlTy nwnber 3 is oversized and may be
reviewed, by appointment only, at EPA Region 1, Boston, Massachusetts.
2.
3.
3.4
"Report of Pump Test of the Forestdale Water Association Well," GHR
Engineering Associates, Inc. for U.S. Anny Corps of Engineers (March 1989).
Interim Deliverables
1.
2.
"Final - Site Operations, QA/QC and Site Health and Safety Plans," GHR
Engineering Associates, Inc. for U.S. Army Corps of Engineers (April 1986).
"Report of the Assessment of Soil and Groundwater Conditions in the Landfill.
Area," GHR Engineering Associates, Inc. for U.S. Army Corps of Engineers
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3.7
'Page 2
3.5
Applicable or Relevant and Appropriate Requirements (ARARs)
3.6
Ooss-Reference: Letter from James Fester, State of Rhode Island Department
of Environmental Management to Merrill S. Hohman, EPA Region I
(June 7, 1990). Concerning transmittal of the attached Applicable or Relevant
and Appropriate Requirements identified by the State of Rhode Island [Filed and
cited as entty number 1 in 4.5 Applicable or Relevant and Appropriate
Requirements (ARARs)].
Remedial Investigation (RI) ReportS
1.
"Remedial Investigation Report - Volume I - Main Text," GHR Engineering
Associates, Inc. for U.S. Army Corps of Engineers (January 1990).
"Remedial Investigation Report - Volume IIA - Appendices," GHR Engineering
Associates, Inc. for U.S. Army Corps of Engineers (January 1990).
"Remedial Investigation Report - Volume fiB - Appendices," GHR Engineering
Associates, Inc. for U.S. Army Corps of Engineers (January 1990).
"Remedial Investigation Report - Volume ill - Presentation of Analytical Data,"
GHR Engineering Associates, Inc. for U.S. Anny Corps of Engineers
(January 1990).
Work Plans and Progress Reports
1.
2.
3.
4.
1.
Letter from Robert F. Smart for S.L. Carlock, U.S. Anny Corps of Engineers
to John Hartley, Rhode Island Department of Environmental Management
(July 24, 1985). Concerning the attached Trip Report on a Visit to Stamina
Mills, Randy Petersen, U.S. Army Corps of Engineers (June 12, 1985).
"Additional Field and Laboratory Work Beyond the Existing Scope of the Final
RIlFS Work Plan dated March 18, 1986," GHR Engineering Associates, Inc.
(September 15, 1987).
2.
3.10 Endangerment Assessments
"Endangerment Assessment - Revised Phase n Draft Fmal Report,"
GCA Corporation (July 1985).
Feasibility Study (FS)
4.0
4.1
4.5
1.
Correspondence
1.
2.
Memorandum from Karen 1. Wilso~ EPA Region I to Neil Handler, EPA
Region I (May 31, 1990). Concerning ground water classification.
Memorandum from Stephen Mangio~ EPA Region I to Neil Handler, EPA
Region I (May 31, 1990). Concerning evaluation of the soil clean-up level.
Memorandum from Maureen R. McClelland, EPA Region I to Neil Handler,
EPA Region I (June 22, 1990). Concerning review of the "hot spot" area soil
sample results.
3.
Applicable or Relevant and Appropriate Requirements (ARARs)
1.
Letter from James Fester, State of Rhode Island Department of Environmental
Management to Merrill S. Hohman, EPA Region I (June 7,1990). Concerning
transmittal of the attached Applicable or Relevant and Appropriate RequirementS
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5.0
Page 3
4.6
Feasibility Study (FS) Reports
Reports
1.
2.
"Feasibility Study Repon." GHR Engineering Associates, Inc. for U.S. Anny
Corps of Engineers (June 29, 1990).
"Feasibility Study Repon - Appendices," GHR Engineering Associates, Inc. for
U.S. Army Corps of Engineers (June 29, 1990).
Lener from Uoyd Selbst, EPA Region I to Beulah Richer (July 10, 1990).
Concerning attached addendum to the Feasibility Study Report.
3.
Comments
4.9
Comments on the Feasibility Study received by EPA Region I during theformal public
comment period are filed and cited in 5 J Responsiveness Summaries.
Proposed Plans for Selected Remedial Action
Reports
1.
"EPA Proposes Cleanup Plan to Address Contamination at the Stamina Mills
Superfund Site," EPA Region I (July 1990).
Comments
Comments on the Proposed Plan received by EP A Region I during the formal public
comment period are filed and cited in 5 J Responsiveness Summaries.
Record of Decision (ROD)
5.1
Correspondence
1.
Memorandum from Don R. Clay, EPA Headquarters to EPA Regions I-X
Regional Administrators (January 29, 1990). Concerning the twenty-fIrst
remedy delegation report authorizing EP A Region I to proceed with a 1990
Record of Decision for the Stamina Mills NPL site.
"Field Investigation Report," State of Rhode Island Department of
Environmental Management (July 5, 1990).
Letter from Susan C. Svirsky, EPA Region I to Neil Handler, EPA Region I
(July 9, 1990). Concerning comments on the Ecological Risk Assessment.
Memorandum from Mark D. Sprenger, EPA Environmental R~c:~~se Branch to
Neil Handler, EPA Region I (August 22, 1990). Concerning the attached
"Analytical Repon," Roy F. Weston, Inc. (June 15, 1990).
Letter from Edward F. Sanderson, Historical Preservation Commission to Uoyd
Selbst, EP A Region I (August 28, 1990). Concerning impact of the remedy on
listing of the site on the National.Register of Historic Places.
Letter from Gordon E. Becken, U.S. Department of the Interior Fish and
Wlldlife Service to Neil Handler, EPA Region I (September 19, 1990).
Concerning comments on 1990 "Draft Record of Decision."
Memorandum from Neil Handler, EPA Region I to File (September 27, 1990).
Concerning procedures used by Region I to calculate soil cleanup levels.
2.
3.
4.
5.
6.
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5.3
5.4
Page 4
Responsi veness Summaries
1.
Cross-Reference: Responsiveness Summary, EP A Region I
(September 28, 1990) [Filed and included as Appendix C in entry number 1 in
5.4 Record of Decision (ROD)].
The following citarions indiCale written comments received by EP A Region / during
the formal public comment period.
2.
Cross-Reference: Transcript, Infonnal Public Hearing Summary, EPA Region I
(July 31, 1990) [Filed and mcluded in Appendix C in entry number I in 5.4
Record of Decision (ROD)].
Comments Dated July 31, 1990 from James Fester, State of Rhode Island
Department of Environmental Maugement on the July 1990 "EP A Proposes
Qeanup Plan to Address Contamination at the Stamina Mills Superfund Site,"
EP A Region I.
Letter from Broce H. Edelson, Kayser-Roth Corporation to Neil Handler, EP A
Region I (August 8, 1990). Concerning transmittal of the attached August 1990
"Review of Remedial Investigation and Feasibility Study Reports for the
Stamina Mills Site:' Geraghty & Miller, Inc. for Kayser-Roth Corporation.
Record of Decision (ROD)
3.
4.
1.
Record of Decision, EP A Region I (September 28, 1990).
11.0 Potentially Responsible Party (PRP)
11.9 PRP-Specific Conespondence
Letter from Merrill S. Hohman, EPA Region I to James I. Speigel, Kayser-Roth
Corporation (September 19,1984). Concerning notice of potential liability.
Letter from Merrill S. Hohman, EPA Region I to Henry Richards,
Hydro-Manufacturing, Inc. (October 23,1984). Concerning notice of potential
liability .
13.0 Community Relations
1.
2.
Please refer to the 1984 -1985 Removal Adminirtrative Recordfor additional
documenu which are included in this section by reference only.
13.1 Correspondence
Memorandum from Wendy Rundle, ICF Corporation to Patty D'Andrea, Susan
Patz and Debra Prybyla, EPA Region I (March 14, 1986). Concerning
community relations on-site discussions.
13.2 Community Relations Plans
1.
1.
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Page 5
13.3 News Clippings/Press Releases
News Clippings
1. "N. Smithfield Hoping DEM Won't Levy'Fines," The Woonsocket Call-
Woonsocket, RI {December 23, 1989).
2. "Meeting Will Air Stamina Mills Contamination," The Woonsocket Call-
Woonsocket, RI (February 14, 1990).
3. "Investigation Conf'mns Contamination Of Ground Water, Soil Near Stamina
Site," Evening Bulletin - Providence, RI (February 16, 1990).
4. "Investigation Conf'mns Contamination Of Ground Water, Soil Near Stamina
Site," The Providence Journal- Providence, RI (February 16, 1990).
5. "Residents Near Stamina Shouldn't Use Wells," The Woonsocket Call-
Woonsocket, RI (February 22, 1990).
6. "Stamina Cleanup May Take 5 Years," The Woonsocket Call- Woonsocket, RI
(February 22, 1990).
7. "Tainted Wells May Never Be Safe, EPA Says," Evening Bulletin -
Providence, RI (February 22, 1990).
8. ''The United States Environmental Protection Agency Invites Public Comment
On The Proposed Plan and Feasibility Study For The Stamina Mills Superfund
Site in North Smithfield, Rhode Island," The Woonsocket Call- Woonsocket,
RI (July 2, 1990).
9. "Showing The Stamina For Cleanup," The Observer - Greenville, RI
(July 5, 1990). .
10. "Agency Seeks Input On Cleanup," The Evening Bulletin - Providence, RI
(July 6, 1990).
11. "Agency Seeks Input On Cleanup," The Providence Joumal- Providence, RI
(July 6, 1990). .
12. "EPA To Discuss $4.3 Million Plan For Stamina Mills Superfund Cleanup,"
The Woonsocket Call- Woonsocket, RI (July 10, 1990).
13. "Stamina Mills Cleanup May Be Delayed Two Years,"
The W oonsocket Call - W oonsocket, RI (July 11, 1990).
14. "Residents Want Action On Cleanup Of Toxic-Waste Site,"
The Providence Joumal- Providence, RI (July 11, 1990).
15. "Cleanup Of Toxic Waste Under Way At Stamina,"
The Woonsocket Call- Woonsocket, RI (August 18, 1990).
Press Releases
16. "Public Meeting.Announced on Stamina Mills Hazardous Waste Site,"
EPA Region I (September 14, 1984). .
17. "Environmental News," EPA Region I (November 27, 1984). Concerning U.S.
Environmental Protection Agency announcement that it has allocated $700,000
from Superfund to provide an alternate water supply to residents of the Stamina
Mills area of Forestdale.
18. "Public Meeting to Explain Plans for the Stamina Mills Superfund Site
Announced," EP A Region I (February 24, 1986).
19. "Environmental News - EPA to Hold Meeting on Stamina Mills Cleanup Plan,"
EPA Region I (June 26, 1990).
20. "EPA Selects Cleanup Plan at Stamina Mills Superfund Site," EPA Region I
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Page 6
13.4 Public Meetings
1. EP A Region I Attendance List, Public Hearing for the Stamina Mills Superfund
Site (September 24, 1984).
2. EP A Region I Meeting Agenda, Public Meeting for the Stamina Mills Superfund
Site (March 10, 1985). Concerning overview of Superfund program and
schedule of events for the site.
3. "Final Public Meeting Summary," Camp Dresser & McKee Inc.
(April 4, 1986).
4. Letter from Richard K. Quateman, ICF Kaiser Engineers to James Sebastian,
EPA Region I (April 19, 1990). Concerning transmittal of the attached
February 21, 1990" Summary of the Public Infonnational Meeting on the
Remedial Investigation and Risk Assessment"
5. . EPA Region I Meeting Notes, Public Meeting for the Stamina Mills Site
(July 10, 1990). Concerning release of the Proposed Plan and Feasibility
Study.
6. Cross-Reference: Ttanscript, Informal Public Hearing Summary, EP A Region I
(July 31, 1990) (Fi1ed and included in Appendix C in entry number 1 in 5.4
Record of Decision (ROD)].
13.5 Fact Sheets
"Superfund Program Fact Sheet - Stamina Mills Site," EPA Region I
(March 1986). Concerning remedial investigation and feasibility study activities
to be carried out by EP A.
"Stamina Mills Superfund Site - Progress and Plans," EPA Region I
(May 1986). Concerning EP A activities and investigations underway at the site.
16.0 Natural Resource Trustee
1.
2.
J6.4 Trustee Notification Form and Selection Guide
1.
Letter from Menill S. Hohman, EPA Region I to William Patterson, U.S.
Department of the Interior (June 17, 1987) with attached trustee notification
form. Concerning notification of potential damage to natural resources at the
site. .
16.5 Tecbn.ical Iaue Papers
. .
Letter from Robert Pavia, U.S. Department of Commerce National Oceanic and
Atmospheric Administration to Dennis P. Gagne, EP A Region I
(May 17. 1990). Concerning transmittal of the attached May 17, 1990 "National
Oceanic and Atmospheric Administration Preliminary Natural Resource Survey."
17.0 Site Management Records
1.
Please refer to the 1984 -1985 Removal Administrative Recordfor documellls which
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Section II
-------
Page 7
GUIDANCE DOCUMENTS
EP A guidance documents may be reviewed at EP A Region I, Boston, Massachusetts.
General EPA Guidance Documents
1. U.S. Environmental Protection Agency. Office of Research and Development Municipal
Enviro~ta1 Research Laboratory. Biodewadation and TreatabilitY of Specific Pollutants
(EP A -600'9- 79-034), October 1979.
2. U.S. Environmental Protectica Agency. Office of Research and Development Municipal
Environmental Research Laboratcxy. Carbon Adsoq>tion ISQthenns for Toxic Orianics
(EP A-600/8-80-023), April 1980. . .
3. U.S. Environmental Protection Agency. Office of Water and Waste Management
Evaluatin~ Cover Systems for Solid and Hazardous Waste. 1980.
4. U.S. Emironmental Protection Agency. Office of Research and Development Municipal
Environmental Research Laboratory. Handbook for EvaJuatin, Remedial Action Technoloe:y
flam (EP A-600/2-83-076), August 1983.
5. U.S. Environu:tental Protection Agency. Office of Ground-Water Protection. Ground-Water
Protection Strateey. August 1984.
6. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response,
Office of Emergency and Remedial Response, and Office of Research and Development
Review of ~reatment ~hniQues for Contaminat~ace Soi~ume l:
Technical Evaluation (EPA-S40/2-84-003a), September 1984.
7. "Guidelines Establishing Test Procedures for the Analysis of Pollutants Under the Oean Water
Act; Final Rule and Interim Final Rule and Proposed Rule" (40 CFR Part 136),
October 26, 1984.
8. U.S. Environmental Protection Agency. Office of Research and Development Guide for
Decontaminatin, Buildin&s. Sttuctures. and Equipment at SQperfund Sites
(EP A-60012~85/028), March 1985. .
9. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Hazardous Response Support Division. Standard ~ratine SafetY Guides. November 1984.
10. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance Document for Cleanup of Surface Tank and Drum Sites (OSWER Directive
9380.0-3), May 28, 1985.
11. U.S. Environmental Protection Agency. Office of Research and-Development Environmental
Research Laboratory. EPA Guide for Minimizine the Adverse Environmental Effects of
Cleanup of Uncontrolled Ha~JlrrfnllS Waste Sites. (EP A-600/8-85/(08), June 1985.
12. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Gui1ance on FeasibilitY Studies under CERCLA (Comprehensive Environmental Response.
Compensation. and LiabilitY Act) (EPAlS4O/G-8S1OO3, OSWER.Directive 93SS.0-05C),
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Page 8
13. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Remedial Investi~ations under CERCLA (Comprehensive Environmental
Response. Compensation. and Liabili~ Act) (EPA/54O/G-85/002, OSWER Directive
9355.0-06B), June 1985.
14. Memorandum from Gene Lucero to the U.S. Environmental Protection Agency,
August 28, 1985 (discussing community relations at Superfund Enforcement sites).
15. U.S. Environmental Protection Agency. Office of Waste Programs Enforcement
The Endan~erment Assessment Handbook. August 1985.
16. U.S. Environmental Protection Agency. Office of Waste Programs Enforcement
Toxicoloe:y Handbook, August 1985.
17. U.S. Department of Health and Human Services. National Institute for Occupational Safety
and Health, and Occupational Safety and Health Administration. Occupational Safe~ and
Health Guidance Manual for Hazardous Waste Site Activities. October 1985.
18. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Handbook of Remedial Action at Waste Disposal Sites (EPA/625/6-85/006), October 1985.
19. U.S. Environmental Protection Agency. Office of Research and Development Hazardous
Waste Engineering Research Laboratory. Handbook: Remedial Action at Waste Disposal Sites
(Revised) (EP A/625/6-85/006), October 1985.
20. "National Oil and Hazardous Substances Pollution Contingency Plan," (40 CFR Part 300),
November 20, 1985.
21. U.S. Environmental Protection Agency. Office of Research and Development Hazardous
Waste Engineering Research Laboratory. Handbook for Stabilization/Solidification of
Hazardous Wastes (EPA/54O/2-86/001), June 1986.
22. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Draft Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites
(OSWER Directive 9283.1-2), September 20, 1986.
23. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response and
Office of Emergency and Remedial Response: Mobile Treatment Technolo~es. for Superfund
Wastes (EPA 54012-86/003 (0), September 1986.
24. COrT\Prehensive Environmental Response. Cornpensation. and Liabili~ Act of 1980, amended
October 17, 1986.
25. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Public Health Evaluation Manual (OSWER Directive 9285.4-01), October 1986.
26. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Federal-Lead Remedial Project Manaiement Handbook (EPA/54O/G-87/oo1,
OSWER Directive 9355.1-1), December 1986.
27. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund State-Lead Remedial PrQject Manaiement Handbook. '(EPA/54O/G-871OO2),
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Page 9
28. U.S. Environmental Protection Agency. Office of Research and Development Hazardous
Waste Engineering Research Laboratory. Technoloey Briefs: Data Requirements for SelectiT1&
Remedial Action TechnolQe;y (EPA/60012-871OO1), January 1987.
29. U.S. Environmental Protection Agency. Office of SolidWaste and Emergency Response.
Data Quali(y Obiectives for Remedial Re~nse Activities: Develo.pment Process
(EPA/540/G-87/003), March 1987.
30. Letter from Lee M. Thomas to James J. Florio, Chainnan, Subcommittee on Consumer
Protection and Competitiveness, Committee on Energy and Commerce, U.S. House of
Representatives, May 21, 1987 (discussing EPA's implementation of the Superfund
Amendments and Reauthorization Act of 1986).
31. Memorandum from J. Winston Porter to Addressees ("Regional Administrators, Regions I-X;
Regional Counsel, Regions [- ~ Director, Waste Management Division, Regions I, IV, V,
VII,and VIII; Director, Emergency and RemcdiaJ Response Division, Region IT; Director,
Hazardous Waste Management Division, Regions III and VI; Director, Toxics and Waste
Management Diviiion, Region IX; Directcr, Hazardous. Waste Division, Region X;
Environmental SeT"rices Division Directors, Region I, VI, and VD"), July 9, 1987 (discussing
interim guidance on compliance with applicable or relevant and appropriate requirements).
32. Memorandum from David P. Ryan, EPA Headquarters to Addressees (Assistant Regional
Administrators; Management Division Directors; Senior Budget Officers; Regional
Comptrollers; Waste Management Division Directors; ESD Directors of Regions I, VI, and Vll;
Director, Office of Emergency and Remedial Response; Director, Office of Waste Programs
Enforcement; Financial Management Officers), July 15, 1987 (Discussing determination of
indirect costs in Superfund Removal project ceilings (Comptrollers Policy Announcement
No. 87-15». .
33. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Alternate Concentration Limi1S GuYlance (OSWER Directi~ 9481.00-6C,
EPA/530-SW-87-017), July 1987.
34. U.S. Environmen1al Protection Agency. Office of Health and Environmental Assessment
A Compendium ofTechnolo,ies Used in the Treatment ofH:I7~rrlous Waste
(EPA/62S18-87/014), September 1987.
35. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Draft Guidance on CERCLA Conwliance .with Other Laws Manual (OSWER Directive
9234.1-01), November 25, 1987.
36. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
A Compendium of Superfund Field Operations Methods (EPA/5401P-87/001, OSWER
Directive 9355.0-14), December 1987.
37. U.S. Environmental Protection Agency. Office of Research and Development Treatment
Potential for 56 EPA Listed Hazardous Chemical in Soils (EPA-600/6-88-OO1),
February 1988.
38. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. Drait
Guidance on Conductin, Remedial Investieations and Feasibili(y Studies under CERCLA
(Comprehensive Environmental Response. Compensation. and Liabili(y Act), March 1988.
39. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. Drail
Guidance on Remedial Actions for Contaminated GroundWater at Superfund Sites
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Page lO
40. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Community Relations in Superfund: A Handbook (Interim Version) (EPA/HW-6, OSWER
Directive 9230.0-3A), June 1988.
41. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. Draft
Guidance on CERG...A Compliance with Other Laws Manual- Part I (EPN540/G-89/006),
August 1988.
42. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Interim Final Guidance on Conductin~ Remedial InvestiJations and Feasibility Studies under
CERG...A (Comprehensive Environmental Response. Compensation. and Liability Act),
October 1988.
.
43. U.S. Environmental Protection Agency. Office of Research and Development Site Prowam
Demonstration Test Terra Vac In Situ Vacuum Extraction System. Groveland. Massachu5et~-
Technoloe:y Evaluation Re.port (EP N540/5-89/003a), Apri11989.
44. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response~- .
Final Covers on Hazardous Waste Landfills and Surface Impoundments .
(EPAJ530-SW-89-047), July 1989.
45. U.S. Environmental ProtectionAgency. Office of Emergency and Remedial Response. Qrafi
Guidance on CERG...A Compliance with Other Laws Manual- Part n (EP N540/G-89/009,
OSWER Directive 9234.1-02), August 1989.
46. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Detenninin~ Soil Response Action Levels Based on Potential Contaminant Miwation to
Ground Water: A Compendium of Examples (EPN540/2-89/057), October 1989.
47. U.S. Environmental Protection Agency. Office of Research and Development Site Prowam
Demonstration of the Ultrox International rntraviolet Radiation/Oxidation Technoloe:y -
Technolo&y Evaluation Report (EPN540/5-89/012), January 1990.
48. "National Oil and Hazardous Substances Pollution Contingency Plan; Final Rule"
(40 CPR Part 3(0), March 8, 1990.
49. U.S. Environmental Protection Agency. Office of Research and Development Basics of
Pump-and-Treat Ground-Water Remediation Technoloe:y (EPN600/8-90/003), March 1990.
50. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
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